Just as with my Quick Hitter series on the FAR, my Quick Hitter series on the GSAR is meant to simplify contracting business with the government. This time with GSA.
GSAR 537.504 Contracting Official’s Responsibilities
This GSAR subpart gives directions on how to manage building services (O&M) contracts without the appearance of contractors blending into the federal workforce and being confused as federal employees. CO oversight is essential.
Identificationn
Have contractor staff differentiate themselves as contractors in email signatures and PIV badges whether those badges are temporary or long-term. This is usually done through the job title (e.g. Janitorial Staff-Contractor or Contracted Landscaping Crew Member). Such contracted labor can also identify themselves through work attire. For example, when I worked at the VA’s FSS program in Hines, Illinois the O&M staff wore different colored T-shirts. The janitorial staff wore light gray T-shirts and the maintenance staff wore standard blue T-shirts.
Communication Of Roles & Responsibilities
During the kick-off meeting, share the method of communication (usually email or text message) and the chain of communication (who’s included) when information is dispersed regarding assignments and progress.
Terms & Conditions
Notify contracted staff regarding their specific roles and responsibilities pertaining to the scope of the contract as well as any required deliverables. Ensure the contractors understand that the CO is not a personnel supervisor and that the awardee should have their own on staff.
Contract Type
GSA recommends a FFP contract as they are less likely to give a false impression of government oversight although every federal contract type can lend itself to the impression of government oversight. This is the government‘s way of ridding themselves of a potential lawsuit in terms of accepting any responsibility for mishaps orchestrated through the actions of contracted staff as I am sure contractors attempt to utilize the legal system to get rich off the government via legal action and I’m sure they have paid gratuities in the past.
Limit Who Can Assign Work
Only the government can assign work through the CO or designated COR to a designated PM or Team Lead specified by the contractor.
Avoid Ad Hoc Assignments
There are no “other duties as assigned” as is customary in the commercial corporate workforce. This is called “scope creeping” inside the federal contracting arena.
Do Not Provide Managerial Or Support Services To Contractors
Such lends the impression of a personnel services contract. Examples include contractor employee appraisals or approval of leave.
Computer System Access
Limit access and role of functionality pertaining to federal IT systems. For example, contracted O&M labor should never have access to an agency’s contract writing system or have authority to obligate money in IFCAP.
All of this may seem simple if you are somewhat cynical like I am. However, the government learns and learns quickly regarding its own personnel and the personnel they hire to do their projects. Yes, i’m sure they have been slapped with a lawsuit before by a contractor, but I’m also sure they know that their own personnel may desire to cut corners due to laziness or heavy workload.
Services contracting is fun. I contracted services within the VA’s FSS program for about seven years. I know what your CO will look for in a proposal.
If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation. 
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