MAIL BAG: MUST I LABOR OVER CATEGORY DESCRIPTIONS WHEN ALL THE CUSTOMER WANTS IS MARY?

Alert reader M. Kunis of Quahog, RI writes, “My long-time federal customer wants us to hire Mary, one of their own recent retirees, and have Mary go back to work for them as a contract employee.  How do I work this with the labor rates I have on my Schedule?”.  Excellent question, M. and one that you’re smart to think about.  While procurement rules try to ban “personal services” acquisition, people are people.  They like working with those that they know, especially if it’s a recent retiree who knows more about an agency function than anyone on the inside.  Contractors have to make sure, though, that the labor category they assign to the individual is a good fit.  In this case, if Mary only has a BA, and the labor category states that all people in it have an MS, this could be a problem.  One way to address this is at contract formation or modification.  Make sure you use phrases like “education or relevant professional experience”, or a phrase like “work experience is regularly considered to be an acceptable alternative to an advanced degree”.  This way, you can bill for Mary in a way that makes sense for both you and the customer agency.  An outcome that would make Meg Griffin, herself, proud.