OMB Mandated Business Cases
Purpose: To remind the VA Acquisition Workforce of the Office of Federal Procurement Policy (OFPP) requirement to develop and post business cases for the following types of acquisitions vehicles: All Government-Wide Acquisition Contracts (GWACs), Multiple-Agency Contracts, and Agency-Specific Contracts or Agency-Specific Blanket Purchasing Agreements (BPAs).
Effective Date: Immediately
Expiration Date: NA
Background: On September 29, 2011, OMB released a memorandum to the Chief Acquisition Officers (CAOs) entitled, “Development, Review, and Approval of Business Cases for Certain Interagency and Agency-Specific Acquisitions.” This memorandum outlined required elements of business case analysis as well as a process for developing, reviewing, and approving business cases to support the establishment and renewal of GWACs, multi-agency contracts, BPAs, and agency-specific contracts. The requirements outlined in this memorandum address section 865(b)(2) of the National Defense Authorization Act for FY 2009 (P.L. 110-417), which requires multi-agency contracts to be supported by a business case analysis detailing the administration of the contract, including an analysis of all direct and indirect costs to the government of awarding and administering the contract and the impact that the contract will have on leveraging purchasing power.
Action Required: Heads of Contracting Activities (HCAs) shall ensure their respective Contracting Officers comply with the OFPP requirements outlined in the aforementioned OMB Memorandum. Other than draft solicitations, agencies shall not issue solicitations for proposed BPAs, multi-agency contracts, and agency-specific contracts until the business case has been finalized and approved by the appropriate agency official(s). In addition, in the case of those approved business cases for establishing or renewing a GWAC, the agency shall formally submit the approved business case to OMB, as part of the request by the agency head (or deputy) to the OMB Director requesting that the Director grant the agency an executive-agent designation to award and manage the proposed GWAC. While an agency may release a draft solicitation for a proposed GWAC, the agency may not release a final solicitation for a proposed GWAC unless and until the OMB Director has granted the agency’s request for an executive-agent designation.
Agencies are required to post on MAX links to web pages containing information about the BPAs and contracts that are covered by the September 29, 2011 memorandum. Web pages should include the names of vendors, contract terms and conditions, information about pricing, and provide a point of contact for further information. Instructions for posting award information are provided on MAX at: https://max.omb.gov/community/x/b5G8IQ.
Additional Information: Questions or concerns should be addressed to the Office of Acquisition and Logistics (003A), Procurement Policy and Warrant Management Service (003A2A) at firstname.lastname@example.org.