In the recently released GAO report to congress “Civilian Intelligence Community – Additional Actions Needed to Improve Reporting on and Planning for the use of Contract Personnel” (GAO-14-204 – pdf) the GAO takes the Intelligence Community (IC) to task for being unable to document or validate the utility of their contractor work force.
The GAO report specifically called out how 40 percent of the reviewed contract records did not contain evidence to support the use of the contract personnel. The GAO observes, “Without guidance, strategies, and tools related to these types of functions, the eight civilian IC elements may not be well-positioned to identify and manage related risks.” The report noted only the Department of Homeland Security and Department of State had issued policies which address the requirements of the Office of Federal Procurement Policy, concerning “contracting for services that could affect government’s decision-making authority.” (Note: The US IC comprises 17 different organizations, of which eight are civilian.)
RESPONSIBILITY OF MANAGEMENT
If you are responsible for the use of contract personnel whose scope of work includes “intelligence collection, processing, and analysis, along with program management” in the execution of your mission, it is incumbent upon you to invest in the process, from tooth to tail. In the event these personnel are performing staff-like work, the need to ensure that their services, which may be core to mission success, fall under the appropriate authorities of the contracting office and are not involved in the formulation of policy, “as setting agency policy and issuing regulations, are inherently government and must be performed by federal employees.” Furthermore, when a GAO report calls out specific civilian and Department of Defense (DOD) entities as being unable to determine the number of contractor FTE (full-time-equivalent) personnel, one clearly is missing some of the administrative steps. This begs the question, What value are the contractor FTE’s? The IC entity is expending funds, but are unable to account for the purpose or positive impact the contracted FTE is making to the IC entity’s mission.
RESPONSIBILITY OF INDIVIDUAL CONTRACTORS
On the other side of this coin are the individual contractors. Contracting firms and individual contracting personnel can help themselves by ensuring their statement of works include the level of specificity of the expected outcomes of their work, to include specific impact statement associated with Key Performance Indicators (KPI). This will enable their IC contracting officer to be successful in reporting up the administrative food-chain the rationale for and the specific mission impact of the contractor’s efforts. Additionally, it is totally appropriate to include a reference to the appropriate IC entity’s policies on the specific triage expected of the FTE contractor when faced with situations or decision points which may affect the agency policies or regulations, two specific areas which fall under the remit of federal employees.
