Enclosure (1) to COMDTINST 5224.3
COMMERCIAL ACTIVITIES INVENTORY
Introduction. The Coast Guard is responsible for implementing and managing cost
comparisons in accordance with the principles and procedures of the FAIR Act, OMB
Circular A-76 and the Revised Supplement. OMB has directed agencies that require or
provide administrative or other commercial support services consider the use A-76 as a
management tool and use competition and privatization to optimize resources, manage
budgets and react to changing missions. The A-76 program is a critical management tool
that can assist the Coast Guard in achieving annual performance plans, budget savings, and
improved performance. Because departments were not committed to using A-76 as a
management tool, Congress in October 1998 passed legislation (FAIR Act, P. L. 105-270)
to raise visibility of the program. The act requires all agencies to submit an annual
inventory of Commercial Activities starting 30 June 1999.
Inventory. The inventory requires a review of full and part time positions to determine
which functions and positions support activities that are:
Inherently governmental (those positions so intimately related to the public
interest as to mandate performance by Federal employees).
Commercial, but specifically exempt from cost comparison requirements of
OMB Circular A-76 (conversion to or from in-house, contract or Interservice
Support Agreement (ISSA) performance is permitted without a cost
comparison). Examples of these include National Defense, patient care, core
capability, less than 10 full time equivalents (FTE's) and greater than 10 FTE's if
all directly affected Federal employees serving on permanent appointments are
reassigned to other comparable Federal positions for which they are qualified.
Commercial and should be competed; and
Commercial, but specifically exempt by the agency from the cost comparison
requirements of the Circular and the A-76 supplement because the agency does
not want to study at this time. The agency may decide to go direct to contract
without a cost comparison.
At this time, only those positions designated as commercial are reported outside Coast
Guard headquarters; however, OMB may request a total functional inventory.
Inherently governmental positions are identified and tracked in the Personnel
Allowance List (PAL) in the same manner as commercial activity positions.
A functional code (Appendix A) will be assigned by the program manager or a
designated representative to identify each position in the Coast Guard Personnel
Allowance List (PAL) regardless of the type activity this position supports.