The Professional Services Council, through the Council of Defense and Space Industry Associations (CODSIA), made recommendations to the Office of Federal Procurement Policy on how it can improve its proposed policy letter “Work Reserved for Performance by Federal Employees” to avoid creating an environment that would promote arbitrary insourcing at federal agencies.
The proposed policy letter sought to clarify the definition of what constitutes “inherently governmental” work that must be performed by federal government employees and to provide guidance to agencies to help them identify functions “closely associated with inherently governmental” and “critical” functions that should also be reserved for federal employee performance.
But we felt that agencies could misinterpret the proposal as a mandate to insource work that is neither inherently governmental nor critical to government’s mission performance, such as base maintenance, information technology support or other tasks found in the yellow pages.
To avoid a final policy that results in wide-scale, non-strategic, quota-driven insourcing, we recommended OFPP:
- Provide a clear definition and examples of what constitutes inherently governmental work;
- Combine the categories of “closely associated with inherently governmental functions” and “critical functions” into one narrowly defined category to eliminate duplication and confusion;
- Require that agencies to submit and publicize a list of their inherently governmental and critical functions and define which critical functions must be reserved for performance by federal employees;
- Require agencies establish a comprehensive human capital plan and conduct in-depth cost comparisons before making insourcing determinations for work that could be performed by either the public or private sectors.
