B-1 Process ď ś How the B-1 Procedure has changed ď ś How the changes will impact CRPs
Panel Participants Sally Henderson Executive Director NISH South Central Region
Jean Robinson NISH General Counsel
Nancy Yoder Business Development Director NISH North Central Region
Nicole Hansma Senior Program Manager, CRP Support NISH National Business Development
Joel Pagliarello Director, Customer Relations, NISH Regional Operations
Kim Roland, Director, Contract and Support Management NISH Products
AbilityOne Program Bulletin No. B-1
• History of the B-1 Procedure • New version of B-1 – What changed in the new version?
• CRP Customer Satisfaction Survey – Responses and B-1 Changes
• Project Distribution in FY10
What is the AbilityOne Program Bulletin No. B-1?
Project Development Distribution and Transparency Procedure This document sets forth the procedure and criteria by which NISH will distribute AbilityOne opportunities and projects to qualified Community Rehabilitation Programs (CRPs).
History of AbilityOne Program Bulletin No. B-1
• Distribution of projects has taken place since 1974. • NISH has grown and changed in response to the environment in which it exists. • Changes to the distribution process have taken place due to: – Legal or Regulatory Changes – CRP Input – Federal Customer Input
History of AbilityOne Program Bulletin No. B-1
FY00: – NISH engages the NCWC in discussions on project distribution: What process would the NCWC like put into place? – Distribution process developed in close coordination and acceptance by NCWC. FY01 – The first JWOD Program Bulletin (B-1) issued on project distribution “best practices.” FY04: – Minor edits and clarifications of “distribution criteria.”
History of AbilityOne Program Bulletin No. B-1
FY05: – Procedure developed to provide more objectivity and consistency in distribution of projects to CRPs FY08: – Limited use of sole-source informational postings – Added new subscription notification service FY09: – Added new ineligibility requirements and an ineligibility review process – Added clarification around NISH Four Step Process – Increased the number of days that a CRP has to request a debriefing if not selected – Changed whom to address initial and final appeals – Announced that the Chief Operating Officer’s decision on appeals is final
AbilityOne Program Bulletin No. B-1 FY11: Updates to Procedure
Version D to be released soon: • States statutory authority for NISH making distribution decisions: – Title 41: Public Contracts and Property Management, PART 51–3—CENTRAL NONPROFIT AGENCIES – § 51-3.2 Responsibilities under the JWOD Program. – Each central nonprofit agency shall: • Represent its participating nonprofit agencies in dealing with the Committee under the JWOD Act. • Evaluate the qualifications and capabilities of its nonprofit agencies…
AbilityOne Program Bulletin No. B-1 FY11: Updates to Procedure
For Any Opportunity – Eligibility Considerations (“Go/No-Go”) • A CRP must have met the 75% Agency ratio or have a written plan with the Committee or the NISH Regulatory Department. • CRPs that do not currently have any AbilityOne Projects must be affiliates in good standing and able to meet all Program requirements. • A CRP will be compliant with the requirements set forth in NISH’s Procedures/policy for Reporting of AbilityOne Sales and Payment of NISH AbilityOne Funding Fee.
AbilityOne Program Bulletin No. B-1 FY11: Updates to Procedure
For Any Opportunity – Eligibility Considerations (“Go/No-Go”) • CRPs that have a valid cure-notice applicable to any of their AbilityOne projects, or are currently in Step #2, #3, or #4 of the 4-Step Process due to performance /quality issues, will not be eligible for any new opportunities. • If a CRP’s AbilityOne Contract has been removed, it will not be eligible for new opportunities until one year has elapsed and the CRP can demonstrate renewed capability. • A CRP must be current in its annual registration with NISH.
AbilityOne Program Bulletin No. B-1 FY11: Updates to Procedure
• Updated distribution principles – Recognizes that federal customer may have input to consider when making distribution decisions – Gives authority to Executive Directors to make solesource assignment to a CRP for projects with an estimated total annual dollar value of $50,000 or less (similar to Contracting Officer’s discretionary authority)
AbilityOne Program Bulletin No. B-1 FY11: Updates to Procedure
• Updated distribution principles • Communication with CRPs to ensure consistency • Responsibilities of NISH staff
• Updated considerations for distribution • Mentoring and subcontracting considerations • Projects with an annual value in excess of $1M will trigger a financial stability and sustainability assessment
• Refined appeal process • COO appeal only allowed if there is new pertinent information that was not available at the time the Vice President, Regional Operations issued the initial decision
Future of AbilityOne Program Bulletin No. B-1
• This is a “living” document • More changes may come in FY11 – We will keep you informed
• NISH will continue to make edits to this process as necessary: – To respond to changes in the procurement environment – To respond to requests, as appropriate, from our CRP or Federal customer
FY10 CRP Customer Satisfaction Survey
Comments: process must be re-evaluated” • “Still does not ‘level’ the playing field” • “My company appears to never get the proper consideration when a new project is available” •
“B-1
– We heard you and have made changes to provide more clarity to the process, including more consistent Sources Sought Notices documentation, objective evaluation by NISH team members, and providing opportunities to smaller CRPs.
FY10 CRP Customer Satisfaction Survey
Comments: • “It seems projects are increasingly given to the big work centers when projects could help other work centers” • “There continues to be a need by small CRPs to acquire projects. With the purchasing process of large contracts, the small agencies are precluded. It would be helpful for mentorship and/or sub-contracting to be provided to smaller CRPs so that they can grow”
FY10 CRP Customer Satisfaction Survey
Change in B-1 Procedure Consideration: “The CRP is willing to mentor and/or enter into subcontracting arrangements with new or smaller CRPs to perform this project.�
FY10 CRP Customer Satisfaction Survey
Comments: • “Provision of any known vendor information would be helpful in meeting submittal deadlines and would save the CRP the time and resources invested in researching product, materials and supplies.” – When possible, information related to Commercial vendors will be provided by NISH. The provision of information will be provided as background and will not “endorse” these companies.
Comments on B-1 Procedure • “I think the process has taken on new issues and concerns with more projects being offered to larger CRPs” • “I do not believe that small operators like our program receive much attention or assistance in growing our list of AO contracts. It appears that the large operators receive the vast majority of attention and support. This trend seems to be growing”
FY10 PL Additions: 134 Projects; $185.6M; 1496 FTE
• Top 25 CRPs (By FY10 AbilityOne Reported Sales) – 27 Projects; $71.2M; 622 FTE
• 26 – 100 – 37 Projects; $71.7M; 509 FTE
• 100 – 534 – 70 Projects; $42.7M; 365 FTE
FY10 Project Distribution
FY10 Project Distribution Sales ($M)
FY10 Project Distribution FTEs
23%
24% 42%
34%
38%
1-25
1-25
26-100
26-100
101-600
101-600 39%
FY09 PL Additions: 94 Projects; $120.3M; 1002 FTE
• Top 25 CRPs (By FY09 AbilityOne Reported Sales) – 18 Projects; $ 62.8M; 406.3 FTE
• 26 – 100 – 31 Projects; $42.3M; 421.4 FTE
• 100 – 540 – 45 Projects; $15.2M; 174.3 FTE
FY09 Project Distribution
FY09 Project Distribution Sales ($M)
FY09 Project Distribution FTEs
13%
17%
41%
1-25
1-25 26-100 101-600
42%
52% 35%
26-100 101-600
It’s not ALL bad! • “I feel the process is very fair and levels the playing field”- S • “The process is working well in my opinion”- NW • “I like the new transparency process. For the most part, we understand when a distribution goes to another producer” SC • “You only bid the contracts that your organization has potential in doing, the program offers a wide array of opportunities in both products and services” - NC • “Project distribution seems to be as fair as an inherently competitive process can be....we have no complaints” - E • “Probably the hardest thing NISH leadership has to do” - NW
Thank you!
Panelist Discussion and Questions
Session Evaluation Information
SESSION TITLE: B1 SESSION CODE: A1-W130