The Latest Developments in Army Acquisition Reform
One week before the Thanksgiving holiday the Acting Secretary of the Army, Ryan McCarthy, issued a series of memoranda outlining expectations that Army leadership has for moving forward its Acquisition Reform Initiative. These pieces include Improving the Integration and Synchronization of Science and Technology, Streamlining Test and Evaluation and Minimizing Redundant Testing, Aligning Sustainment Policy to Foster Cost Efficiency and Improved Readiness, Enabling the Army Modernization Task Force, Improving Cost Estimation and Resourcing, Assessing Performance with Metrics, and Streamlining the Contracting Process. In today’s post we’ll take a look at the guidance in the “Streamlining the Contracting Process” memo and the importance this guidance may hold for Army contractors.
Army Directive 2017-32 (Acquisition Reform Initiative #6: Streamlining the Contracting Process) addresses challenges the Army faces when delivering capabilities to warfighters in a timely manner. Under current regulations, it can take 1-2 years to develop and award a contract, which is far too long if the Army is going to effectively respond to the changing nature of threats presented by real and potential adversaries. In order to speed up the acquisition process Acting Secretary McCarthy is directing the Assistant Secretary of the Army (ASA) (Acquisition, Logistics and Technology) to implement the following measures by no later than April 30, 2018:
- Centralize policy under the Deputy ASA (Procurement) to standardize contracting policy across the Army and remove unnecessary or outdated policies that delay the contracting process.
- Review regulatory thresholds for key contracting approval authorities and identify opportunities for further delegation than currently authorized to reduce delays in the procurement process.
- Complete a review of the 350 potential required contract file documents to identify and reduce contract documentation requirements and identify streamlining opportunities. The goal is to reduce contract file documents by at least 10%.
- Review source selection policies, procedures, and training and identify opportunities for increased standardization, greater sharing of best practices, and training for source selection evaluations, cost and price evaluations, and the conduct of debriefings.
- Assess current training requirements for the Defense Acquisition Workforce Improvement Act and findings from the most recent skill gap analysis.
- Direct Heads of Contracting Activities to examine their internal organizational structures and develop plans for the optimization of mission, people, and processes across each activity.
- Develop a process for early engagement between requiring activities and contracting to address deficiencies in the definition of the requirement and preparation of the contract request package.
- Establish a Program Integrator and Review Board policy to review contract document packages before they are submitted to the contracting office.
- Update and reissue policy memoranda aligning contracting offices with customers.
- Write a legislative change proposal for inclusion in the FY 2020 NDAA to reduce extended protest periods and to establish a statute allowing the Government to recoup costs associated with “frivolous” protests.
- Direct Army Materiel Command to establish a Contracting-Acquisition Review Board with leadership at the appropriate general officer level to drive collaboration of acquisition and non-acquisition stakeholders for Acquisition Categories I, II, and III acquisition programs.
The directives outlined by Acting Secretary McCarthy aim to standardize the Army acquisition process and inject better trained acquisition personnel into the mix, steps that could make the system more efficient if they are properly implemented. The alignment of contracting activities and Army customers should also improve the development of Army requirements and contracts to procure those requirements, but it is hard to see how additional reviews at the Program Integrator and Review Board and customer command levels would do anything other than slow procurements. A dollar threshold for reviews would limit the number of them, but this step is not outlined in the memorandum. Finally, the proposal to add language to the FY 2020 NDAA concerning protests mirrors changes to protest procedures in previous NDAAs making protesting increasingly risky if it is used as part of a vendor’s competition practices.
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