FAC Policy Analysis & Evaluation 2 — Questions and Answers
Question 1: Which framework is most commonly used by federal agencies to conduct a cost-benefit analysis (CBA) when evaluating acquisition policy alternatives?
- OMB Circular A-94 guidelines (Correct answer)
- FAR Part 12 commercial item rules
- DFARS subpart 207.1 procedures
- GAO decision tree analysis
Correct answer: OMB Circular A-94 guidelines
OMB Circular A-94 provides the standard guidelines for benefit-cost analysis of federal programs and regulatory proposals.
Question 2: A program manager wants to assess whether a new procurement policy reduced contract award cycle times. Which evaluation method best measures this outcome?
- Benchmarking against industry norms only
- Pre/post comparison using historical contracting data (Correct answer)
- Stakeholder opinion surveys alone
- Random assignment of contracts to test and control groups
Correct answer: Pre/post comparison using historical contracting data
A pre/post comparison using historical data directly measures changes in cycle time attributable to the policy change.
Question 3: Under the Program Management Improvement Accountability Act (PMIAA), what is required of major federal agencies regarding program management policy?
- Designate a Program Management Improvement Officer (PMIO) (Correct answer)
- Publish annual acquisition forecasts in the Federal Register
- Submit quarterly cost-benefit reports to OMB
- Conduct third-party audits of all major contracts annually
Correct answer: Designate a Program Management Improvement Officer (PMIO)
PMIAA requires covered agencies to designate a Program Management Improvement Officer to oversee policy implementation and improvement.
Question 4: When evaluating the effectiveness of a sole-source policy waiver, which metric would BEST indicate whether competition was appropriately limited?
- The number of modifications issued after award
- Price reasonableness determination documentation
- Comparison of awarded price to independent government cost estimates (Correct answer)
- Contractor past performance ratings
Correct answer: Comparison of awarded price to independent government cost estimates
Comparing the awarded price to the independent government cost estimate reveals whether the lack of competition resulted in an unreasonable price.
Question 5: A contracting officer conducts a policy gap analysis and finds that existing regulations do not address cloud service acquisitions. What is the appropriate next step?
- Proceed under the closest analogous FAR provision and document the rationale (Correct answer)
- Halt all cloud acquisitions until new regulations are published
- Seek a congressional appropriation to fund regulation drafting
- Delegate authority to the vendor to propose compliance terms
Correct answer: Proceed under the closest analogous FAR provision and document the rationale
When a regulatory gap exists, contracting officers should apply the most analogous provision and document their rationale while advocating for updated guidance.
Question 6: Which federal statute requires agencies to evaluate the performance of acquisition programs against cost, schedule, and performance goals?
- Federal Acquisition Streamlining Act (FASA)
- National Defense Authorization Act Section 809
- Government Performance and Results Modernization Act (GPRAMA) (Correct answer)
- Clinger-Cohen Act
Correct answer: Government Performance and Results Modernization Act (GPRAMA)
GPRAMA requires federal agencies to set strategic goals and evaluate program performance, including acquisition outcomes, against established targets.
Question 7: An agency discovers that its small business subcontracting policy is consistently resulting in subcontracting plan non-compliance by prime contractors. Which corrective action is MOST appropriate?
- Waive subcontracting requirements for all future contracts
- Assess liquidated damages and review the subcontracting plan review process (Correct answer)
- Transfer enforcement authority to the Small Business Administration exclusively
- Eliminate subcontracting plans for contracts under $10 million
Correct answer: Assess liquidated damages and review the subcontracting plan review process
FAR 19.705-7 authorizes assessing liquidated damages for non-compliance, and reviewing the plan review process addresses systemic root causes.
FAC Policy Analysis & Evaluation 2
Which framework is most commonly used by federal agencies to conduct a cost-benefit analysis (CBA) when evaluating acquisition policy alternatives?