April 15, 2013, POGO Letter to OMB
April 15, 2013
Office of Federal Procurement Policy
Office of Management and Budget
ATTN: Ms. Aisha Hasan
725 17th Street, N.W.
Washington, D.C. 20503
Submitted via regulations.gov
Subject: Public Comments on the Use of Cost Comparisons
Dear Ms. Hasan:
The Project On Government Oversight (POGO) provides the following public comment regarding the use of cost comparisons outlined at 78 Fed. Reg. 11232 (February 15, 2013). Founded in 1981, POGO is a nonpartisan independent watchdog that champions good government reforms. POGO’s investigations into corruption, misconduct, and conflicts of interest achieve a more effective, accountable, open, and ethical federal government. POGO has a keen interest in government contracting matters, especially the important but often ignored issue of service contracting costs.
The Office of Federal Procurement Policy (OFPP) in the Office of Management and Budget (OMB) announced a public meeting on March 5, 2013, and requested public comments on “the practice of comparing the relative cost of performance by Federal employees versus contract performance in order to identify the most cost-effective source.” POGO hopes that all of the oral and written comments will be used to create a comprehensive cost comparison model that will be used when making human capital planning decisions.
Establishing a uniform, effective cost comparison model is one of the most, if not the most, important tasks facing the government today. This model, whether established by improving the A-76 process or building a new cost comparison process, must be initiated earlier in the human capital policy and planning phase. It also must compare the full life-cycle costs of outsourcing federal services to contractors with the costs of having those services performed by federal employees.
POGO realizes that such a system is difficult to create and will be subject to harsh criticism by all stakeholders involved. However, previous decisions to hire military or civilian personnel or to contract out have often been made without any strategic thinking about government operations and costs, and that needs to change. Continue reading “Feds vs. Contractors: Federal Employees Often Save Money, But an Advisory Panel is Needed to Create a Cost Comparison Model”