Promoting Efficiency, Accountability, and Performance in Federal Contracting
1. Purpose
Executive Order 14402 aims to improve efficiency and accountability in federal contracting by promoting fixed-price contracts that focus on performance rather than merely cost reimbursement.
2. Key Actions And Directives
- Default to Fixed-Price Contracts: Agencies must adopt fixed-price contracts with performance-based considerations as the standard procurement method.
- Justification for Non-Fixed-Price Usage: Agencies must provide written justification to agency heads for any non-fixed-price contracts.
- Approval for High-Value Contracts: Contracts exceeding the agency's specified thresholds, e.g., $100 million for the Department of War, require agency head approval.
- Semi-annual Reporting: Agency heads must report semi-annually to the Director of OMB on the status of non-fixed-price contracts.
- Review of Large Contracts: Agencies need to review their largest non-fixed-price contracts within 90 days to explore modifications to fixed pricing.
- Guidance Issuance by OMB: The Director of OMB is required to issue implementing guidance within 45 days of the order.
3. Important Points
- Shift Towards Fixed-Price Contracts: This order emphasizes a significant shift away from cost-reimbursement contracts, which are seen as leading to overspending due to lack of cost control incentives.
- Increased Oversight for Non-Fixed-Price Contracts: The requirement for written justifications and semi-annual reports enhances accountability in contracting practices that deviate from the norm.
- Focus on Performance Incentives: The order aims to align contract incentives with performance outcomes, incentivizing contractors to deliver value effectively.
- Severability Clause: The inclusion of a severability provision ensures that if any part of the order is invalidated, the rest remains enforceable.
- No Creation of Enforceable Rights: The Executive Order explicitly states that it does not confer enforceable rights to individuals against the government.
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