Experience a Substitution of education?

OPM requgulations and 5 CFR only applies to government employees. However some agencies make compliance a requirement. I don't know why other than having some control over the people the contractor provides. When they do, it's up to that agency (the CO) to decide whether to allow the substitution.

Agreed, my CO was just looking for some regulatory backup to her decision to allow contractors to re-staff substituting experience for education. As far as I am concerned as long as the decision is reasonable let them do it; we the government should get out of the business of reading and approving resumes. Ultimately, the contractor is responsible for staffing the contract with qualified personnel?

Steve

Steve,

Your thoughts are right on target. Describe the work you want done in terms of required outcomes, establish standards for acceptance, and stay away from deciding who the contractor uses on the job.

Another thought is your CO may want to consider the FAC-C requirements of OFPP. Here is the link to the memorandum regarding FAC-C - http://www.whitehouse.gov/omb/procurement/...ing_program.pdf

I have seen where at least one Department (Agriculture) has stipulated that FAC-C standards required for certification should be extended to contracted resources. Here is the statement from Agriculture Acquisition Advisory No. 85 that implements FAC-C for USDA agencies.

"Contract Specialist awarding contracts for the performance of acquisition functions as outlined in OFPP Policy Letter 05-01 (Appendix shall assure solicited personnel meet comparable training requirements for government employees performing the same or similar functions."