AFFARS PGI 5301
Federal Acquisition Regulations System
Table of Contents
Click any column header below to sort by that column.
|
PGI Paragraph |
MAJCOM |
Paragraph Title |
|
AFICC |
(No Title) |
|
|
AF |
FAR Conventions |
|
|
AFICC |
Peer Reviews |
|
|
SMC |
Peer Reviews |
|
|
AF |
Pre-award Peer Reviews |
|
|
AF |
Post-award Peer Reviews of Service Contracts |
|
|
AF |
Administration of Peer Reviews |
|
|
AFMC |
Designation of Subject Matter Experts (SME) |
|
|
SMC |
Agency Control and Compliance Procedures |
|
|
AFICC |
Class Deviations |
|
|
SMC |
HCA Matrix |
|
|
USAFA |
HCA Responsibilities |
|
|
AFICC |
Air Force Contracting Self-Inspection System |
|
|
AFMC |
Air Force Contracting Compliance Inspection Program |
|
|
AFMC |
Responsibilities |
|
|
SMC |
Responsibilities |
|
|
AF |
Procedure for Processing Ratifications of Unauthorized Commitments |
|
|
AFMC |
Standardized Contracting Officer Warranting |
|
|
SMC |
Selection, Appointment, and Termination of Appointment for COs |
|
|
USAFA |
General |
|
|
AFICC |
Selection |
|
|
AFDW |
Clearance |
|
|
AFICC |
Clearance |
|
|
AFMC |
Clearance |
|
|
USAFA |
Clearance |
|
|
AFICC |
Air Force Installation Contracting Center Clearance Delegations |
|
|
AFMC |
Clearance Delegations |
|
|
SMC |
Policy, Thresholds, and Approvals |
|
|
AF |
Clearance: Multi-Functional Independent Review Teams |
|
|
AFMC |
Clearance Request |
|
|
AFMC |
Clearance Documentation |
|
|
AF |
Ombudsman Program |
|
|
AFMC |
Ombudsman Program |
|
|
SMC |
Ombudsman Program |
|
|
AFICC |
Ombudsman |
|
|
USAFA |
Ombudsman Program |
AF PGI 5301
Federal Acquisition Regulations System
AF PGI 5301.108 FAR Conventions
(b) Submit delegations to SAF/AQCP for inclusion in the PGI.
(c) The total estimated value of an acquisition is the basis for determining the applicable dollar threshold.
(1) For competitive, multiple award acquisitions, the total estimated value is the cumulative value of all potential awards, except for A&E services, BAAs, SBIRs, and STTRs, use the individual contract value;
(2) For competitive acquisitions, the highest proposed amount in the competitive range;
(3) For sole source acquisitions, the negotiation objective including any requested settlement range;
(4) For modifications, the sum of the absolute value of the price increase and/or decrease is the total estimated value. For example, a price increase of $4M and decrease of $3M results in an estimated value of $7M;
(5) The total estimated value of a BPA or task and delivery order an indefinite delivery type contract is the estimated value of all future orders; and
(6) For defective pricing actions, the DCAA Recommended Price Adjustment (RPA).
AF PGI 5301.170-2 Pre-award Peer Reviews
(a) For Competitive Actions valued at $1B or more: [See DFARS Class Deviation 2019-O0010, Peer Reviews of Competitive Contracts for Supplies and Services (OUSD(A&S)/DPC Memo, 6 Sep 19)].
(1) Phase 1 Peer Reviews (prior to issuance of the solicitation) may occur before or after the Business Clearance Session with the DAS(C)/ADAS(C) (see MP5301.9001(i)(1)(i)(B). The assigned SAF/AQC action officer communicates with the OUSD(A&S)/DPC Peer Review program coordinator regarding the specific timing of the review. Subsequent to a successful Business Clearance Session with the DAS(C)/ADAS(C), the contracting officer uploads the required pre-negotiation clearance documents to the DoD Peer Review website.
(2) Phase 2 Peer Reviews (prior to request for final proposal revisions, if applicable) may occur before or after the Contract Clearance. Coordinate the timing of the review with the CAA prior to proceeding. The contracting officer is responsible for coordinating the timing of the review with the OUSD(A&S)/DPC Peer Review program coordinator. Subsequent to a successful Contract Clearance Session, the contracting officer uploads the required clearance documents to the DoD Peer Review website.
(3) Phase 3 Peer Reviews (prior to contract award) occur after the Contract Clearance Session with the CAA. The contracting officer is responsible for coordinating the timing of the review with the OUSD(A&S)/DPC Peer Review program coordinator and uploading the appropriate documents to the DoD Peer Review website. The contract may not be awarded until all Peer Review recommendations have been addressed.
(b) For noncompetitive actions valued at $500M or more:
(1) Phase 1 Peer Reviews (prior to commencement of negotiations) occur after the Business Clearance Session with the DAS(C)/ADAS(C) (see MP5301.9001(i)(1)(i)(A)(8)). The assigned SAF/AQC action officer communicates with the OUSD(A&S)/DPC Peer Review program coordinator concerning the specific timing of the review. Subsequent to a successful Business Clearance Session with the DAS(C)/ADAS(C), the contracting officer uploads the required pre-negotiation clearance documents to the DoD Peer Review website.
(2) For Phase 2 Peer Reviews (prior to contract award), the assigned SAF/AQC action officer communicates with the OUSD(A&S)/DPC Peer Review program coordinator concerning the specific timing of the review. The contracting officer uploads the Final Price Negotiation Memorandum to the DoD Peer Review website and emails a copy of the Final PNM to SAF/AQC. On a case-by-case basis, additional supporting documentation may be requested in support of the Peer Review. The contract may not be awarded until disposition of any Peer Review recommendations.
AF PGI 5301.170-3 Post-award Peer Reviews of Service Contracts
The contracting officer notifies the cognizant SAF/AQC action officer of all Peer Reviews to be accomplished in accordance with DFARS PGI 201.170-3 at least 10 business days prior to the required review.
AF PGI 5301.170-4 Administration of Peer Reviews
The contracting officer simultaneously provides a copy of the memorandum documenting disposition of all Peer Review recommendations to OUSD(A&S)/DPC, SAF/AQC, and their SCO.
AF PGI 5301.602-3-90 Procedure for Processing Ratifications of Unauthorized Commitments
(a) The contracting officer initiates an investigation by requesting the office(s) involved to provide documentation and evidence concerning the unauthorized commitment.
(b) The commander of the organization in which the unauthorized commitment occurred ensures the following are provided to the contracting officer within 30 days of the request:
(1) A report on the circumstances surrounding the unauthorized commitment, to include a statement on corrective actions taken to prevent a recurrence of the event and a description of disciplinary action taken, or an explanation as to why no action was taken.
(2) A signed statement from the individual who made the unauthorized commitment detailing the incident. If a statement is unavailable, the commander explains in the report the reason for not providing the individual's statement.
(3) Relevant documentation and records, (e.g., evidence the supplies or services were received, accepted, and were of benefit to the government, contractor correspondence and invoice, funds availability statement, etc.).
(c) The contracting officer analyzes the documentation and, if ratification is appropriate, prepares the ratification file, which includes the following:
(1) Statement of the contracting officer that summarizes the case and addresses each of the elements contained in FAR 1.602-3(c).
(2) Legal opinion.
(3) Contractor's invoice with relevant correspondence.
(4) The report by the organization in which the unauthorized commitment occurred--prepared in accordance with paragraph 2 above. Include any attachments to the report.
(d) The ratification statement reads substantially as follows:
“Pursuant to the authority vested in me by AFFARS 5301.602-3(b)(2), I hereby ratify the act of (name, title, grade, and organization), who on or about (date) authorized (company name) to (commitment). The dollar value of the transaction is (dollar amount). Ratification is deemed to be in the best interest of the government and is within the authority and limitations of FAR 1.6 and supplements thereto.”
(e) For ratification of unauthorized commitments equal to or greater than $30,000 of appropriated funds, the contracting officer forwards the file through the wing commander for review by the SCO. For organizations that do not have a wing commander or equivalent, forward the file to the Center Technology/Functional Director for review. The contracting officer should include words substantially as follows:
"Attached is the ratification file concerning the unauthorized contracting act of (name) for your review. If you concur ratification of this act is appropriate, this file is be forwarded to the Head of the Contracting Activity (HCA) designee for final approval."
(f)
(1) Tenant organizations with contracting authority: When an unauthorized commitment occurs within a tenant organization, the ratification is processed through the tenant’s chain of command.
(2) Tenant organizations without contracting authority: The host command investigates, process, and, if appropriate, approve the ratification. The host command provides copies of the ratification to the tenant’s parent organization.
(g) After execution of the ratification statement by the appropriate authority, the contracting officer processes the ratification action. A copy of the ratification statement is included in the contract file. A copy of the contract is placed in the ratification file.
(h) Organizations may use the Ratification Action template when preparing ratifications.
AF PGI 5301.9001(b) Clearance: Multi-Functional Independent Review Teams
1. Objective. The use of multi-functional independent review teams (MIRT) is considered a best practice for high dollar value or complex competitive acquisitions. MIRTs conduct independent reviews to ensure the quality and effectiveness of the competitive contracting process, and may facilitate cross-sharing of best practices and lessons learned. The MIRT operates in an advisory capacity in its assessment of the acquisition approach employed, and the consistency and sufficiency of the source selection team products.
2. Guidelines.
To promote an understanding of the MIRT process and to ensure the process is value added, the CAA and SSA should establish the rules of engagement for the MIRT (e.g., how many reviews are planned, the expected duration of each review, and what is required to close MIRT comments prior to the CAA granting clearance, as well as the relationship between the clearance process and source selection process events).
3. Typical MIRT Process.
3.1. The CAA should establish an independent and objective process, tailored to the needs of the acquisition, employing cross-functional subject matter experts (SME) with source selection experience and knowledge of current source selection procedures. The CAA should ensure that the established review process encourages frank and open discussion among MIRT members concerning their observations and recommendations.
3.2. For maximum benefit, MIRTs should be formed at the beginning of an acquisition with membership agreed to by the CAA. When the DAS(C) or ADAS(C) is the CAA, the SCO may appoint the MIRT and interact with the SSA as needed. Recommended team members include the Technical/Requirements Activity, Legal, Contracting, Finance/Cost, Small Business, and participants from other specialized areas as needed. A member from the SAF/AQCP Field Support Team may be requested to participate on MIRTs when DAS(C) or ADAS(C) is the CAA or on a case-by-case basis. Submit requests for SAF/AQCP participation to SAF/AQCP. To promote consistency, the same MIRT members should participate in each critical decision point review for the duration of the acquisition unless otherwise agreed to by the CAA. To prevent bias, MIRT members should not be members of the source selection team. The use of contractors on a MIRT is discouraged.
4. Critical Decision Points (CDP). The CAA and SSA typically determine the CDPs, or other focus areas, to be reviewed by the MIRT for each acquisition. The CDPs below are examples of opportunities for MIRT activity. CDPs 1 and 2 would occur prior to the request for Business Clearance, and CDPs 3, 4 and 5 would occur prior to request for Contract Clearance.
CDP#1: Review draft ASP Brief or review of draft Acquisition Plan (AP). (Includes review of requirements documents, results of market research and risk assessment, and incentive structure, as applicable.)
CDP#2: Review Sections L and M of the Request for Proposal (RFP). (Includes review of Source Selection Plan, requirements documents, and other portions of the solicitation, as necessary, to ensure executable evaluation criteria.)
CDP#3: Review draft Initial Evaluation/Competitive Range Brief or review of draft Award without Discussions Brief. (Review of these draft briefs includes review of supporting documentation and evaluation notices or interim ratings, etc.)
CDP#4: Review draft Final Proposal Revision (FPR) Request. (Review of this draft brief includes review of pre-FPR brief including interim ratings after discussions, etc.)
CDP#5: Review draft Source Selection Decision briefing. (Review of this draft brief includes review of the Source Selection Evaluation Board Report, Source Selection Advisory Council Comparative Analysis Report and Award Recommendation, etc.)
5. MIRT Work Product. The MIRT typically out briefs the source selection team at the conclusion of each MIRT review conducted, and an assessment to the CAA on the state of the acquisition. The MIRT assessment and contracting officer disposition of MIRT comments/recommendations may be included with the applicable Business and Contract Clearance requests at the CAA’s discretion. Contracting officers should advise the CAA of any unresolved MIRT comments. The SSA should be provided a copy of MIRT reports for their information and use as appropriate.
AF PGI 5301.91 Ombudsman Program
The Ombudsman for each MAJCOM/DRU/FOA is identified on the Air Force Contracting POCs page.
AFDW PGI 5301
Federal Acquisition Regulations System
AFDW PGI 5301.90 Clearance
For Enterprise programs, the AFDW SCO establishes the below approval thresholds for AFDW/PK as follows:
|
Contract Value |
Enterprise Contracting Program Clearance Approval Authority |
|
>$50M to <$1B |
SCO |
|
>$25M to $50M |
COCO |
|
>$5M to $25M |
Two levels below the SCO |
For Operational programs, the AFDW SCO establishes the below approval thresholds for 11CONS as follows:
|
Contract Value |
Operational Contracting Program Clearance Approval Authority |
|
>$10M to <$1B |
SCO |
|
$2M to $10M |
COCO |
|
>$500K to <$2M |
One level above the CO |
This PGI applies to all acquisitions of supplies, services, construction and R&D purchased with appropriated funds by operational acquisition units (contracting offices and squadrons) within the Air Force Installation Contracting Center (AFICC), Air Combat Command (ACC), Air Force Global Strike Command (AFGSC), Pacific Air Forces (PACAF), Air Mobility Command (AMC), Air Force Special Operations Command (AFSOC), Air Force Space Command (AFSPC) except Space and Missile Systems Center, Air Education & Training Command (AETC) and United States Air Forces Europe & Air Forces Africa (USAFE-AFAFRICA).
The PGI is not a standalone document, it is used in conjunction with the FAR and FAR Supplements.
AFICC PGI 5301.170 Peer Reviews
On a case-by-case basis, the AFICC OL SCO may require an advance review of Peer Review documentation prior to the submission to the DoD Peer Review website.
Class Deviations that impact more than one AFICC OL are typically coordinated through AFICC/KP to SAF/AQC.
AFICC PGI 5301.601-91 Air Force Contracting Self-Inspection System
In accordance with AFI 90-201, The Air Force Inspection System and AFFARS MP5301.601-91, Air Force Contracting Self-Inspection Program, all contracting offices/squadrons will have a Self-Inspection Program (SIP) that assesses contract files and management programs. This PGI establishes the standardized process for performing self-inspections of contract actions/files and support the Unit Self-Assessment Program Managers (USAPMs) in the completion of both the Air Force Contracting Self-Assessment Communicator (AQC 2) and Air Force Operational Contracting Self-Assessment Communicator for Operational Contracting Squadrons Only (AQC 3), both of which are found in the Management Internal Control Toolset (MICT) system.
Each contracting office/squadron is responsible for ensuring their contract actions reflect good business judgment and comply with applicable statutes, regulations and policies. The self-inspection process includes the selection of previously awarded and/or completed contract actions, both above and below prescribed clearance review thresholds, for review by the office/squadron’s Self-Inspection Program (SIP) Team. Through review of previous contract actions and gap analysis, the identification of best practices, trends or areas of concern (AOCs) should result in recommendations for sharing lessons learned, recommended areas for improvement (i.e., RIAs) and/or the development of corrective action plans (CAPs). The process is iterative and requires proactive trend and issue identification with the goal of improving the quality of the resultant contract files as well as the overall acquisition health of the unit.
Commanders/Directors appoint a Unit Self-Inspection Program Manager (USIPM) with overall responsibility for the self-inspection process to include use of appropriate checklists, worksheets or other tools, collation of self-inspection data, completion of the Unit Self-Inspection Report and submission of the report to the cognizant senior functional (contracting) leadership. Based on the volume and complexity of actions to be reviewed, the USIPM assigns an appropriate number of assessors to complete the self-inspection, to include entry of all required data into the appropriate self-inspection worksheets and checklists, analysis of self-inspection data (including subjective observations/comments), culminated by the completion of the written report.
The USIPM and assigned assessors should possess the minimum requisite skill level of APDP Level II in Contracting and have no less than five years of experience in the contracting career field. When required, the USIPM/SIP Team will brief the results of the self-inspection, to include open observations, corrective actions, repeat findings and all pertinent information to the COCO and/or SCO or designee (reporting requirements are determined by the SCO).
SIP Teams should assess contract actions/files using the applicable portions of the Air Force Contracting Self-Inspection Checklist and whenever possible, teams should utilize the self-inspection capability of KT FileShare to assist them in completing the Unit Self-Inspection Report. At a minimum, SIP Teams will review the specified number of contract actions (by type) for the current or previous fiscal year (not to exceed 12 months prior to the date of the self-inspection unless a review of the basic contract is necessary) in accordance with the table below.
AFICC Self-Inspection Program – Minimum Action Review Requirements
|
If the Action type* is: |
And the Total Number of Actions for the previous FY or 12 mos is: |
Then the Minimum** Number of Actions (by type) to be Reviewed is: |
|
Competitive Awards (including multiple award ID/IQ task/delivery orders) |
1—500 |
10% or 25 actions–
|
|
Over 500 |
5% or 50 actions–
|
|
|
Non-Competitive Awards (including orders issued citing a Fair Opportunity Exception, 8(a) SB set-asides and other mandatory or designated sources) |
1—500 |
25% or 50 actions–
|
|
Over 500 |
10% or 100 actions–
|
|
|
Modifications
|
1—500 |
10% or 25 actions–
|
|
Over 500 |
5% or 50 actions –
|
|
|
BPAs, BOAs and associated Calls/Orders |
1—500 |
All Blanket/Basic Agreements & 10% or 25 Calls/Orders–
|
|
Over 500 |
All Blanket/Basic Agreements & 5% or 50 Calls/Orders–
|
|
|
Terminations, UCAs, Protests, Ratifications and other extraordinary contract actions |
1—500 |
ALL |
|
Over 500 | ||
|
OT-P Agreements/Awards and contract awards as a result of the Defense CSO Pilot Program |
1—500 |
ALL |
|
Over 500 | ||
|
*This list is not inclusive of every type of contract action or agreement; Commanders/Directors may include other contract action types or specific actions as they deem necessary. **If the total number of actions available for review is less than the mandatory minimum, all files for that action type should be reviewed. Note: To ensure maximum fidelity in the resultant SIP data and to determine the overall acquisition health of the office/squadron, actions chosen for review should be selected from the entire contract portfolio, to include the responsible flights, divisions, teams and individual contracting officers. | ||
Unless otherwise directed by their senior functional leadership, MAJCOM, Center and/or Wing’s policy, Commanders/Directors can exercise their own discretion in deciding the interval of their self-inspections/assessments. However, at a minimum, OAUs should perform an annual self-inspection which should be completed NLT 15 November, the results of which should be provided to the cognizant AFICC senior functional leadership with an informational copy provided to the AFICC Policy & Acquisition Support Directorate (AFICC/KP).
AFICC PGI 5301.603-2 Selection
For AFICC warranting procedures, see the AFICC Warrant Process Guide (located within the “Warrants” focus area of the AFICC Academy).
The standard AFICC Clearance process is typically used for all contract actions requiring clearance. The contracting officer typically allows at least 5 business days after receipt of a complete clearance request package by the cognizant AFICC reviewing office for completion of a clearance review. Clearance request packages received after 1300 local time should be logged as received the following business day. Additionally, contracting officers should anticipate approximately 3 additional business days for Clearance Approval Authority (CAA) review. Clearance Reviews should be accomplished using KT FileShare.
Business and Contract Clearance Approvals
Prior to requesting clearance, the contracting officer should ensure all required clearance documentation is uploaded to KT FileShare, followed by an e-mail to the cognizant AFICC OL workflow account requesting assignment of a Clearance Reviewer. When the CAA requires Clearance briefing charts, contracting officers may use the AFFARS template, AFICC template, or a locally developed template. Competitive RFP amendments should be reviewed and approved by the CAA prior to issuance (not applicable to administrative changes).
Noncompetitive Contract Actions
Unless otherwise exempted, a Preliminary-Price Negotiation Memorandum (P-PNM) is typically used to explain the rationale applied to arrive at the Government objective by cost element. For purposes of the clearance process, Architect-Engineering Services should be handled as noncompetitive acquisitions. Business clearance approval is required prior to beginning negotiations with the contractor.
Competitive Contract Actions
For competitive Contract Clearance the CAA may be invited to the SSA briefing.
Clearance Exclusions
Unless otherwise prohibited, when excluding task or delivery orders from business or contract clearance, Contracting officers typically document their clearance exclusion decision, the record of which should be included in the contract file for every order. Contracting officers may utilize the Fair Opportunity Order Clearance Exclusion MFR template (not yet uploaded to PGI Library) to exclude an order from business or contract clearance.
AFICC PGI 5301.9001 Air Force Installation Contracting Center Clearance Delegations
This PGI sets forth approval authorities and delegations that are specific to AFICC and its AF MAJCOM Operating Locations. Contracting Offices/Squadrons that receive their contracting authority from AFICC are responsible to execute the authorities provided to them by their cognizant AFICC Senior Contracting Official. Specific delegated authorities can be found by accessing the EIS sites of the respective AFICC OLs.
AFICC – Air Force Installation Contracting Center
AFICC/KC – Air Combat Command (ACC)
AFICC/KG – Air Force Global Strike Command (AFGSC)
AFICC/KH – Pacific Air Forces (PACAF)
AFICC/KM – Air Mobility Command (AMC)
AFICC/KO – Air Force Special Operations Command (AFSOC)
AFICC/KS – Air Force Space Command (AFSPC)
AFICC/KT – Air Education & Training Command (AETC)
AFICC/KU – United States Air Forces Europe & Air Forces Africa (USAFE-AFAFRICA)
Contracting officers should include the responsible AFICC Operating Location Ombudsman in all solicitations/RFPs and contracts (refer to AFFARS 5352.201-9101).
(a) The Air Force Installation & Mission Support Center Ombudsman is:
Air Force Installation Contracting Center,
Policy & Acquisition Support Directorate (AFICC/KP)
1940 Allbrook Drive, Building 1
Wright-Patterson AFB OH 45433
Phone: (937) 257-5529
Fax: (937) 656-0919
(c) Contracting officers should include the responsible AFICC Operating Location Ombudsman in all solicitations/RFPs and contracts (refer to AFFARS 5352.201-9101, OMBUDSMAN (JUN 2016)). Contracting officers should refer to the applicable AFICC PGI Appendix for more information concerning MAJCOM specific designations, delegations and authorities.
AFMC PGI 5301
Federal Acquisition Regulations System
AFMC PGI 5301.290 Designation of Subject Matter Experts (SME)
The SMEs for all matters related to the various parts of the FAR, DFARS, AFFARS, and the AFMC PGI can be found at the HQ AFMC/PK POC Index.
AFMC PGI 5301.601(a)(i)(A)
|
All SCOs in: |
Grant Authority |
Cooperative Agreement Authority |
Other Transaction Authority for Research |
Other Transaction Authority for Prototype |
Other Transaction Authority for Experimental |
|
AFICC |
No |
No |
No |
Yes |
Yes |
|
AFLCMC |
No |
No |
No |
Yes |
Yes |
|
AFNWC |
No |
No |
No |
Yes |
Yes |
|
AFRL |
Yes* |
Yes* |
Yes |
Yes |
Yes |
|
AFSC |
No |
No |
No |
Yes |
Yes |
|
AFTC |
No |
No |
No |
Yes |
Yes |
*Grant appeal authority is retained by HQ AFMC/PK.
AFMC PGI 5301.601(a)(i)(A)(S-91)
(a) The AFNWC/PZ SCO retains all HCA delegated responsibilities with the exception of delegating the authority to enter into, approve, modify, and terminate contracts to the SCO at Eglin AFB, Hanscom AFB, Hill AFB, and Tinker AFB for all AFNWC contracting personnel residing at their respective locations.
(b) The AFLCMC SCO has delegated all delegable HCA responsibilities, to include the authority to enter into, approve, modify and terminate contracts, to the AFSC SCO for all AFLCMC contracting actions executed at Tinker AFB. The AFSC SCO has further delegated all delegable HCA responsibilities, to include the authority to enter into, approve, modify and terminate contracts, to the SCO equivalents at Hill AFB and Robins AFB for all AFLCMC actions executed at their respective locations.
AFMC PGI 5301.601-91 Air Force Contracting Compliance Inspection Program
Reference MP5301.601-91, Air Force Contracting Compliance Inspection Program
(a) AFMC Contracting Self-Inspection Process - Introduction
This PGI establishes the AFMC standardized process for Contracting Unit Self-Inspections of awarded actions using the Air Force Contracting Self Inspection Checklist. Each Center and Operating Location (OL) contracting unit (referred to in this document as the “Contracting Office”) should conduct unit self-inspections to ensure contracting actions reflect good business judgment, compliance with existing statutes, regulations, and policies (including AFI 90-201, The Air Force Inspection System’s purpose to identify, and report issues); and enable proactive trend and issue identification to improve acquisitions in the long term. The process addresses self-inspection from the identification of awarded actions below prescribed clearance review thresholds chosen for review, through review, trend/Area(s) of Concern (AOC) analysis, Corrective Action Plan (CAP) development, and data entry/final resolution. The Self-Inspection Program Monitor (SIPM) briefs Management Internal Control Toolset (MICT) status to the SCO and actions are considered complete when Contracting Office SCO has been briefed on closure of any corrective action, and closure in the system.
(b) Applicable Publications, Regulations, and Checklists
● AFI 90-201
● AFI 90-201 AFMCSUP
● AFFARS 5301.601-91
● AFFARS MP5301.601-91
● Air Force Self-Inspection Checklist
● AFMCI 64-116
(c) Roles and Responsibilities
Self-Inspection Program Monitor (SIPM): Responsible for administration of the Contracting Office’s overall Self-Inspection Program, which includes both the assessment of individual contract files and the assessment of contracting management programs. The SIPM (or alternate) is also responsible for entry, review, and monitoring of MICT.
Self-Inspection Program Point of Contact (SIP POC): The SIP POC is the liaison between the reviewed buying office, reviewers, the SIPM and the SCCO/SCO. Responsibilities include oversight of the review process within a respective buying office and collection of all inspection review sheets. The SIP POC flags all Critical, Significant, and Minor deficiencies as well as identifies any trends resulting from the unit inspection. The SIP POC is also responsible for working with the cognizant office(s) to create CAPs, where/when applicable, and monitoring CAPs through closure. Upon closure, the SIP POC should notify the SIPM of CAP completion.
Unit Self-Inspection Program Reviewer (USIP–R): For reviews done by other than a formally assigned Reviewer, such review(s) should be done by a PCO (and may be supported by a buyer). (The intent/role of the buyer is to provide a mentoring experience for junior contracting personnel to facilitate both thorough inspections and a culture of learning and professional growth.) PCOs may only review files within the scope/limit of their individual warrant. The USIP-R (or designee) is responsible for reviewing the contract file IAW Air Force Contracting Self-Inspection Checklist. The USIP-R is responsible for verifying discrepancies are corrected/fixed prior to submitting the completed inspection review sheets to the SIP POC. Should an office not have an assigned reviewer, the individual serving as the USIP-R should coordinate efforts with their assigned SIP POC and/or SIPM.
(d) Contracting Management Program IAW the AF Contracting Self-Assessment Communicator
Contracting Offices should inspect contracting management programs IAW AFI 90-201 and AFFARS MP 5301.601-91. SCOs should be regularly briefed on organization MICT status.
Contracting Office(s) may, as MICT date milestones/criteria are fulfilled/changed, enter/update as practicable. Upon closure of a MICT record for a trend/item self-inspection, the individual(s) designated to complete work on a given CAP should notify the SIPM and request closeout in the MICT system.
(e) Unit Awarded Action Self-Inspections
The self-inspection of individual contract files flows through a three phase process: first, Identification/Selection and Review of Awarded Actions; second, Analysis/Trend Identification and Corrective Action Plans; and third, Contracting Office tracking through resolution. Unit contracting self-inspection is considered complete when the SIPM (or delegate) briefs the Contracting Office SCO on successful review of actions, and the closure of any corrective action based on finding from the review(s). The data/findings from informal lower organization reviews of awarded actions may be included in the overall Contracting Office self-inspection.
(e)(1) Phase One - Identification/Selection and Review of Awarded Actions:
Unit PZCs (or their delegate if no PZC is resident at a given location) should identify and review contract actions including contracts, modifications, and orders issued since the last data pull, below the clearance review thresholds identified in the AFMC PGI.
The table below provides the minimum annual self-inspection quantities/percentages against awards with dollar values below those of clearance review thresholds. The two (2) percent standard is based on total awards of the year (not just total action count below review thresholds). The annual data pool/count is based on twelve months’ worth of data since the end of the previous year’s inspection. Self-inspections should be accomplished on a continual basis and ensure compliance, as a minimum, with the most current Air Force Contracting Self-Inspection Checklist identified in AFFARS MP5301.601-91, para 2.
|
Number of Actions |
Number/Percent of awards annually reviewed for Self-Inspection |
|
1-100 |
Five actions (or all, if less than five total awards) |
|
101 - 500 |
Five (5) actions, or no less than two (2) percent minimum - whichever is greater |
|
Over 500 |
No less than two (2) percent |
In addition to the actions inspected to meet the requirements of this process, contracting self-inspections may include additional actions above the review threshold as a secondary quality check (and final verification that final contract clearance issues were adequately addressed). All reviews in the self-inspection should be conducted on a representative sampling of actions (e.g., purchase orders, contracts, supplemental agreements, undefinitized contract actions, funding modifications, orders, option exercises, assistance instruments, etc.). Additionally, specific actions may be selected (outside of random sample) due to the high visibility, or uniqueness of a given acquisition.
While buying organizations should also conduct reviews for their own internal quality control/proactive improvement, those reviews are separate from the self-inspection addressed by this process. However, organizations are encouraged to provide such results to the Contracting Office for sharing of lessons learned/trend analysis/correct. PZC may allow for buying office augmentation of reviews. Augmentation may also be used for those organizations who do not have a resident PZC, and virtual inspection is not practicable.
Larger samples may be pulled as necessary by utilizing a percentage greater than the 2% minimum (e.g., to ensure sufficient quantities have been reviewed, to verify past corrective actions, or to support training decisions). Samples may also include actions valued above the clearance review threshold for which no review was conducted (e.g., funding modifications or option exercise).
(e)(2) Phase Two: Analysis/Trend Identification, Areas of Concern and Corrective Action Plans
Upon completion of the AF Self-Inspection Checklist, the data should be consolidated and the SIP POC should analyze and identify any trends (using the table below for trend analysis) or actions requiring further effort as CAPs or Area(s) of Concern (AOC)–reporting to Contracting Office SCO (or COCO as appropriate or two-letter local Contracting lead for those locations who do not have a SCO physically located – this distinction applies to SCO references through remainder of this document) for approval. PZC should brief or facilitate briefing to report trends and/or results of the self-assessment. The SIPM should generate or facilitate creation of CAPs with input and buy-in from affected buying offices.
CAPs should be developed and should be tracked to closure by the applicable PZC office with support from the office(s) in which the observations occurred. Systemic trends are distinguished by the reportable Contracting Office.
The following table identifies the frequency for which finding a specific checklist item may be used to identify a trend for that item. Immediate offices/locations have the discretion to initiate a CAP/below threshold, given severity or direction by higher authority at said site to proactively address for future efforts. The table provides a consistent aid for consideration of a trend for final determination/approval of trend by SCO.
|
Data Pull Sample Size |
Volume/percent within a given award assessment pull to consider as a trend for analysis for SCO) |
|
1-10 |
Three (3) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist item (whichever is greater) |
|
11-25 |
Four (4) or more findings of a given checklist item or twenty (20) to thirty (30) (or more) of actions with given checklist item |
|
26-50 |
Ten (10) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist (whichever is greater) |
|
51-75 |
Eighteen (18) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist item (whichever is greater) |
|
76-100 |
Twenty-four (24) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist item |
|
101-200 |
Thirty-six (36) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist item (whichever is greater) |
|
>201 |
Fifty (50) or more findings of a given checklist item or twenty (20) to thirty (30) percent (or more) of actions with given checklist item (whichever is greater) |
The SIPM coordinates proposed AOCs, CAPs and trends with the SCO for approval. A summary identifying all CAPs and trends are finalized and the SCO should implement and monitor corrective measures, including CAPs, if applicable. Assigned individuals working a specific CAP should report monthly on CAP status to the SIPM. The SIPM should continue to monitor any open CAPS through to completion, providing quarterly updates to the SCO. The SIPM should ensure inspections are completed using the applicable Contracting Self-Assessment Communicator or AF Contracting Self-Inspection Checklist.
(e)(3) Phase Three: Local Tracking Through Resolution:
Each Checklist inspection result is consolidated by each reportable Contracting Office and should include reportable identified Critical, Significant, and Minor trends (as established by the criteria in this process).
Unit self-inspection for a record is considered complete upon final corrective resolution out-briefed to the cognizant SCO.
(f) Deficiency Severities
Deficiency severity definitions are found in AFI 90-201, Attachment 1. There are three deficiency severities: critical, significant, and minor.
(g) Areas of Concern (AOC)
AOC merit additional attention by management, but are not of the severity that they merit a CAP. Contracting Offices can designate an item as an AOC for local focus (e.g., based on observations from recent inspection, based on new regulations being issued for that area, based on a new checklist question being added, reading other IG reports for insight, etc.). Contracting Office AOCs should be managed and closed at the level they were initiated. Creation of each AOC item should include the exit criteria for action closure.
(c)(i)(A) In addition to the matters listed in AFFARS 5301.602-2(c), contracting officers should obtain legal review for the following:
(20) Procurement integrity issues
(21) Organizational conflict of interest issues
(22) Matters related to defective pricing
(23) Advance or pre-contract cost agreements
(24) Undefinitized contract actions and change orders (initial issuance and definitization).
(c)(i)(C) See Class Deviation - Legal Review-AFLCMC/PK 19-02
AFMC PGI 5301.603 Standardized Contracting Officer Warranting
Reference AF MP5301.603, Section 2.2 Focal Points (FP)
SCOs are responsible for selecting and appointing FPs in accordance with AF PGI 5301.603, Section 2.2.
Reference AF MP5301.603, Section 2.6 Transferring Warrant Eligibility, 2.6.2. AFMC-Wide Warrants
AFMC SCO warrant program focal points or designees use the AF Contracting Officer Warrant Tracking Tool (AFCOWTT) SharePoint site to enter/track data for all COs and upload copies of SF1402s IAW AF MP5301.603.
An AFMC warrant is not terminated when a CO transfers to another AFMC Center and requires a warrant in the new position. If a warrant is required in the new position (or if it is unclear if a warrant is required in the new position) and there is a change to the appointing authority, the losing focal point or designee prepares the Contracting Officer Appointment/Warrant Eligibility Transfer/Termination Request template; ensures that the template and copies of SF1402s are properly loaded on the SharePoint site; updates the Center designation and the CO location designation in the AFCOWTT site; and notifies the gaining focal point that CO records have been transferred.
The warrant status of a transferring CO may be changed to inactive status during a transition period if the gaining appointing authority determines that a transition period is needed for the CO to become familiar with new workload responsibilities and organizational procedures. The gaining focal point prepares a letter for the gaining appointing authority to sign to change the warrant to an inactive status during a specified transition period and provides the letter to the incoming CO. The letter explains that an inactive status means that the warrant holder does not have the authority to sign/execute contract actions. At the end of the transition period, the gaining focal point prepares a letter for the gaining appointing authority to sign to change the warrant to an active status, or prepares the necessary documentation to terminate the warrant. In either case, written notification is provided to the CO and the AFCOWTT site is updated accordingly by the focal point or designee. If a CO transfers to a staff position within an AFMC Center, the CO warrant is changed to an inactive status and a formal letter from the appointing official is not required. The focal point or designee notifies the individual that the warrant is inactive and the individual does not have the authority to sign/execute contract actions. The focal point updates the AFCOWTT site accordingly.
Reference AF MP 5301.603, Section 3.4 Limited Warrants.
See Class Deviation - Limited Contracting Officer Warranting Process-AFLCMC/PK 19-01
When exercising contracting officer responsibilities, contract action value is determined by the definition in FAR 1.108(c) and AFPGI 5301.108(c).
Reference AF MP 5301.603, Section 3.5 Warrant Board, 3.5.6 Warrant Board Question Repository
AFMC PK appointing authorities obtain all warrant board questions from the AFMC Warrant Board Question Repository when convening warrant boards for individuals seeking a warrant > $5M. The repository is located at: https://cs2.eis.af.mil/sites/10148/afcc/cowbqr/_layouts/15/start.aspx#/
Only warrant appointing authorities, Enterprise Process Board (EPB) voting members, and designated focal points can access the site. For information on how to gain site access, send a request to the HQ AFMC/PK Workflow at AFMC.PK.Workflow-02@us.af.mil.
Reference AF MP 5301.603, Section 4 Appointing Contracting Officers
4.1. Certificates of Appointment-AFMC-Wide Warrant.
The organization line of the SF1402 reads: “Air Force Materiel Command”. The appointment number nomenclature is as follows: AFMC-FY-XXXX. The middle two characters for “FY” denote the fiscal year when the warrant is issued. The Center focal point or designee obtains the last two to four digits of the appointment number from the ID field of the AFMC Contracting Officer Warrant site. For example, in FY13 an ID field number of 22 would yield an appointment number of AFMC-13-0022.
The following language is typically added to appoint an individual as a combined Contracting Officer, Grants Officer, and Agreements Officer: "Unless sooner terminated, this Contracting Officer appointment is effective as long as the appointee is assigned to: Air Force Materiel Command and the Grants Officer/Agreements Officer appointment is only effective as long as appointee is assigned to: (insert Air Force Research Laboratory or applicable program).”
5301.603-2-90 Selection
(e)(4) SCOs select and appoint CCOs and terminate their appointments in accordance with this section.
5301.9001(d)(1) Within 24 hours of receipt of the contract file and applicable clearance documents, the CR should perform a cursory analysis to ensure that all required documentation is included in the contract file. The CR should review the file within five (5) business days of receipt of an acceptable file.
(2) The Reviewers Checklist may be used to complete clearance reviews.
For Air Force Life Cycle Management Center (AFLCMC): This PGI sets forth approval authorities, including any delegations that are specific to the AFLCMC contracting organizations located at Wright-Patterson Air Force Base, Eglin Air Force Base, Hanscom Air Force Base, Gunter Annex, Lackland Air Force Base, Randolph Air Force Base, Peterson Air Force Base, Offutt Air Force Base, Tinker Air Force Base, Hill Air Force Base and Robins Air Force Base.
(a) Clearance Review
|
Clearance Review | ||
|
AFLCMC Location |
Dollar Level |
Clearance Reviewer |
|
Eglin, Hanscom |
≥$10M |
Local PZC |
|
Gunter, Randolph |
≥$10M |
AFLCMC/PZC review staff, review staff at Gunter if available |
|
Peterson, Offutt |
≥$10M |
PZC (Hanscom) |
|
Lackland |
≥$25M
|
PZC (Hanscom)
|
|
Tinker, Hill, Robins |
≥$10M |
Local PZC |
|
Wright-Patterson: WFK, WVK, WWK, HIK, PZI |
≥$25M
|
Local PZC
|
|
Wright-Patterson: WIK, WLK, WKK, WNK |
>$50M
|
Local PZC
|
(b) Clearance Review for Operational Contracting actions below $10M
|
Clearance Review for Operational Contracting below $10M | ||
|
AFLCMC Location |
Dollar Level |
Clearance Reviewer |
|
Wright-Patterson, Hanscom |
≥$3M < $10M |
Local PZI Reviewer |
Clearance Approval Equivalents – Program Executive Officer (PEO) programs
The following table defines the applicable CAA for all PEO program actions, except when the DAS(C) is CAA.
|
Organization (Location) |
CAA for >$250M “SCO” |
CAA for $10M - $250M |
|
Wright-Patterson
|
AFLCMC/PK (WP) – Includes Deputy Director and Technical Director |
As assigned and documented by the COCO (Organizational Senior Functional) |
|
Eglin
|
AFLCMC/PK (Eglin) – Includes Deputy Director and Technical Director |
As assigned and documented by the COCO (Organizational Senior Functional) |
|
Hanscom
|
AFLCMC/PK (Hanscom) – Includes Deputy Director and Technical Director |
As assigned and documented by the SCO |
For Air Force Nuclear Weapons Center (AFNWC): This PGI sets forth approval authorities including any delegations that are specific to the AFNWC contracting organizations located at Kirtland Air Force Base, Hill Air Force Base, Tinker Air Force Base, and Eglin Air Force Base.
The Clearance Reviewer may delegate clearance review down one level on a case-by-case basis.
(a) Clearance Review.
|
Clearance Review | ||
|
Dollar Level |
Clearance Reviewer |
|
|
AFNWC (all locations) |
≥$5M |
Local PZC |
For Air Force Research Laboratory (AFRL): This PGI sets forth approval authorities, including any delegations that are specific to AFRL.
(a) Clearance Review
|
Clearance Review | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFRL |
≥$100M
|
AFRL/PK
|
(b) Clearance Review for Operational Contracting actions
|
Clearance Review for Operational Contracting | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFRL |
>$10M
|
AFRL/PK
|
For Air Force Sustainment Center (AFSC): This PGI sets forth approval authorities including any delegations that are specific to the AFSC contracting organizations located at Tinker Air Force Base, Hill Air Force Base, and Robins Air Force Base.
(a) Clearance Review.
|
Clearance Review | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFSC (all locations) |
≥$5M |
Local PZC |
(b) Clearance Review for Operational Contracting actions below $5M
|
Clearance Review for Operational Contracting below $5M | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFSC (all locations) |
≥$500K < $5M |
Local PZI Reviewer |
For Air Force Test Center (AFTC): This PGI sets forth approval authorities including any delegations that are specific to the AFTC contracting organizations located at Edwards Air Force Base, Arnold Air Force Base, Eglin Air Force Base, and Hill Air Force Base.
(a) Clearance Review for Enterprise Actions
|
Clearance Review | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFTC (All locations except AEDC) |
≥$5M |
Local PZC |
|
AFTC (AEDC) |
≥$5M |
Local PZZ |
(b) Clearance Review for Operational actions below $5M
|
Clearance Review for Operational Contracting below $5M | ||
|
Organization |
Dollar Level |
Clearance Reviewer |
|
AFTC (Edwards) |
≥$500K < $5M |
One level above the CO |
|
AFTC (Eglin) |
≥$500K < $5M |
One level above the CO |
AFMC PGI 5301.9001-92 Clearance Request
(a) Clearance Request. CAAs may use the Air Force Request for Clearance template, or any local template, to request both business and contract clearance review and approval, except when required to follow AFFARS 5301.9001(f)(1)(i) when the CAA is the DAS(C)/ADAS(C). When both business and contract clearance are required, submit a new request each time. Clearly identify any significant issues or unresolved comments on the “Request for Clearance.”
(b) Clearance Request -- Legal Review.
(1) Legal review should be accomplished prior to submitting actions for clearance review and approval. Simultaneous legal and clearance review may be requested only in exceptional cases and when agreed to by the program attorney and the Chief of the clearance review staff. Files submitted for clearance approval should clearly evidence local legal review and comment resolution with the program attorney. If there are unresolved legal comments they should be clearly identified in the file and highlighted in the clearance request and any clearance briefing.
(2) If any significant changes occur after legal review, or the CAA requires the contracting officer to make significant changes to the contract, then legal should review the file again.
(d) Clearance Request -- Clearance Approval. If the CAA is satisfied that the contract action/file meets the clearance objectives of AFFARS 5301.9001, the CAA signs and dates the “Request for Clearance” form. Any conditions that the CAA places on clearance approval should be specified on the “Request for Clearance.”
(f) Clearance Request -- Resubmission for Clearance Approval.
(1) Changes in acquisition strategy and/or terms and conditions may require the contract action to be resubmitted for clearance approval, for example:
(i) Exceeding approved negotiation parameters such as the cost line, contract type, profit/fee rate and (if applicable) the ceiling rate and/or incentive share ratios.
(ii) Changing contract type
(iii) Changing contract share ratio
(iv) Major change in quantity
(v) Major change in requirements
(vi) Change to a significant term or condition
(vii) Addition or deletion of a significant term or condition
(viii) Solicitation amendments (non-administrative)
AFMC PGI 5301.9001-93 Clearance Documentation
Files submitted for clearance review should include, at a minimum, the following documentation. The list below is not totally inclusive.
(a) Business Clearance for competitive acquisitions requesting approval to issue the solicitation:
(1) Solicitation (and all amendments, if applicable) in chronological order
(2) Acquisition Plan (or other Acquisition Planning Documentation)/Acquisition Strategy (as applicable)
(3) J&A (if for limited sources)
(4) Source Selection Plan (if applicable)
(5) Other applicable file items of the Contract File Content Checklist (e.g., Purchase Request, determinations, synopses, Award Fee/Incentive Plan, and if services, required documentation and Services Designated Official (SDO) approvals, and SSA briefing charts if available)
(6) Clearance briefing charts (if required by the CAA).
(b) Business Clearance for noncompetitive contract actions requesting approval to begin negotiations:
(1) J&A, Fair Opportunity Exception, or Sole Source justification restricting consideration of schedule contractors (as applicable);
(2) Acquisition Plan/Acquisition Strategy (as applicable);
(3) In-scope determination for modifications to existing contracts;
(4) Request for Proposal;
(5) Contractor proposal (or pricelists/pricing/other required documentation for orders under FSS/multiple award contract vehicles);
(6) Preliminary Price Negotiation Memorandum (Pre-PNM).
(7) Signed technical evaluation with figures that track to both the proposal and Government objective position detailed in the Pre-PNM;
(8) Draft award document (including proposed Section B CLIN structure and applicable clauses and special contract requirements) if available. If the contract action involves a contract modification, include a copy of the contract (conformed, if appropriate). If the action is a noncompetitive order provide the basic contract ordering vehicle (if available). If an action is awarded under a Broad Agency Announcement (BAA), include the BAA solicitation and proposal evaluation/selection for award documentation in addition to other required file documentation;
(9) Other applicable file items in the Contract File Content Checklist (e.g., Purchase Request, determinations, synopses, Award Fee/Incentive Plan, technical evaluations, audits or field pricing reports, and if services, required documentation and SDO approvals);
(10) Clearance briefing charts (if required by the CAA).
(c) Contract Clearance for all competitive acquisitions with discussions requesting approval to request Final Proposal Revisions (FPRs):
(1) Contractors’ proposals (and all revisions and updates if applicable) in chronological order;
(2) Evaluation Notices, offerors’ responses, and government evaluation of responses;
(3) SSEB Initial Report;
(4) Signed technical evaluation;
(5) Draft determination of adequate price competition in accordance with FAR 15.403-1(c)(1)(ii)(B) (or price evaluation documentation for orders);
(6) Proposed request for Final Proposal Revisions;
(7) Other applicable file items in the Contract File Content Checklist (including all items required for Business Clearance, updated Award Fee/Incentive Plans, (if applicable) and if services, required documentation and SDO approvals, and SSA briefing charts, if available);
(8) Clearance briefing charts (if required by the CAA).
(d) Contract Clearance for all competitive acquisitions requesting approval for the Source Selection Authority to make a source selection decision (either with or without discussions):
(1) Contractors’ proposals (and all revisions and updates if applicable) in chronological order;
(2) Proposed award document(s) in ready to award format;
(3) Signed SSEB Report (or price evaluation documentation for orders);
(4) Signed technical evaluation;
(5) Determination of adequate price competition in accordance with FAR 15.403-1(c)(1)(ii)(B) (or price evaluation documentation for orders);
(6) Other applicable file items in the Contract File Content Checklist (including all items required for Business Clearance, updated Award Fee/Incentive Plans, (if applicable) and if services, required documentation and SDO approvals, and SSA briefing charts, if available);
(7) Clearance briefing charts (if required by the CAA).
(e) Contract Clearance for all noncompetitive contract actions requesting approval to award:
(1) Proposed award document; if the contract action involves a contract modification include a copy of the contract (conformed, if appropriate). If the action is a noncompetitive order provide the basic contract ordering vehicle (if available). If an action is awarded under a BAA, include the BAA solicitation and proposal evaluation/selection for award documentation in addition to other required tab documentation;
(2) Signed PNM that complies with FAR 15.406-1 (or price evaluation documentation for orders);
(3) Signed technical evaluation with figures that track to both the proposal and Government objective position detailed in the PNM;
(4) Other applicable file items in the Contract File Content Checklist (including all items required for Business Clearance, plus the Certificate of Current Cost or Pricing Data, audits or field pricing reports not previously included in the file (as applicable), and Congressional Notification, if applicable);
(5) Clearance briefing charts (if required by the CAA).
AFMC PGI 5301.91 Ombudsman Program
5301.9102 Policy
(a) Center Commanders appoint an ombudsman (and alternate ombudsman, if desired) with notification of the appointment(s) to AFMC/PK.
For AFLCMC:
(a) Due to the organizational structure of the Program Executive Officer (PEO) Directorates and the numerous AFLCMC operating locations, it is not possible to appoint an ombudsman at every location. Therefore, AFLCMC appoints an ombudsman point of contact, independent of contracting and PEO program channels, at WPAFB in the AQ-AZ directorate. The AFLCMC ombudsman utilizes Resolution Advisors (RAs), designated from each Directorate (PEO and non-PEO), to help answer questions and resolve concerns about specific acquisition issues. All questions and concerns are directed to the ombudsman. The ombudsman can, at their discretion, call upon the RAs based on the nature of the interested party’s concern. This approach is intended to give the ombudsman flexibility to quickly resolve concerns and foster communication between Government and industry while remaining independent of established protest and dispute processes.
(1) Lt Col Brian Miller, Deputy Director, Acquisition Excellence and Program Execution Directorate, AFLCMC/AQ-AZ, as the ombudsman for AFCMC.
(2) The AFLCMC RA duties within each Directorate are performed by the Program Management Organizational Senior Functional. For the 66th Air Base Group and 88th Air Base Wing, the deputy/vice commander is the RA.
SMC PGI 5301
Federal Acquisition Regulations System
Transmittal of Peer Review Request and Applicable Documents. The contracting officer is responsible for submitting requests for Peer Review in accordance with the procedures in DFARS 201.170(a) and AFFARS 5301.170(a). For situational awareness, the contracting officer should copy the Pricing Reviewer, the Committee Reviewer and the COCO on the request for Peer Review. Documentation prepared for clearance review is ordinarily sufficient for the Peer Review. Prior to submitting Peer Review documentation to SAF/AQC and OUSD(A&S)/DPC, obtain clearance review in accordance with the procedures in SMC PGI 5301.9001. The contracting officer should share the Peer Review comments and disposition with the Pricing Reviewer and Committee Reviewer to provide insight into Peer Review results and facilitate sharing of lessons learned.
SMC PGI 5301.304 Agency Control and Compliance Procedures
(c)(4) Contracting personnel cannot assume a local clause or provision has been approved for use and may be incorporated into a contract/solicitation simply because it is in the automated contract writing system (e.g., ConWrite) clause database. The contract writing systems do not differentiate amongst outdated or unapproved provisions and clauses and approved, non-standard provisions and clauses.
SMC PGI 5301.601(a)(i)(A) HCA Matrix.
SMC PGI 5301.602-2 Responsibilities
(c)(i) Legal Review
(B) Program attorneys should use the following terminology when documenting legal review:
(a) Legally sufficient – No legal issues exist which require corrective action or further documentation prior to award, solicitation release, or other action.
(b) Legally sufficient, subject to [insert comments] – Further documentation or specified corrective action is required prior to proceeding. The file is not legally sufficient until the specified comments are resolved. The legal advice or recommendations should be accepted or resolved with the program attorney before proceeding. The program attorney may require limited resubmission of the contract file to ensure that the contracting officer’s response to the comment resolves the issue.
(c) Legally insufficient – Further documentation or significant corrective action is required prior to proceeding. The legal advice or recommendations should be accepted or resolved with the program attorney before proceeding. The program attorney is likely to require resubmission of the contract file to ensure the contracting officer’s response to the comment resolves the issue.
(d) Coordination withheld – The program attorney has determined that the file is so deficient that it is not feasible to specify all of the legal problems; or the nature of the changes required is so significant that substantial revision or rework should be accomplished which require resubmission of the entire file.
(e) Other comments/administrative comments – These comments do not affect the legal sufficiency of the file. They are provided to improve the quality or clarity of the file and can be accepted or rejected at the contracting officer’s discretion.
(f) If the legal reviewer has not clearly labeled the review using the terminology above, or you do not agree with the categorization of the comments, politely challenge the reviewer. If you cannot resolve the issue with the reviewer, elevate it through leadership chain quickly so that it does not linger and delay your action.
(iii) Committee and Pricing Reviews.
(A) Committee (SMC/PKC) Review. Contracting officers obtain Committee Review for—
(1) Actions requiring clearance at the SCO or SAF/AQC level;
(2) Non-competitive solicitations and amendments estimated at ≥ $100M (non-Operational) and ≥ $3M (Operational) prior to the solicitation review board or prior to requesting a proposal from the offeror, whichever action occurs first;
(3) Documents submitted for legal review in accordance with AFFARS 5301.602-2(c)(i)(A) and SMC MP5301.602-2(c)(i)(A), except competitive award decisions and supporting documentation for operational actions under $3M and non-operational actions under $100M;
(4) Documents, formal coordination packages, or briefings submitted for coordination or approval to the SMC Competition and Commercial Advocate, SMC/PK (or SCO), SMC/CA, SMC/CV, SMC/CC (or AFPEO/SP), or higher-level AF, DoD, or other outside authority or entity, regardless of dollar value.;
(5) Evaluation notices for non-operational source selections >$100M and operational source selections >$10M; and
(6) Other actions as directed by the COCO, or SMC/PK.
(B) Pricing (SMC/PKF) Review. Obtain Pricing Review for—
(1) Actions requiring clearance at the SCOor DAS(C)/ADAS(C);
(2) Non-competitive solicitations and amendments estimated at > $100M (Systems, Sustainment, and Enterprise and Operational Contracting-Non-Operational) and >$10M (Enterprise and Operational Contracting) prior to the solicitation review board or prior to requesting a proposal from the offeror, whichever action occurs first;
(3) New incentive and award fee plans and substantive changes to existing incentive plans and award fee plans that require SMC/CA, SMC/CV, or AFPEO/SP approval; and
(4) Documents, formal coordination packages, or briefings pertaining to pricing or incentive matters submitted for coordination or approval to the SMC Competition and Commercial Advocate, SMC/PK (or SCO), SMC/CA, SMC/CV, SMC/CC (or AFPEO/SP), or higher-level AF, DoD, or other outside authority or entity, regardless of dollar value. See SMC/PK Staff Package Expectations for an explanation of the staff package process; and
(5) Evaluation notices pertaining to pricing or incentive matters for non-operational source selections > $100M and operational source selections >$10M; and
(6) Other actions as directed by the COCO, SMC/PKF Chief, or SMC/PK.
(iii) Legal, Committee, and Pricing Review Process. Contracting officers—
(A) Submit all requests for legal, committee, or pricing review using the Review Request available on the Buyer and PCO Library. Legal, committee, and pricing reviews may be done in parallel.
(1) Contracting officers may provide a link to the Livelink or SharePoint file in the “Program Description” field of the review request form. Contracting officers are responsible for ensuring that the electronic files are named and organized in such a fashion that can easily be understood and accessed by the reviewer. Files that are not clearly named or well-organized may be returned without review.
(2) If documents are sensitive (e.g., source selection information) and the contracting officer does not want to upload them to Livelink or SharePoint, the contracting officer provides alternate instructions for access to the documentation in the “Program Description” field of the review request form. Note: The Buyer and PCO Library site is maintained by the SMC/PK Advisory and Assistance Services contractor.
(B) Committee (SMC/PKC) Review. Committee review comments are categorized as Critical, Substantive, or Administrative. The following definitions apply:
(1) Critical means an issue that causes non-concurrence such as a violation of law, regulation, policy, or higher-level direction.
(2) Substantive means factually incorrect material or a course of action that may significantly increase risk or timeline.
(3) Administrative means relating to grammar, punctuation, style, format, etc. or is provided to improve the quality or clarity of the file.
(C) Adjudicate review comments using the Review Request form.
(1) The contracting officer’s response to review comments should clearly indicate if the comment was accepted, partially accepted, or rejected. The response should explain what actions were taken in response to the comment and the rationale for partial acceptance or rejection.
(2) The contracting officer is highly encouraged to discuss critical and substantive comments that are partially accepted or rejected by the reviewer prior to submitting the final responses in the Review Request form. These comments should also be discussed during the clearance review, if applicable.
(iv) Review Process. The following tips should help SMC contracting professionals ensure efficient and effective reviews.
(A) In determining what constitutes a complete file for review, contracting professionals should:
(1) Review the Contract File Content Index. Determine what documentation can be completed at this time. If there is enough information to generate the documentation at this point in the process, the documentation should be in the file.
(2) Consider adding a note to the review request form or in the contract file explaining any missing documentation. While it is the expectation that files submitted for review be complete (based on what is appropriate for the current milestone), there are times when it may be necessary or in the best interest of the acquisition to proceed with a less than complete file. If the reviewer knows that you made a conscious decision to proceed without a complete file, this note gives them the opportunity to consider your rationale and make a more informed recommendation to you and the CAA. It may avoid the impression that you have been sloppy in your work. And, it may reduce the amount of comments that need to be written and adjudicated.
(B) Build the acquisition schedule with sufficient time for review. SMC/PK and SMC/JAQ have each established an internal review goal of 3 business days for most reviews. However, large files (e.g., draft RFPs) or matters requiring substantial research and analysis may take longer, so plan accordingly. You can expedite the review process by:
(1) Providing a complete, well-researched, well-documented, and well-organized file. Files that are incomplete, poorly researched or poorly documented, or unorganized may delay the review and result in additional or duplicative work on the part of the contracting officer. The review window does not start until the file is complete so it is imperative to deliver a complete file up-front.
(2) Involving your reviewers throughout the planning and execution of the action. When reviewers are familiar with the action, it is easier for them to review the file and they can often complete their reviews faster.
(3) Looking at your file through the eyes of the reviewer who has not been as intimately involved in the action as you. Are there areas that might require a little more explanation?
(4) Engaging reviewers early where there is an issue of doubt or controversy. Offer to walk the reviewer through the file briefly so that you can explain any areas that might be unusual, confusing, or controversial.
(5) Using a parallel or “shotgun” review or coordination process with legal, committee, and pricing reviewers is authorized in the PGI and may save time in your schedule. However, contracting officers should carefully consider the appropriateness of parallel review for certain actions. There may be cases where it would be more beneficial to use a serial review approach to minimize the total number of comments to adjudicate or avoid other unnecessary confusion or rework.
(6) Requesting that your reviewers, including legal, get together to deconflict their comments before providing them to the contracting officer or buyer. In a parallel review process, it is highly likely that you may receive conflicting advice from your reviewers. It may be beneficial to have the reviewers go over their comments together with the intent of trying to resolve disagreements before you go through each set of comments individually.
(7) Providing timely and complete adjudications of review comments. In most cases, your reviewer is performing a review not only to provide you advice and guidance but also to provide recommendations to leadership such as SMC/PK, DAS(C), or ADAS(C). In order to provide those recommendations and to avoid prolonging coordination or approval timelines, the reviewer needs to clearly understand how you adjudicated their comments. Do not simply respond “Noted”. Label your responses as accept, partially accept, or reject. Provide revised documents when appropriate to illustrate how you adjudicated comments. For partially accepted or rejected comments, explain what actions you took and provide your rationale. When partially accepting or rejecting a comment, discuss your adjudications with your COCO and reviewer before you finalize your response. It is perfectly okay to disagree with your reviewer. However, both you and the reviewer should be prepared to represent your points of view before leadership so they can make decisions regarding coordination or approval.
(C) For hard copies, fasten each official document into the contract file as soon as it is received to prevent misplacement or loss of documentation. For soft copies, upload documents immediately. Use file structures and names that facilitate a quick review by someone unfamiliar with your file and move draft or old versions of documents to an archive file or simply delete them.
(D) Arrange file contents chronologically by date under each tab, with the most recent piece of data on top or at the beginning of an electronic list.
(E) The contracting officer conducts a preliminary review of the file before submitting it for review. Most elementary mistakes can be filtered out by a thorough management review. Such reviews decrease the staff review timeline and result in fewer substantive comments. Great care and deliberation should be exercised in documenting the file, preparing the contractual document, and reviewing the adequacy and quality of both.
(F) See PKC POC Finder and PKF POC Finder for current listing of SMC/PKC and SMC/PKF reviewer assignments. Consult your COCO or the current SMC/JAQ Chief for the list of program attorney assignments.
SMC PGI 5301.603 Selection, Appointment, and Termination of Appointment for Contracting Officers
(a)(i) Air Force Contracting Officer Test (COT).
(A) Scheduling. Candidates may request to schedule the COT by sending an email to the SMC COT focal point (FP) listed on the Warrant Process page of the Buyer and PCO Library regardless of testing location..
(B) Feedback. Upon request, the FP that administered the COT provides feedback on COT performance. Feedback should be limited to which FAR Parts may require further study based on test results and any general types of errors made in taking the test. The FP does not review the actual questions and answers on the test.
(C) Presentation of COT Certificate. The SMC COT FP coordinates the presentation of the COT certificate.
(ii) Mock Contracting Officer Review Board (CORB). SMC/PKC facilitates quarterly Mock CORBs. Mock CORBs are a training tool for potential CORB candidates that meet the qualifications for an unlimited warrant and believe they are nearly ready to meet an unlimited warrant board. Additional information about the Mock CORB process and registration information is available on the Warrant Process page of the Buyer and PCO Library.
(iii) Warrant Boards.
(A) Warrants > $5M
(1) Nominations. Qualified candidates may submit the Contracting Officer Appointment/Warrant Eligibility Transfer/Termination Request to the Warrant FP identified on the Warrant Process page of the Buyer and PCO Library. See the Warrant Process page for tips on preparing for the CORB.
(2) Scheduling a CORB. SMC/PKC typically conducts a CORB within two to four weeks after each quarterly Mock CORB. SMC/PKC conducts ad hoc CORBs to support civilian hiring panels or if urgent mission needs require an out-of-cycle CORB.
(3) Panel Membership. The CORB panel typically consists of 5 members. The SMC/PKC Chief chairs the CORB and work with the SCO to identify the other panel members. Other members typically include the SMC/PK Deputy Director, the SMC/PKF Chief or Deputy, Committee Reviewers, and COCOs or Deputy COCOs. The sponsor COCO may observe the formal CORB but does not participate in questioning, panel discussions, or deliberations.
(4) CORB Questions. SMC/PKC maintains a bank of CORB questions. A minimum of 5 scenario-based questions are selected for each CORB. The CORB Chair selects the questions to be asked during the CORB. These questions include the topics required by regulation and other topics randomly selected from a list of FAR Parts.
(5) Non-Disclosure. To maintain the integrity of the process, do not disclose questions asked during the CORB outside of the CORB process.
(6) Evaluation and Feedback. Panel members use a scoring sheet for each candidate to evaluate CORB performance. The SMC/PKC Chief consolidates the evaluations and present a recommendation to the SCO for final decision. Candidates assessed as not ready for a warrant meet the CORB again before a warrant over $5M is issued. Upon request, the warrant board chairperson provides feedback to the candidate.
(B) Tips for preparing for the CORB are in the Buyer/PCO Library - Warrant Process.
(C) Presentation of the Warrant. The Warrant FP coordinates the presentation of the warrant.
SMC PGI 5301.9000 Scope and Definitions
(f) When the CAA is at the SCO or DAS(C)/ADAS(C) level, the clearance review is conducted by the Committee Reviewer, the Pricing Reviewer, and the Program Attorney. When the CAA is at the COCO level or below, the COCO assigns the Clearance Reviewer(s) as needed.
SMC PGI 5301.9001 Policy, Thresholds, and Approvals
(b) Clearance process.
(1) Clearance approval authority (CAA) is at the SCO or DAS(C)/ADAS(C) level. The clearance review is conducted by the assigned committee reviewer, pricing reviewer, and program attorney using the procedures in SMC PGI 5301.602-2.
(2) CAA is the COCO or below. COCOs establish procedures for conducting clearance reviews.
(3) Scheduling the Clearance Briefing with SCO, DAS(C) or ADAS(C).
(i) CAA is the SCO. The committee reviewer schedules the date and time of the clearance briefing after the legal, committee, and pricing reviewers (and the MIRT, if applicable) have submitted their comments to the contracting officer. The committee reviewer notifies the contracting officer as soon as the clearance review is scheduled and the contracting officer invites other attendees (e.g., legal reviewer, pricing reviewer, program office). All review comments should be adjudicated and responses returned to the reviewers 24 hours before the briefing.
(ii) CAA is the DAS(C) or ADAS(C). The contracting officer is responsible for submitting the notification of anticipated Business Clearance Session in accordance with AF PGI 5301.9001(f), paragraph 1.a or 2.b. For situational awareness, the contracting officer should copy the pricing reviewer, the committee reviewer and the COCO on the notification. Prior to submitting the Business Clearance documentation to SAF/AQC, the documentation should be reviewed in accordance with the clearance review procedures described in SMC PGI 5301.9001(b)(1). All review comments should be adjudicated and responses returned to the reviewers prior to requesting reviewer and SCO coordination on the Request for Business Clearance form (see MP 5301.9001(f), paragraphs 1.a.(1) or 2.b.(1)).
(4) Clearance Briefings. For clearances to the SCO, DAS(C) or ADAS(C), contracting officers are highly encouraged to use the templates identified below. SAF/AQC updates its clearance templates periodically. When DAS(C) or ADAS(C) is the CAA, t follow MP5301.9001(f) to ensure that the applicable SMC template below captures all necessary content for the specific action. Consult the assigned committee (competitive clearances) or pricing (non-competitive clearances) reviewer for the latest guidance on developing clearance briefings. For clearances at or below the COCO, the CAA determines whether or not a briefing is required. If the CAA does not require a briefing, the contract file should document the clearance approval and identify the information relied upon in making the clearance decision.
(i) Competitive Clearances
(A) Approval to Issue the Solicitation: Business Clearance Template
(B) Approval to Request Final Proposal Revisions: Use the SSA briefing and supplement with the charts in the Pre-FPR Clearance Template
(C) Approval to Make a Source Selection Decision: Use the SSA briefing and supplement with the charts in the Award Decision Clearance Template.
(ii) Noncompetitive Clearances
(A) Approval to Begin Negotiations: Noncompetitive Clearance Template
(B) Approval to Award (unless not required in accordance with AFFARS 5301.9001(e)): Noncompetitive Clearance Template
(5) Attendance at Clearance Briefings. The committee, pricing, and legal reviewers and other MIRT members (if applicable) should participate in all clearance briefings for which they acted as clearance reviewer.
(i) Clearance Approval Authority. See tables below for SMC clearance delegations. For tracking purposes, contracting officers should notify the SMC/PKC committee reviewer when DAS(C), ADAS(C), or SCO clearance is delegated and state whether clearance reviews were waived as part of the delegation.
|
Systems / Sustainment / Enterprise Contracting - Non-Operational | |
|
Contract Value |
SMC Clearance Approval Authority |
|
≥ $1B |
DAS(C)/ADAS(C) |
|
>$100M to <$1B |
SCO |
|
≥$25M to ≤$100M |
COCO |
|
≥$5M to <$25M |
Deputy COCO |
|
>$5M |
Contracting Officer |
|
Operational Contracting | |
|
Contract Value |
SMC Clearance Approval Authority |
|
≥$1B |
DAS(C)/ADAS(C) |
|
>$10M to <$1B |
SCO |
|
≥$1M - ≤$10M |
COCO |
|
≥$500k - <$1M |
Deputy COCO |
|
>$500K |
Contracting Officer |
SMC PGI 5301.91 Ombudsman Program
5301.9103 Solicitation Provision and Contract Clauses
In compliance with AFFARS 5352.201-9101, Ombudsman and SMC/CC Appointment Letter, the SMC Ombudsman for unclassified programs is:
Name: Colonel Trent Tuthill
Phone: (310) 653-1786
Email: trent.tuthill@us.af.mil
Address: SMC/PK
Attn: Col Trent Tuthill
483 N. Aviation Blvd
Los Angeles AFB, CA 90245-2808
The SMC Alternate Ombudsman for unclassified programs is:
Name: Ms. Melissa Duong
Phone: (310) 653-1792
Email: melissa.duong@us.af.mil
Address: SMC/PKF
Attn: Ms. Melissa Duong
483 N. Aviation Blvd
Los Angeles AFB, CA 90245-2808
For classified programs, the SMC Ombudsman is:
Name: Ms. Melissa Duong
Phone: (310) 653-1792
Email: melissa.duong@us.af.mil
Address: SMC/PKF
Attn: Ms. Melissa Duong
483 N. Aviation Blvd
Los Angeles AFB, CA 90245-2808
USAFA PGI 5301
Federal Acquisition Regulations System
USAFA PGI 5301.601(a)(i)(A) HCA Responsibilities
HCA Matrix Table 2:
The USAFA SCO delegates the authority to enter into, approve, or terminate Grants and Cooperative Agreements to the COCO. Contracting Officers should refer to the USAFA/PK authorities and delegations site concerning specific COCO designations, delegations and authorities at https://cs2.eis.af.mil/sites/13093/PP/USAFA_PK/_layouts/15/start.aspx#/SitePages/Home.aspx.
The USAFA SCO delegates the authority to issue and terminate limited contracting officer and grants officer warrants of less than $5M to the COCO.
The USAFA SCO delegates clearance authority to the COCO for actions valued at less than $10M. Contracting Officers should refer to the USAFA/PK authorities and delegations site concerning specific COCO designations, delegations and authorities at https://cs2.eis.af.mil/sites/13093/PP/USAFA_PK/_layouts/15/start.aspx#/SitePages/Home.aspx.
USAFA PGI 5301.9102(a) Ombudsman Program
The primary USAFA Ombudsman is Mr. James Anderson.