Contingency Contracting Corps
The Contingency Contracting Corps is a government-wide group of volunteer, trained contract specialists who provide on-call support to lead agencies in emergency response and recovery missions.
In the aftermath of Hurricane Katrina, the U.S. mobilized resources as part of a nation response to provide and deliver goods and deliver goods and services in support of response and recovery efforts. Emergency acquisitions played an integral role in this and many other disasters. Emergency acquisitions, which includes contingency contracting, allows for greater flexibilities in contracting to assist in the procurement of basic or complex commodities and services, to include the construction of temporary or permanent structures.
To ensure that qualified and interested members of the acquisition workforce serve as ready-reserve cadre, prepared to assist in emergency acquisitions and acts in the recovery and restoration of affected areas. The General Services Administration (GSA) Contracting professionals may be required to volunteer to help manage the Contingency Contracting Corps (CCC). The Corps is a voluntary membership, in which participants from across the entire acquisition workforce may serve and support federal agencies in response to disaster and recovery efforts domestically and internationally.
Section 870 of S. 3001, of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 amended The Office of Federal Procurement Policy Act (41 U.S.C. 403 et seq. and created the Contingency Contracting Corps, designating GSA as the lead agency. While GSA manages the Corps, the Director of the Office of Management and Budget (OMB) activates the Corps upon request by an executive agency.
No funding exists to manage the Corps. The salary and other operational costs, associated with activating the Corps, is the sole responsibility of the executive agency requesting emergency, major disaster, or contingency operations support.
Once activated, the Corps shall be used with respect to any procurement of property or services for the support of (1) contingency operations as defined in Section 101(a)(13) of Title 10, U.S.C.; or (2) emergencies or major disaster, as defined in Section 102 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5122).
The Corps provides acquisition support, expertise and supplements in support of responses to national emergencies, major disasters or contingency operations. This support includes pre-award, award, and post award activities consistent with applicable Federal statutes and regulations.
Membership and participation in the contingency corps is voluntary and open to all Federal employees and members of the Armed Forces who are members of the acquisition workforce. The Corps encourages participation from Contracting Officer Representatives and Program/Project managers.
All volunteers will be required to complete, with supervisor approval, a “Contingency Contracting Corps Personal Data Form.” GSA will review membership and maintain an active list of participants, which includes validating membership information biannually. Federal employees interested in becoming members or who need to update their membership information should submit their inquiries to GSA. Once interested acquisition professionals have contacted GSA, GSA will review eligibility requirements and send a “Welcome to the Corps” email with additional informational resources.
The Federal Acquisition Workforce is also able to volunteer to become a Corps member via the Federal Acquisition Institute Training Application System (FAITAS).
Contingency Contracting Corps Benefits
|Agency Benefits||Employee Benefits|
|Public exposure (Positive advertisement for agency and acquisition profession)||Public recognition (Recognized by agency as being an Emergency Responder)|
|Interagency collaborations/partnerships||Networking opportunities (Visibility with Senior Government Officials)|
|Acquisition Working Group/Agency Liaison||Acquisition Working Group Member/Agency Liaison|
|Retention of employees; low attrition rates/turnovers||Professional development/leadership opportunities|
|Ability to attract high performing Contracting Officers (Top talent)||Job rotation (Interagency Detail Agreement)|
|Offer Continuous Learning Points (CLPs) for training as an Emergency Responder||Achieve Continuous Learning Points (CLPs)|
Emergency Acquisition Resources for Corps
The following resources are provided for executive agencies requesting disaster and recovery support from the Corps.
- OFPP’s “Emergency Acquisitions Guide”
- Department of Homeland Security’s Disaster Contracting Desk Guide
- Federal Acquisition Regulations (FAR) Part 18 on emergency acquisitions
- The National Response Framework’s guidance for domestic incident response
- Memoranda of Understanding (MOUs) for emergency contracting support
Logistics and Deployment Readiness
Members of the Contingency Corps may be required to perform work in various locations, either domestically or internationally, in support of preparations for, or response to, potential or actual emergencies. Such work may be performed in various locations in support of incident response including, but not limited to, a member’s regular office, a member’s home, an agency’s Operations Center, or an alternate teleworking site.
In some instances, Corps members may be required to deploy to the field in preparation for, during, or immediately following an incident. Such field deployments would be typically made at the request of an agency leading a response to a particular emergency. The requesting agency is responsible for the logistical requirements associated with a deployment including but not limited to work stations, electronic communications equipment, food, shelter, and transportation.
Requesting agencies are required to assemble and furnish deployment kits for designated Corps members. Deployment kit may include but are not limited to the following:
- copies of Federal Acquisition Regulations (FAR), Department of Homeland Security’s Emergency Contracting Desk Guide, and OMB’s Emergency Contracting Guide
- laptop (with wireless capability and solar chargers)
- cell phone with charger
- satellite phone
- a wireless email device
web access or stand-alone capability (CD backups) to:
- the agency’s contract writing system, if applicable
- current sites needed for sourcing, data collection, guidance & references to agency unique requirements, and points of contact
Additionally, activated Corps members shall bring their government identification, warrant, travel, and purchase card, if applicable.
Once activated, assignments may entail working extended hours, evenings and weekends. While activated, corps members will be under the operational control of the employing agency. The employing agency, not the requesting agency, is responsible for paying salaries for responding Corps members.
Training and Certification
No funding is provided for the Corps. Therefore, any training expenses associated with participation in this program will be sponsored by the employer of the Corps members. The Federal Acquisition Institute (FAI) will offer Corps related training, free of charge, as needed.
Members of the Contingency Contracting Corps are required to meet the mandatory OFPP Federal Acquisition Certification training requirements supplemented with emergency acquisition training. These include:
- Federal Acquisition Certification in Contracting, Contracting Officers’ Representatives (COR), or Program and Project Management (PPM) associated with the Defense Acquisition Workforce Improvement Act requirements.
- Completion of 12 hours of online coursework developed by the Federal Emergency Management Agency: IS-100, IS-200, IS-700, IS-800.
- Acquisition emergency management training from other federal or private learning institutions.
Emergency-specific training. FEMA’s Emergency Management Institute (EMI) offers online courses on the National Incident Management System (NIMS) and the Incident Command System (ICS) for all who may deploy during an emergency. FEMA also offers emergency-specific acquisition courses, which may be of particular value to contracting officers (COs). Some courses are classroom based; others are available as independent study. The following may be of particular interest for COs and other personnel involved in the acquisition process:
- Disaster Contracting
- Introduction to FEMA Office of Chief Counsel
- Introduction to the Defense Priorities and Allocations System (DPAS)
Additional information and sign-up procedures for these and other FEMA EMI courses are available on EMI's website.
Contingency contracting courses. The Defense Acquisition University (DAU) has worked with service representatives to standardize required contingency contracting courses to ensure well-trained, prepared contracting officers. The DoD contingency contracting training is at least 90 percent common material across all DoD services.
The minimum core training for federal agencies' Contingency Contracting Officers (CCOs) consists of the following courses:
|FAC-C Training Requirements|
10 Core Courses:
8 Core Courses:
Plus all required Level 1 training
2 Core Courses Plus 1 Elective:
Plus all required Level I and Level II training
* 32 Hours of Electives. The 32 hours of electives may be one course or a series of courses. Each course should be at least eight hours in length and can be classroom, online, or a combination of the two. Topics must be related to acquisition and may include general business courses such as statistics or budgeting. Topics of subject areas may also be in a technical area related to the individual’s specific work, such as IT. Agencies have the option of specifying the courses their workforce members must take to meet the 32 hours of electives.
In addition to the above, the newest contingency contracting course, CON 334, Advanced Joint Contingency Contracting, is now a core course for DoD civilian and military contingency leadership positions. CON 244, Construction Contracting, is optional but recommended for contingency contracting deployments.
Proposed Activation Process
This process flow is meant to be a representation of the likely steps involved with activating the Contingency Contracting Corps (CCC). It is not meant to show the entire activation and response process. Actual steps and communications may vary, depending on the size and nature of the emergency, disaster or declared contingency.
Step 1: Major disaster, emergency or contingency operation declared.
Step 2: FEMA activates its incident response coordination process.
Step 3: FEMA receives a mission assignment and assigns the appropriate resources. In this step, FEMA and other participating agencies may also determine if supplemental contracting representatives are necessary to complete the assignment.
Step 4: Executive agencies submit a request for the Corps to be activated to the Office of Management and Budget (OMB). The requesting agency specifies whether there is a need for contracting officers, contracting officer representatives and/or program/project managers.
Step 5: The Office of Management and Budget (OMB) activates the Corps, as appropriate.
Step 6: GSA’s OGP notifies Corps members’ agency of the activation of the volunteer Corps member.
Step 7: The requesting agency will provide GSA OGP with the duty or deployment instructions for the activated Corps members. GSA will furnish the activated Corps members with the deployment information.
Step 8: The Corps member(s) report(s) or deploy(s) to requesting agency locations, in accordance with the instructions.
Step 9: The contracting mission is executed.
Step 10. Follow up post contracting missions as necessary.
Acquisition support. Each agency with responsibilities for conducting emergency acquisitions should establish, in advance of actual emergencies, a cadre of contracting personnel to function as a rapid deployment force on short notice. Because funds are not usually available in advance of an emergency and requirements may vary considerably, agencies should consider establishing basic ordering agreements (BOAs) or blanket purchasing agreements (BPAs) for additional acquisition professional support from the private sector. BOAs and BPAs will facilitate access to additional support when needed. An agency may wish to use acquisition support personnel to help federal contracting professionals responsible for activities such as market research, contract documentation, and contract closeout. Agency officials would retain responsibility for all inherently governmental activities, including the award and modification of contracts. See FAR 7.503(c)(12). Where agencies have engage contractors in acquisition support roles, they must ensure they are providing appropriate oversight of activities closely associated with inherently governmental functions and have sufficient in-house capability to maintain control of their mission.
Agencies should also consider establishing service-for-fee agreements with the:
- Defense Contract Management Agency (DCMA) or the General Services Administration (GSA) Assisted Acquisition program to evaluate contractor capabilities and support contract administration, and
- Defense Contract Audit Agency (DCAA) to evaluate cost reasonableness and conduct contract audits.
To provide additional technical support at the point of operations, an agency may plan to allocate contracting personnel in the field with contracting officer’s representatives (CORs) who have received emergency contract surveillance training. DHS employed this practice to mitigate risk during Hurricane Katrina–related operations.
Deployment readiness. The CAOC recommends that contracting professionals have deployment/to-go kits available for use when deployed. To-go kits may vary depending on the disaster environment and expected resources available at the disaster site. Some agencies may have items pre-positioned, but the uncertainties of the emergency environment make it wise to be prepared. Deployment kits for contracting professionals should include the following:
- Laptop (with wireless capability and solar chargers)
- Cell or satellite phone with charger
- Government travel card
- Government purchase card and convenience checks
- Blank contract forms (SF 44, SF 30, SF 1442, and model contract files)
- Current FAR, including FAR 18 on emergency acquisitions and FAR 26.2 on disaster or emergency assistance activities
- Wireless email device
- Basic office supplies necessary for immediate use
- Badges or other government-issued identification
- List of important contact numbers
- Maps of the affected and adjacent areas
- Authorized USB flash or storage device
- Web access (or compact disk) to the agency’s contract writing system; current sites needed for sourcing, data collection, guidance and references to agency unique requirements, and points of contact.
Warranting and certification processes. Agencies should establish expedited processes for modifying or issuing new warrants, as needed, for personnel deployed to an emergency situation. The Federal Acquisition Certification in Contracting (FAC-C) program establishes core, common competencies for civilian agency contracting professionals and is recognized as the standard contracting credential by all civil agencies. Civilian employees who may be deployed should hold a FAC-C at the appropriate level to support the mission.
Generally Available Acquisition Flexibilities
The following authorities are generally available flexibilities that may be particularly beneficial to agencies in emergency situations. This is not an exhaustive list; see FAR 18.1 for additional flexibilities.
1. Simplified Procedures for Certain Commercial Items. Agencies are authorized to use simplified procedures for the acquisition of commercial items in amounts above the SAT. Contracting officers may use any simplified acquisition procedure provided in FAR 13, subject to specific dollar limitations applicable to the particular procedure selected. This means, among other things, that agencies are:
- Not required to establish a formal evaluation plan or competitive range, conduct discussions with vendors, or score quotations from offerors; and
- permitted to limit documentation required in justifying contract award decisions (See FAR 13.501 for special documentation requirements).
2. Interagency acquisitions. Interagency acquisitions offer important benefits, including efficient access to prequalified sources and the ability to leverage resources. Interagency contracts include the Federal Supply Schedules operated by GSA (see FAR 8.4), multiagency BPAs established under a Multiple Award Schedule (see FAR 8.405-3(a)(4)), government-wide acquisition contracts established under Section 5112(e) of the Clinger-Cohen Act, and multiagency contracts established pursuant to the Economy Act (see FAR 16.505(a)(7)). These contracts offer agencies access to a broad range of goods and services using streamlined procedures that permit rapid response.
Purchases on many interagency contracts, including the Federal Supply Schedules, may be made through “direct acquisition” where the requesting agency (the agency with the requirement) places an order directly against another agency’s contract. A number of agencies also offer acquisition assistance to place orders on another agency’s behalf. When conducting an assisted acquisition, agencies must take extra precautions to ensure a clear understanding of roles and responsibilities between the requesting agency and the servicing agency (the agency placing the order). Interagency acquisitions under the Economy Act must be supported by a determination and finding (see FAR 17.503).
Select the links below to access resources for the Contingency Contracting Corps.
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