Jump to content
The Wifcon Forums and Blogs
stephgoe

Contracts vs SF182

Recommended Posts

Hoping to get Vern's two cents here:

I am in a regional procurement office. My training officer is trying to avoid processing approx 480 SF-182s. He is requesting an IDIQ contract so that each of our field offices can write Task Orders against it instead. The requested training is a series of eight classes at a non-governmental college to tranfer 1105s to 1102. According to OPM a SF182 can be used if each course is under the SAT (among other rules). The training officer feels that this rule of non-competition (his interpretation, not mine) should transfer over to the contracting world. I believe that this should be competed!

What do you think??

Share this post


Link to post
Share on other sites
Guest Vern Edwards

The following is from the OPM Handbook, available at http://www.opm.gov/hrd/lead/pubs/handbook/lrbsa12.asp#Form:

USES OF THE TRAINING AUTHORIZATION FORM

Agencies may use an authorized training form to procure and certify payment of training expenses through Government or non-Government facilities. The form is certified by training officials and supervisors instead of the contracting officer under a procedure negotiated by the two offices and addressed in the agency's administrative directives. Comp. Gen. B-210334 (July 14, 1983).

Under typical negotiated procedures, the Training Authorization Form (SF-182) or equivalent is authorized for use to obligate funds, contract for training, and certify payment of approved training expenses under the following conditions:

  • the training cost of a single training event, program, or instructional service does not exceed the simplified acquisition process dollar limit established by U.S. General Services Administration;
  • the cost is of a fixed nature, i.e., price per student or price per course, program, or service; and
  • the program, course, or instructional service is off-the-shelf and no modification or development resulting in increased cost to the Government is needed to meet the organization's needs.

The Training Authorization Form is also used for requesting, approving, and certifying payment for attendance at meetings, conferences, seminars, and symposia where the primary purpose is to train an employee to meet a performance improvement related need. The form is not used to purchase general supplies, training equipment, or non-training services.

When an agency training course or program requires new design and development, the authorized contracting officer contracts for the service on behalf of and as requested by the responsible training or management official.

Note that the SF 182 may be used only with the contracting office's agreement.

If you are going to award an IDIQ contract instead of using the SF 182, then you need to comply with FAR just as you would for any other procurement. Training is not exempt

Share this post


Link to post
Share on other sites

Couldn't you compete the ID/IQ and within the ID/IQ specify that the SF-182 would be an acceptable ordering means for orders under a certain amount (could be designated as SAT or figure less than the SAT)? If it's a single award ID/IQ and there's no competition at the order level, you can pretty much establish any ordering process you want, right? Granted, you would need some process by which the CO gets all the SF-182s so you can track ceiling issues. Could be CO must sign them or simply that CO is provided a copy. Trick seems to be developing the ordering process and documenting it well enough in the ID/IQ so the vendor knows when an order is valid.

Organization I'm on detail to is looking at putting one or more training ID/IQs is place this year as well s we've been having similar discussions

Share this post


Link to post
Share on other sites

Without looking into the matter in detail I guess an "order" under an IDIQ could be in any form and/or on any form the contract stipulates but consider....

Automated procurement systems - I suspect such systems do not have a SF-182 in it.

Track of SF-182 versus a usual SF or optional form used as a IDIQ order - In many agencies the SF-182 tracks through the financial management system completely different than a form used to complete a FAR procurement.

All told I believe you are at great risk in confusing apple and orange processes if you attempt to use a SF-182 as the order form for an IDIQ.

Share this post


Link to post
Share on other sites

C Culham - Thanks. Not being familiar with this agency's financial systems, I hadn't thought of that aspect. Although one would hope they talk to each other, that is something we'd have to look into to be sure

Share this post


Link to post
Share on other sites

There was a WIFCON thread a few years ago about this topic: http://www.wifcon.com/discussion/index.php?/topic/1584-basic-ordering-agreement-and-training/

The question that remained unanswered in that thread is whether outside training requirements through the SF182 process are exempt from the FAR. I have run into this issue and for training requests over the MPT, I have asked my HR office to have these requests completed through the normal contracting process. Generally, this has been a good thing because we have received significant discounts from the GSA schedule price through competition; we have been able to target small businesses; and all our training requirements are FFP so we can keep our high-risk contracting percentage down.

My fear with the SF182 is that an HR person untrained in contracting would select the first contractor he or she found on their web search and pay the single student price advertised for all 30 students.

Share this post


Link to post
Share on other sites

Kathleen above said,

I think that your training officer needs to stick to training and leave the contracting to the trained contract specialist.

I agree. I also agree that contracting officers should leave training specialist alone and let them do their SF-182s. Depending on agency regulations and practices, training officers may approve SF-182s with or without competition and at whatever prices they find as they see fit as part of their responsibility to manage training dollars and outcomes, and those SF-182s can also serve as payment forms. Contracting ofifcers should leave the training officers alone and let them do their thing. Don't we already have enough work that is properly ours that we don't need to intrude on the SF-182 process?

Share this post


Link to post
Share on other sites

apsofacto - I've seen this done at a couple of agencies now. The general thought is that they can make an 1102 to do 1105 work but they can make an 1105 do 1102 work. The management's reasoning is that by making them all 1102s they can have greater flexibility to get the work accomplished. Not saying I agree with that theory, but that is the theory that both of these agencies have cited.

Share this post


Link to post
Share on other sites
Guest
This topic is now closed to further replies.

×
×
  • Create New...