R 031407Z MAY 24
MARADMIN 209/24
MSGID/GENADMIN/CMC WASHINGTON DC PR//
SUBJ/U.S. MARINE CORPS CONTRACT SERVICES GUIDANCE FOR FISCAL YEAR (FY) 2025//
REF/A/DOC/DOD/24JUN21//
REF/B/DOC/DON/08APR22//
REF/C/DOC/DON/27NOV23//
REF/D/DOC/DON/01JUL21//
REF/E/DOC/DOD/SEP 2008//
REF/F/DOC/DON/MAR 2024//
NARR/REF A IS DOD INSTRUCTION 5000.74. REF B IS SECNAVINST 5000.2G ENCLOSURE (8). REF C IS DASN (P) MEMO, ADDITIONAL DEPARTMENT OF THE NAVY IMPLEMENTATION GUIDANCE FOR DEFENSE ACQUISITION OF SERVICES. REF (D) IS MARINE CORPS BUSINESS COUNCIL CHARTER. REF (E) IS DOD FINANCIAL MANAGEMENT REGULATION VOLUME 2B, CHAPTER 19. REF (F) IS DON FY2025 BUDGET ESTIMATES, OMMC VOLUME II DATA BOOK//
POC/DENNIS MARTINO/CIV/HQMC R/LOC: WASHINGTON DC/TEL: 703-692-5506/EMAIL: [email protected]//
POC/ROBERT NAFTAL/CIV/HQMC L/LOC: WASHINGTON DC/TEL: 703-604-3269/EMAIL: [email protected]//
POC/CARLTON HENSLEY/CIV/UNIT: MCSC/LOC: QUANTICO VA/703-432-3899/EMAIL: [email protected]//
GENTEXT/REMARKS/1. Purpose. This MARADMIN updates the Service Requirements Review Board (SRRB) policy and provides SRRB guidance for FY25.
2. Background.
2.a. The SRRB process will be used to review, validate, prioritize, and approve service requirements to accurately inform the budget and acquisition processes. Per reference (a), contract service requirements must be vetted through an SRRB process as early in the services acquisition process as practical before a procurement request package is transferred to a contracting officer for execution.
2.b. Command leadership shall review, adjudicate, and prioritize service requirements. Requirement reviews should be appropriately tailored to include, but not be limited to, the following considerations.
2.b.1. Mission Need. Explanation of the mission need for the requirement and the outcomes to be achieved from acquiring services.
2.b.2. Strategic Alignment. How the requirement for services supports the broader organizational mission.
2.b.3. Issues and Risks. Both government and contractor issues and risks impacting the successful execution of fulfilling the requirement.
2.b.4. Workforce Analysis. An analysis of the decision to insource or outsource, including past decisions and why the requirement cannot be fulfilled with military or civilian personnel. Coordination with the DoD Component Manpower and Personnel officials should be done in accordance with DoD Directive 1100.4. The analysis should also take into consideration guidance outlined in DoD Instruction (DoDI) 1100.22, DoDI 7041.04, and Office of Management and Budget (OMB) Circular A-76/Section 2461 of Title 10, U.S.C. In addition, the Office of Small Business Programs (OSBP) is required to review and advise on any decisions to convert an activity performed by a small business concern to an activity conducted by a federal employee.
2.b.5. Relationship to Other Requirements. How the requirement for services impacts other requirements of the DoD Component (positively or negatively). For information technology (IT) services, ensure requirements are consistent with enterprise IT strategies.
2.b.6. Projected Cost of Requirement. Estimate the forecasted cost of fulfilling the requirement, at least through the Fiscal Year Defense Program (5 years).
2.b.7. Prioritization. A determination as to whether the requirement for services is a lower-priority requirement that can be reduced or eliminated with savings transferred to higher-priority objectives or mission requirements.
2.b.8. Contract and Work Functions. A review and identification of contract and work functions that may be prohibited or require heightened management attention, such as closely associated with inherently governmental or critical functions. For additional guidance on identification, SRRBs are recommended to use the DoD Handbook of Contract Function Checklists for Services Acquisition, as needed.
2.b.9. Metrics. Performance management metrics should be considered to the maximum extent practicable during the SRRB review and approval process.
3. Services Defined. Service contracts are defined in the Federal Acquisition Regulation (FAR) Section 37.101 as a "contract that directly engages the time and effort of a contractor whose primary purpose is to perform an identifiable task rather than to furnish an end item of supply." All service requirements and service contracts require SRRBs with the following exceptions:
3.a. Services listed in Section 37.502 of the Federal Acquisition Regulation (FAR) and services obtained under contracts with a total value of less than $1 million.
3.b. Services in direct support of a contingency, humanitarian, or peacekeeping operation as defined in FAR Section 2.101. This exemption shall apply to the response and initial deployment phase but shall terminate as soon as practical based on conditions on the ground and a determination by the decision authority.
3.c. Services that are required to respond to and recover from an emergency or disaster directly supporting an emergency declaration or a major disaster declaration by the President. This exemption shall apply to the response and initial recovery phase but shall terminate as soon as practical during the sustainment phase managing reconstruction and recovery efforts based on conditions on the ground and a determination by the decision authority.
3.d. Research and development (R&D) services (Product and Service Code (PSC) Category “A”).
3.e. Services from DoD Federally Funded Research and Development Centers (FFRDCs), which are acquired in accordance with the management structure described in FAR Section 35.017 and DoDI 5000.77 and from DoD University Affiliated Research Centers (UARCs), which are acquired in accordance with the management structure described in the DoD UARC Management Plan.
3.f. Construction services (PSC Category “Y”).
3.g. Services that are managed and reviewed as part of defense acquisition programs under other Adaptive Acquisition Framework pathways (see https:(slash)(slash)aaf.dau.edu for additional information on the pathways: Urgent Capability Acquisition, Middle Tier of Acquisition, Major Capability Acquisition, Software Acquisition, Defense Business Systems). DoDI 5000.74 and SRRB requirements may apply to services in the operations and support phase of these programs at the discretion of the Milestone Decision Authority.
3.h. Utilities services (PSC Category “S1”).
3.i. Commercial subscription services include database and information systems, periodicals, publications, and educational course subscriptions.
3.j. Service requirements funded at fifty percent or more by Foreign Military Sales.
3.k. Navy Marine Corps Intranet (NMCI) segment of the Next Generation Enterprise Network (NGEN) contract and the Sea Enterprise Global Installation Contract (GIC) services.
4. SRRB Requirements
4.a. The SRRB is a requirement validation process; SRRB approval does not constitute a promise to fund or a promise to award a contract. Final decisions related to contract execution, such as contract type, small business participation, and/or the extent of competition, are reserved for contracting officers.
4.b. Each Headquarters Marine Corps (HQMC) Agency and Marine Corps Commands are required to conduct a SRRB for any contract services requirement valued at $1 million or above including those that are funded by a Request for Contractual Procurement (NAVCOMPT 2276), Military Interdepartmental Purchase Request (MIPR), Fiscal Service Form 7600A, General Terms & Conditions (GT&C), project order, or any other method for obtaining contractor support. To determine when a SRRB is required, the value of the requirement is defined as the total estimated price of the contract, or task order, inclusive of all optional tasks and all optional periods. Additionally, pre-priced options not exercised at time of award, which exceed the SRRB threshold, also require subsequent review and approval prior to award. For Indefinite Delivery, Indefinite Quantity (IDIQ) contracts, only individual task orders meeting the SRRB threshold require an SRRB as no funding is obligated under the base contract.
4.b.1 The Department of the Navy Senior Services Manager (DON SSM) is reviewing various proposals to raise the SRRB threshold starting with FY25 contract services requirements. If approved, each HQMC Agency and Marine Corps Commands may conduct SRRBs at the new threshold.
4.c. Per reference (e), the Military Services are required to notify Congress about the cost and nature of advisory and assistance services falling under object class 25.1 through the PB-15 budget exhibit [Contracted Advisory and Assistance Services (CAAS) exhibit]. All Headquarters Marine Corps (HQMC) Agencies and Marine Corps Commands are required to review and validate any cost escalation within their SRRB in advisory and assistance services from FY24 to FY25 as delineated by object class 25.1 and outlined in Ref (f). Consequently, HQMC Agencies and Marine Corps Commands will certify that all cost escalations resulting from their SRRB are operationally essential and will note such within their finalized endorsement via the required SRRB validation authority.
4.d. The requiring activity is responsible for submitting service requirements to the SRRB regardless of the funding source.
4.e. Marine Corps activities receiving funds from another Marine Corps Command will rely on the originating command’s SRRB validation; an additional SRRB review is not required.
4.f. The SRRB should include representatives from the Comptroller Office and applicable Contracting Office(s). IT-related contract services requirements should also include the Command Information Officer. The SRRB validation authority may specify additional SRRB members and/or the appropriate participation level (e.g., Total Workforce Management Expert, Counsel/Local Area Counsel Offices, etc.).
4.g. The SRRB validation authority shall be the first General Officer (GO) or Senior Executive Service (SES) member in the chain of command. For activities that do not have a GO or SES member assigned, contractual services requirements at or above $1 million must be approved via an SRRB chaired by the first GO or SES member in the chain of command. Base Commanders (O-6) are authorized to chair SRRBs for contractual services requirements below $10M. This authority may be delegated in writing by the next GO or SES in the chain of command to the O-6 or GS-15 level. For any such delegation, the O-6 or GS-15 must provide an annual report of SRRB results to their first GO or SES member in the chain of command no later than the end of the fiscal year (FY).
5. SRRB Internal Controls.
5.a. SRRB approvals shall be documented by the SRRB chair or designated official.
5.a.1. SRRB approvals must be documented and certified by the SRRB chair or designated official with the following certification statement: “I certify that this purchase request requirement is in compliance with the standard guidelines found in the Department of Defense's Handbook of Contract Function Checklists for Services Acquisition (May 2018 or successor document), that all appropriate statutory risk mitigation efforts have been made, and that the purchase request does not include requirements formerly performed by Department of Defense civilian employees”. See the following site for the DoD Handbook of Contract Function Checklists for Services Acquisition: https:(slash)(slash)www.acq.osd.mil/asda/dpc/cp/policy/services-acquisition.html
5.a.1.a. The above certification statement is a statutory requirement (10 USC 4506).
5.a.2. SRRB chairs have discretion in how to document SRRB approval and certification. Some possibilities include the SRRB approval template included as attachment (1) to reference (C), meeting minutes, quad presentation charts, electronic systems, etc.
5.a.3. Should the SRRB chair require meeting minutes, action items, or recommendations, these shall also be documented as directed by the SRRB chair.
5.a.4. HQMC Agencies and Marine Corps Commands must retain all SRRB approval documentation. During Command Inspections, contractual services assessments, training visits, or other similar higher-level assessments, reviewers may request documentation that the HQMC Agency or Marine Corps Command must provide.
5.b. HQMC Agencies and Marine Corps Commands must identify, document, and implement appropriate internal control processes to ensure that funding documents for contract service requirements are not submitted to contracting officers without SRRB validation.
5.c. All funding documents shall include the following statement: “This service contract requirement has been approved by the (insert your organization here) SRRB on DD MM YYYY. The (insert your organization here) SRRB was chaired by - (insert SRRB chair’s name). The unique identifier is M#####-M#####-##-###.” For the SRRB identifier, the format will be Level 2 Command – Level 4 Command – 25- ### (e.g., M00027-M40085-25-123). A unique identifier will be provided upon upload of the requirement to the online portal, as described in 6.a.
6. SRRB Results Submissions.
6.a. SRRB results shall be submitted semi-annually via an online portal to improve data integrity and security. Submissions shall be made no later than 15 Aug 2024 and 01 Feb 2025. The 15 Aug 2024 submission shall include the SRRB results for acquisitions of contract services planned for execution within FY25. The 01 Feb 2025 submission shall validate previously approved requirements, remove any forgone requirements that are no longer necessary, and add any new requirements. Unanticipated contract services requirements not included in either formal submission must still be approved by an SRRB and uploaded to the online portal. Formalized reporting times aid in contracting office work planning.
6.b. Documentation for submission shall consist of a summary letter submitted to HQMC Programs and Resources (P&R), signed by the SRRB approving authority, and an upload of the SRRB data to the online portal. This summary will be made available to the applicable Contracting Offices upon request. Submit semi-annual cover letters to the Budget Execution Branch, P&R, at [email protected]. The Summary Letter must include two examples of cost savings, efficiencies, or process improvements identified during the SRRB.
6.c. An SRRB template and instructions to access the online portal will be distributed to comptrollers via an official tasker in the Enterprise Task Management Software Solution (ETMS2).
6.d. The following HQMC Agencies and Marine Corps Commands shall consolidate SRRB submission results for subordinate commands/organizations and designate a contract service point of contact:
6.d.1 Headquarters Marine Corps Comptroller
6.d.1.a. Director, Marine Corps Staff
6.d.1.b. Deputy Commandant for Plans, Policy, and Operations
6.d.1.c. Deputy Commandant for Combat Development and Integration
6.d.1.d. Deputy Commandant for Manpower and Reserve Affairs
6.d.1.e. Deputy Commandant for Installations and Logistics
6.d.1.f. Deputy Commandant for Aviation
6.d.1.g. Deputy Commandant for Programs and Resources
6.d.1.h. Deputy Commandant for Information
6.d.2. Commander, Marine Forces Pacific
6.d.3. Commander, Marine Forces Command
6.d.4. Commander, Marine Forces Reserve
6.d.5. Commander, Marine Forces Central
6.d.6. Commander, Marine Special Operations Command
6.d.7. Commander, Marine Forces Cyber Command
6.d.8. Commander, Marine Forces Europe/Africa
6.d.9. Commander, Marine Corps Installation Command (MCICOM)
6.d.10. Commander, Marine Corps Recruiting Command
6.d.11. Commanding General, Marine Corps Logistics Command
6.d.12. Commanding General, Training and Education Command
6.d.13. Commanding General, Marine Corps Systems Command
6.d.14. Program Executive Officer Land Systems
7. Marine Corps Business Council (MCBC)
7.a. The MCBC’s core responsibility is to manage the Marine Corps’ integrated portfolio of end-to-end business processes, fully supporting the Commandant of the Marine Corps (CMC) warfighting priorities. MCBC review shall ensure the Marine Corps’ business management aligns with standards that produce effective business process change, compliant internal controls, clean financial statement audit opinions, and effective business reform. MCBC will provide service-level management oversight, facilitate Marine Corps SRRB data analysis, and recommend to the appropriate agencies how efficiencies can be gained, duplication of contracting efforts can be eliminated, and where service-level sourcing can be achieved.
7.b. The MCBC is a standing body of most senior executives in the Marine Corps. These leaders review business process management and support policies, procedures, systems, and resourcing. MCBC authorities, derived from direction provided by the Assistant Commandant of the Marine Corps, result in recommended areas for improvement or change to support the warfighting or business processes of the CMC. The core members are Assistant Deputy Commandant for Programs and Resources (ADC P&R) (Chair of the MCBC), Counsel to the Commandant (Vice Chair of the MCBC), Assistant Deputy Commandant Manpower and Reserve Affairs (ADC M&RA), Assistant Deputy Commandant Installations and Logistics (ADC I&L), Assistant Deputy Commandant Information (ADC I), Executive Director, Marine Corps Systems Command (Ex Dir, MCSC). P&R’s Budget and Execution Directorate will distribute SRRB guidance, collect all SRRB data for each Level 2 Command, and transmit the aggregated data to I&L’s Contracting Office for its analysis in accordance with Paragraph 7.a.
7.c. In relation to SRRB functions, P&R Budget and Execution Directorate is the Marine Corps’ liaison to the Department of the Navy and other agencies.
7.d. The MCBC reports to the ACMC or his direct representative. The MCBC meets on a regular schedule.
8. Release authorized by Lieutenant General James H. Adams III, Deputy Commandant, Programs and Resources.//