B-199463 L/M, OCT 9, 1980
Highlights
EXECUTIVE OFFICE OF THE PRESIDENT: YOU HAVE REQUESTED OUR VIEWS ON A DRAFT SEGMENT OF THE FEDERAL ACQUISITION REGULATION (FAR) COVERING SUBPART 3.6 - CONTRACTING WITH GOVERNMENT EMPLOYEES OR ORGANIZATIONS OWNED OR CONTROLLED BY THEM. SUBPART 7.4 - COMPONENT BREAKOUT YOU PROPOSE THAT POLICIES AND PROCEDURES REGARDING COMPONENT BREAKOUT BE PRESCRIBED AT THE AGENCY LEVEL RATHER THAN BY THE FAR BECAUSE THE COMPONENT BREAKOUT POLICIES AND PRACTICES OF THE DEPARTMENT OF DEFENSE (DOD) DIFFER GREATLY FROM THOSE OF THE CIVILIAN AGENCIES AND THEREFORE A UNIFORM REGULATION IS NOT PRACTICABLE. DOD'S POLICY IS AIMED PRIMARILY AT FOLLOW -ON PROCUREMENTS WHILE CIVILIAN AGENCIES' POLICIES APPLY AT ALL STAGES.
B-199463 L/M, OCT 9, 1980
OFFICE OF GENERAL COUNSEL
WILLIAM J. MARAIST,
EXECUTIVE OFFICE OF THE PRESIDENT:
YOU HAVE REQUESTED OUR VIEWS ON A DRAFT SEGMENT OF THE FEDERAL ACQUISITION REGULATION (FAR) COVERING SUBPART 3.6 - CONTRACTING WITH GOVERNMENT EMPLOYEES OR ORGANIZATIONS OWNED OR CONTROLLED BY THEM, SUBPART 7.4 - COMPONENT BREAKOUT, AND PART 48 - VALUE ENGINEERING. OUR COMMENTS FOLLOW.
SUBPART 7.4 - COMPONENT BREAKOUT
YOU PROPOSE THAT POLICIES AND PROCEDURES REGARDING COMPONENT BREAKOUT BE PRESCRIBED AT THE AGENCY LEVEL RATHER THAN BY THE FAR BECAUSE THE COMPONENT BREAKOUT POLICIES AND PRACTICES OF THE DEPARTMENT OF DEFENSE (DOD) DIFFER GREATLY FROM THOSE OF THE CIVILIAN AGENCIES AND THEREFORE A UNIFORM REGULATION IS NOT PRACTICABLE.
WE BELIEVE THAT FAR SHOULD CONTAIN COVERAGE REGARDING COMPONENT BREAKOUT. ALTHOUGH THE COMPONENT BREAKOUT POLICIES OF DOD DIFFER FROM THOSE OF CIVILIAN AGENCIES, I.E. DOD'S POLICY IS AIMED PRIMARILY AT FOLLOW -ON PROCUREMENTS WHILE CIVILIAN AGENCIES' POLICIES APPLY AT ALL STAGES, WE DO NOT THINK THAT THE DIFFERENCES PRECLUDE UNIFORM POLICY AND PROCEDURES IN THIS AREA. IN OUR OPINION, SIGNIFICANT COST SAVINGS CAN BE REALIZED THROUGH COMPONENT BREAKOUT AT ALL STAGES OF THE ACQUISITION PROCESS, AND WE BELIEVE THAT YOUR OFFICE SHOULD PRESCRIBE UNIFORM POLICY TO BE FOLLOWED BY ALL PROCURING AGENCIES.
WE HAVE NO FURTHER COMMENTS.