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Summary of Changes

Permanent Note: On May 1, 2006, the Interim Internal Purchasing Guidelines were replaced by the Postal Service's Supplying Principles and Practices (SPs and Ps).

The SPs and Ps have been updated to reflect the following:

Ethics and Social Responsibility

Conflicts of Interest

  • The Ethics and Social Responsibility principle has been revised, specifically in the area of conflicts of interest. The new text discusses the need for purchase/SCM teams, contracting officers, and Postal Service management to fully consider and address any ethical concerns on the part of any employee involved in the contracting process as well as any organizational conflicts of interest on the part of suppliers. The new text also addresses financial conflicts of interest, impartiality in performing official duties and misuse of position, and organizational conflicts of interest.

Process Step 2: Evaluate Sources

2-1 Develop Purchase Plan

  • 2-1.1, General, is revised to state that written purchase plans are required for all competitive and noncompetitive purchases valued at $1 million or more.
  • 2-1.2, Preliminary Purchase Method Recommendation, is revised to state that as soon as a need arises, the requesting organization should contact the relevant purchasing organization to discuss upcoming requirements and how they should be met. An important element of planning is the purchase method recommendation (the decision to purchase either competitively or noncompetitively).
  • 2-1.3, Components of a Purchase Plan, contains both new and revised language.
  • 2-1.3.1, Competitive Purchases, contains a list of components that may be included in a purchase plan for a competitive contract. These requirements have been revised to apply to competitive contracts only.
  • 2-1.3.2, Noncompetitive Purchases, is a new section that contains a list of components that may be included in a purchase plan for a noncompetitive contract. These requirements have been revised to apply to noncompetitive contracts only. The contracting officer completes a purchase plan for noncompetitive purchases of $1 million or more after the noncompetitive purchase method has been approved by the appropriate authority.

2-10 Determine Extent of Competition

  • 2-10.3, Noncompetitive Purchases, is revised, restructured, and divided into several subsections.
  • 2-10.3.1, General, is a new section that states that noncompetitive purchases greater than $10,000 are subject to the procedures discussed in 2-10, Determine Extent of Competition.
  • 2-10.3.2, Business Scenarios, has been moved from its previous location and has replaced Switching Costs. There are now only four scenarios when the noncompetitive purchase method may be appropriate.
  • 2-10.3.3, Noncompetitive Purchase Request, is new. The requesting organization must submit a Noncompetitive Purchase Request to the contracting officer. All elements of the Noncompetitive Purchase Request must be addressed both fully and completely.
  • 2-10.3.4, Competition Advocate, is new and is comprised of two subsections: 2-10.3.4.1, General., and 2-10.3.4.2, Review.
  • 2-10.3.4.1, General., states that the Competition Advocate is responsible for (1) promoting competition throughout the purchasing process, (2) challenging barriers to the competition of requirements, (3) assisting purchase/SCM teams in the development of effective SCM solutions and obtaining best value, (4) completing an independent review of all Noncompetitive Purchase Requests for purchases valued at $1 million or more, (5) providing independent advice to contracting officers regarding proposed noncompetitive purchases, and (6) producing an annual report on noncompetitive purchase activity.
  • 2-10.3.4.2, Review., states that during the review, the Competition Advocate should consider the questions listed in this section. After the review of the Noncompetitive Purchase Request is complete, the Competition Advocate prepares his/her recommendations to the contracting officer.
  • 2-10.3.5, Contracting Officer Evaluation and Recommendation, is new and states that the contracting officer must review the Noncompetitive Purchase Request and perform a written evaluation of the proposed supplier’s past performance and supplier capability and any other matter he/she believes will lead to a more informed and effective purchase decision, including the Competition Advocate’s guidance if applicable. The contracting officer must document his/her approval or disapproval if within his or her delegated authority, or forward his or her recommendation through the management chain to the appropriate approval authority.
  • 2-10.3.6, Collaboration, is new and states that if the parties should disagree on the purchase method, then those parties should collaborate in order to make the final purchase method determination or recommendation.
  • 2-10.3.7, Purchase Method Approval Authorities, is new. This section states that portfolio managers within Supply Management may approve purchase method determinations for noncompetitive purchases valued up to $10 million, except for noncompetitive purchases of professional, technical, and consultant services valued at $1 million or more. Requests for noncompetitive professional, technical, and consultant services purchases valued at $1 million or more, and all other noncompetitive purchases valued at $10 million or more, must be reviewed and approved by the VP, SM. Portfolio managers may delegate up to $250,000 of their purchase method approval authority to subordinate team leaders or managers.
  • 2-10.3.8, Publicizing, states that all noncompetitive contract awards valued at more than $1 million must be publicized in the Government Point of Entry and other media, as appropriate. This text was in 3-2.5, Clauses and Provisions, and has moved to 2-10.3.8, Publicizing, for reader convenience.
  • 2-10.3.9, Documentation, is a new section that refers readers to 2-40.3.2, Contract Files for Noncompetitive Contracts, for information on required documentation.

2-18 Select Contract Type

  • 2-18.11, Ordering Agreements, is revised to more fully discuss ordering agreements, to establish that orders valued at $10,000 or more must be competed, and to add a discussion of Basic Purchasing Agreements.

2-20 Develop and Finalize Sourcing Strategy

2-25 Form Proposal Evaluation Team

  • 2-25.2, Identifying and Selecting Members, is revised to state that all members of the proposal evaluation team are required to complete the Conflict of Interest Certification and Nondisclosure Agreement. Additionally, when non-Postal Service employees are members of the proposal evaluation team, the contracting officer must take steps to safeguard against or mitigate any conflicts of interest.

2-34 Conduct Price/Cost Analysis

  • 2-34.4, Pricing Noncompetitive Offers, is revised to state that any of the pricing techniques listed in the SPs and Ps (with the exception of the comparison of competitive offers) can be used to price noncompetitive proposals. If the price analysis methods do not ensure that prices are fair and reasonable, then a cost analysis, or some other technique appropriate for the goods or services being purchased, should be performed.

2-40 Produce Contract Award Recommendation

  • 2-40.1, Contract Awards, is revised to state that the contracting officer is responsible for making the award recommendation after discussions and/or negotiations, determining the price is fair and reasonable, consulting with the purchase/SCM team (if necessary), and obtaining any required reviews and approvals.
  • 2-40.2, Best Value Determination and Award Recommendation, is re-titled and revised to discuss award recommendations for competitive and noncompetitive contracts.
  • 2-40.3, Contract File, is revised and addresses contract file documentation for competitive and noncompetitive contracts.

2-41 Obtain Selected Reviews and Approvals

Process Step 4: Deliver and Receive Requirements

4-1 Ordering

Process Step 5: Measure and Manage Supply

5-8 Contract Modifications

7 General Practices

7-12 Contracts with Former Postal Service Officers, Executives, and Employees, and Employees and Their Immediate Families

  • 7-12.4, Compensation, is a revised section that states that if the Postal Service contracts noncompetitively with a former employee for services similar to those performed by the former employee when he/she was employed with the Postal Service, then the rate of compensation will be consistent with the current salary range for the last position held by the former employee. In addition, the contracting officer must make a determination that the contract price is fair and reasonable.

7-15 Conflicts of Interest

  • This new section (7-15, Conflicts of Interest) has been added to the General Practices to address conflicts of interest. The section discusses financial conflicts of interest, impartiality in performing official duties and misuse of position, organizational conflicts of interest, and avoiding real or apparent conflicts of interest.

 




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