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www.oscreadiness.org 15 th Annual OSC Readiness Training Program IGCEs: From Scoping to Funding

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www.oscreadiness.org

15th Annual OSC Readiness Training Program

IGCEs: From Scoping to Funding

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-1

Course Objectives

After taking this course, participants will be able to: Describe the purpose of an IGCE Identify the elements of an IGCE Connect the importance of proper scoping to

development of an IGCE Identify tools and resources to assist in preparing

an IGCE

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-2

Meet the Instructors

John Gilbert – EPA ERT Michelle Jaster – EPA Region 5 Rich Messimer – EPA Region 3 Carl Norman – EPA Region 5

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-3

Course Topics

Module 1 – Introduction and Background Module 2 – Scoping Exercise Part 1 Module 3 – Scoping Exercise Part 2 Module 4 – Examining IGCEs and Exercise

Debrief Module 5 – Wrap Up

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-4

Before We Dive In – Logistics

Emergency procedures Location of restrooms Reminder to set cell phones

& pagers to silent mode Breaks Conference reminders

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-5

Background Topics

Definition of an IGCE Requirements for preparing an IGCE Uses of an IGCE Components of an IGCE Resources and tools for scoping and

preparing an IGCE

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-6

What is an IGCE?

A detailed estimate of the cost to the Government for services and/or supplies to be acquired

Government’s own estimate of the cost of work Should not be based on information from a

contractor who will be bidding on the work Should never be disclosed to the contractor prior

to Work Plan/Cost Estimation submission

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-7

When is an IGCE Required?

Contract actions greater than FAR threshold for simplified acquisitions - >$150,000 “Contract actions” include:

• New contract awards• Modifications to increase the scope of work of the

contract, work assignments/task orders, and delivery orders

In Removal program, IGCEs should be prepared for Most ERRS delivery/task orders Large START task orders/TDDs For existing TOs and TDDs with increase in

scope

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-8

What Are IGCEs Used For?

Budget purposes prior to awarding contracts or issuing TOs, DOs, TDDs, and WAs Feeds into Action Memo

Evaluating proposals for new contracts Evaluating proposals for TOs, TDDs, DOs,

and WAs Basis for discussions/negotiations with

contractor Documenting decisions

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-9

Who Prepares IGCEs?

Program office Technical personnel most familiar with the work

OSCs

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-10

Three Keys to Good IGCE

SCOPING ! Begins with thorough scoping Thorough scoping involves

breaking the work down into tasks – bottom up method

Breaking tasks down into subtasks

SCOPING !! Identifies subtasks per task Personnel and equipment Time, travel, other direct costs

SCOPING !!! Demonstrates how well project

requirements are understood

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-11

Good Scoping Leads to Adequate . . .

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-12

Shining a Spotlight

IGCEs

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-13

Recent OIG Audit on IGCEs

Audit performed as follow-up to findings cited in a 2007 GAO report

Evaluated overall quality of IGCEs and if they served as effective tools to determine the best value for dollars expended on Superfund contracts

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-14

Audit Explored Five Areas

Clear identification of tasks Relevant data identified and used to develop

IGCE Use of a defined/structured estimating

process IGCE revised as necessary IGCE assumptions properly documented

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-15

Removal Contracts Were Evaluated

Region 2 ERRS Region 4 ERRS and START Region 5 START Region 7 START Region 10 ERRS

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-16

Major Audit Findings

EPA needs to improve IGCEs and cost estimating processes

Overall lack of emphasis from management related to IGCE development

Internal guides and other resources related to IGCEs are outdated

Employees responsible for preparing/reviewing IGCEs are undertrained

Program staff not sufficiently documenting rationale, assumptions, and changes relating to IGCEs.

Program staff over reliance on the contractor’s cost estimates

Failure to prepare an IGCE for contract actions in excess of the simplified acquisition threshold

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-17

Recommendations and Actions

Audit Recommendations OAM update IGCE Guidance Require compliance with and

update guidance as part of Quality Assurance Programs

Cease current practice of accepting contractor estimates without explanation of difference from IGCE

Periodically update, distribute, and maintain tools and guidance used to develop IGCEs

Provide training to Program Staff

OAM Actions Taken Reviewed existing cost

estimating practices Redesigned IGCE templates to

address audit findings Developed an IGCE

preparation training module More to come….

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-18

Typical Problems with IGCEs Part 1

Statement of Work and individual tasks are not clearly defined

Not accounting for all project tasks Undetermined or poorly scoped site needs Not considering local and state government

and neighborhood concerns Davis Bacon Act v. SCA

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-19

Typical Problems With IGCEsPart 2

Contract differences – personnel and equipment rates, travel

Cost and frequency of mobilization and demobilization

Costs for temporary site closure Costs of after-hour and weekend security

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-20

Typical Problems With IGCEsPart 3

Cost of initial contractor on-scene survey and detailed work plan

Off-site hours prior to mobilization, during active operations, and after site closure

Major changes encountered that change IGCE Increasing project costs and time due to limited

regional extramural funding or contract capacity Unknown or undetermined waste quantities or

waste streams

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-21

Personnel Resources for Preparing IGCEs

Project Officer Field Accountant ERT Other OSCs

Contractor

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Tools for Preparing IGCEs

RCMS Available to every Region Can look at historical data

Excel spreadsheets Region-specific

Existing IGCEs for similar work POLREPs for similar work

15th Annual OSC Readiness Training Program www.oscreadiness.org 1-23

Summary

IGCEs are required for most projects Scoping is the key There are resources and tools for preparing

IGCEs Don’t recreate the wheel!

Find a tool you like and use it. Repeatedly. Use previous similar sites as your starting point