Overview
Subpart 7.1 prescribes the policies and procedures for developing acquisition plans and conducting market research for all federal acquisitions. Its primary purpose is to ensure that the Government meets its needs in the most effective, economical, and timely manner while maximizing competition and the use of commercial products.
Key Rules
- Mandatory Planning: Agencies must perform acquisition planning and market research for all acquisitions to promote the use of commercial products/services and ensure full and open competition.
- Written Plan Requirements: While planning is required for all acquisitions, formal written plans are mandatory for cost-reimbursement contracts and other "high-risk" (non-firm-fixed-price) acquisitions, as well as those exceeding agency-defined dollar thresholds.
- Preference for Commerciality: Planners must prioritize the acquisition of commercial products or nondevelopmental items to the maximum extent practicable.
- Small Business Focus: Planning must be structured to facilitate competition among small businesses and avoid "unjustified bundling" that might preclude their participation.
- Life-Cycle Costing: For major systems and high-value acquisitions, planners must consider the total cost of ownership, including acquisition, operation, support, and disposal.
- Sustainability and Accessibility: Plans must incorporate sustainable procurement requirements (environmental/energy efficiency) and Information and Communication Technology (ICT) accessibility standards (Section 508).
- Firm-Fixed-Price Transition: For multi-year or follow-on efforts, planners must develop a strategy to transition toward firm-fixed-price contracts as requirements become more stable and cost history is established.
Responsibilities
- Agency Head (or Designee): Responsible for establishing the criteria and thresholds for formal planning, prescribing procedures for competition, and reviewing/approving plans (approval must be at least one level above the Contracting Officer for non-FFP contracts).
- Acquisition Planner: The designated individual (often a Program Manager or Lead) responsible for forming the acquisition team, drafting the written plan, and reviewing/revising it at least annually.
- Contracting Officer (CO): Must review the acquisition history, concur with the acquisition plan, and designate/authorize a Contracting Officer’s Representative (COR) as early as practicable.
- Acquisition Team: A multi-disciplinary group including contracting, small business, fiscal, legal, and technical personnel who provide input to ensure all significant aspects of the acquisition are covered.
- Small Business Specialist: Reviews acquisition strategies to identify and notify leadership of potential bundling or consolidation that could impact small business opportunities.
Practical Implications
In real-world federal contracting, Subpart 7.1 transforms procurement from a clerical task into a strategic, "team sport" activity.
- Early Engagement: Contractors should realize that by the time a solicitation is released, the "Acquisition Plan" has already defined the "rules of engagement," including contract type, small business set-asides, and evaluation factors.
- Risk Mitigation: The heavy emphasis on documenting the rationale for cost-reimbursement contracts means agencies are under pressure to justify why they cannot use Firm-Fixed-Price, often leading to more rigorous data requirements for bidders to prove their accounting systems can handle high-risk contract types.
- Bundling Hurdles: Large-scale "consolidated" requirements face significant internal hurdles; if an agency merges several smaller contracts into one large one (bundling), they must provide substantial evidence that the move provides measurably higher benefits than the loss of small business participation.