Office of Inspector General Develop guidance for staff on the requirements of FAR § 16.103(d)(1), including updating templates. The guidance should address all the required elements and specify whether it will be documented in the acquisition plan or another document in the contract file.
Provide training to PBGC staff involved in contracting on the requirements of FAR § 16.103(d)(1), highlighting how the staff are required to document contract type risk considerations in the contract file.
Ensure timely development and approval of contract type D&Fs that address all FAR requirements, including a mechanism to track the timeliness of this process.
Review and update guidance to program office staff to ensure they provide information to support all required FAR elements for contract type D&Fs.
Provide training to procurement and program office staff on additional requirements for contract types other than firm-fixed-price. This training should include guidance as to what is needed for sufficient justifications required to comply with FAR requirements related to maximizing the use of firm-fixed-price on future acquisitions.