Description
DESCRIPTIONS I SPECIFICATIONS I STATEMENT OF WORK PURPOSE The Employment and Training Administration (ETA) has a requirement for a qualified contractor that can provide analytical support for administrative, technical or economically significant rules undertaken by the Employment and Training Administration. The Analytical Support for Regulation Development Contract supports the Department of Labor (DOL), ETA, and the Office of Policy Development and Research (OPDR), in the collection, analysis, and development of summary statements of public comments received during the public comment phase of various regulatory initiatives. The contactor shall be responsible for assisting OPDR with the management of public comments under the guidance of OPDR in support of a number of workforce investment system regulatory initiatives. Rule-making activities undertaken as part of this support function include, but are not limited to, collection of public comments, sorting and analysis of comments, preparing comment summaries, tracking dispensation of each comment received, developing summary reports on comments, and assistance with economic and cost-benefit analysis of rulemaking requirements. This work requires that the contractor provide access to a database and Web-based tools in order to: share access to the comments; analyze and sort the content of the comments; prepare comment summaries, and track progress and dispensation of each public comment received. The contractor must be able to manage public comments based upon a secure Web-based software product, and provide Federal staff with real-time access over the Web to results of the contractor's comment sorting and analysis. BACKGROUND OPDR assists ETA in supporting its goal to develop workforce policies and investments and support the continuous improvement of the public workforce investment system by analyzing, formulating, and recommending legislative changes and options for policy initiatives. OPDR provides ETA with strategic approaches to improve performance and outcomes through research, demonstrations and the evaluation of major ETA programs. OPDR then coordinates the development of ETA rulemaking documents implementing Federal statutes or amending outdated information into a regulation. Events that trigger regulation development and implementation include but are not limited to: Legislation, Executive Orders, Task Force reports, Petitions, Court Decisions, Accidents/Incidents, Technology, Need for Modernization, Needs for Streamlining, and Needs for Reducing Burden. The Analytical Support for Regulation Development Contract supports DOL, ETA and OPDR in the collection, analysis, and development of summary statements of public comments received during the public comment phase of various regulatory and other initiatives as identified above. The contactor shall be responsible for assisting OPDR with the management of public comments under the guidance of OPDR in support of FOL, ETA and OPDR regulatory, legislative and executive Order related initiatives. OBJECTIVES This Analytical Support for Regulation Development Blanket Purchase Agreement (BPA) will support DOL, ETA, and the Office of Policy Development and Research (OPDR), in development of the Notice of Proposed Rulemaking (NPRM) and Final Rule activities, including but not limited to specific regulatory texts and preambles, administrative section and regulatory flexibility analyses, economic analyses and other work products needed to move the development of the NPRMs forward for publication in the Federal Register, the collection, analysis, and development of summary statements of public comments received during the public comment phase of various regulatory initiatives. With guidance from DOL, ETA and/or OPDR, the contactor shall be responsible for providing support for specific tasks related to preparation of the NPRMs and Final Rules that include the management, analyses, and dispensation of public comments with the intent to support the public workforce investment system. Activities undertaken as part of this support include, but are not limited to, the collection of public comments, sorting and analysis of comments, preparing comment summaries, tracking dispensation of each comment received, developing summary reports on comments, and developing the cost-benefit analysis of rulemaking. The contractor shall provide access to a database and Web-based tools in order to: share access to the comments; analyze and sort the content of the comments; prepare comment summaries, and track progress and dispensation of each public comment received; as well as to document the economic and cost-benefit analysis involved with rule-making. The contractor must be able to manage public comments based upon a secure Web-based software product, and provide Federal staff with real-time access over the Web to results of the contractor's sorting, and summary reports of the comments collected tracked and analyzed. TASKS Task Order Work Plan. The contractor shall develop task order work plan to address each specific rule-making request, as identified by ETA for each triggering event. The contractor will identify the appropriate activities for each task order awarded, following the task requirements outlined below. The contractor shall provide Principal Consultants, Senior Consultant(s), Consultant(s), Junior Consultants and a Training Specialist to do the following work: User Training and Technical Support for Web-accessible Public Comment Analysis Database. The contractor must provide user training and technical support for a Web-accessible public comment database. Subtask activities include the following: Create and provide user accounts with appropriate system privileges (e.g., read only, edit, approve) created and provided for project staff. Deliver web-accessible database system training tailored to project needs; and, at a minimum, entails a demonstration for the basic internet accessible system features and a more extensive training session for users who need to use the more involved features related to comment content analysis described in the tasks below. Provide end-user support via telephone, e-mail, or on-site service (if requested) to project staff throughout the project. This support will include, as necessary, tips for using the database features, answers to questions about the software, performance monitoring, and troubleshooting. Receive, Process, Load, and Classify Comment Submissions. The contractor receives, processes, loads and classifies comment submissions, as directed by the Contracting Officer's Representative (COR). Sub-task activities include the following: Obtain working copies of all public comments and load them into the web-based software. As part of this task, the contractor will also receive, scan, translate to English (if necessary), and prepare and load paper comment submissions into the Federal Docket Management System (FDMS) or any other system that the government deems appropriate for comment submissions. Identify and enter appropriate identifying information about the submission/submitter (e.g., comment number, date, organization and/or commenter name. commenter type. etc.) into FDMS (or other government-approved system), and the web-based software. Review and classify the comments and letters as either substantive (major), non-substantive (minor), form letter, duplicate, or non-germane to each rule-making initiative. Make results available to OPDR staff and appropriate program office staff on a real-time basis through the comment tracking component of the project-specific web-site. In addition, and at the request of the COR, the contractor may be required to prepare paper dockets of the comments received on the rulemaking activities. The contractor will be responsible for entering all comments related to each specific rule making initiative into the FDMS (or other government-approved system), and making necessary classifications. The contractor shall also be responsible for alerting OPDR if any commenter makes a request an extension to the comment period for any of the rule-making initiatives. Analyze and Sort Public Comment Content. The contractor shall analyze and sort public comment content for each task order awarded. To ensure the analysis and sorted content fulfills agency requirements, the contractor shall performance the following sub-task activities: Partner and work closely with OPDR staff and appropriate program office subject matter experts to prepare a detailed, hierarchical outline, of the key issues for each rulemaking initiative, which is to be used to organize and summarize comments. In addition to developing the key issues outline, partner and work closely with agency staff and subject matter experts to develop protocols for bracketing and coding comment excerpts to issues (e.g., how to handle background/introductory or redundant information). Categorize minor/non-substantive comment submissions in their entirety, into one or more relevant topical categories, e.g., general support, general opposition, request for comment period extension. etc. For comment submissions that contain major/substantive comments, prepare a text-based version of the comment that will allow for it to be parsed into individual salient comments that will then be coded and sorted according to the key issues outline, including the following : Review each unique and substantive comment submission, identify substantive comments within each submission (bracketing), and associate each comment to the issue(s) to which it applies (coding). 11. Make the results from bracketing and coding process available to OPDR and appropriate program office staff in real time through the internet by generating reports of comments by issue category. Provide a report that includes all substantive comments and their key identifying information sorted by issue category, at the direction of the task order COR. For each rulemaking activity, the contractor will receive a schedule that provides a timeframe for the public comment collection; sorting, coding and analysis; tracking dispensation; and substantive comment summary report must be submitted. The contractor shall notify OPDR within two (2) business days of receipt of any comments which request an extension of the rule-making comment period. Comment Summary Report. The Contractor shall provide support for the Comment Summary Report, as directed by the COR, and after the comments sorted and coded into the issue categories. The additional support may include the following subtask activities: Prepare summaries of the public comments received under each issue topic, according to the following steps: Work with OPDR and appropriate program office staff to prepare an annotated outline and model section for these summaries. Develop written content in a style and format suitable to form the basis of a comment response supplement in the Federal Register. 111. Identify the substantive arguments of the comments received and the sources of the comments on the issue, the general magnitude of the comments (e.g., many, several, few), and include one or more illustrative examples of excerpts from individual comments. Provide comment summaries to OPDR and appropriate program office staff so that agency staff can prepare group responses to comments that make similar arguments on a given issue. The Contractor shall download the relevant sections of the CFR in Word format to facilitate the actions required for each rule-making initiative. For each rule-making initiative, the contractor will also receive a schedule providing the timeframe in which to complete all of the support service activities that lead to the submission of the substantive comment summary report. Additional NPRMs/Final Rules Support. The contractor shall provide additional regulatory, analysis, and business process support services that may be required for the development and implementation of NPRMs and Final Rules, that includes, but is not limited to: l) revisions to comments; 2) creating crosswalks with the action identified for regulatory change; 3) economic analysis for each proposed rule, if needed; 4) cost-benefit analyses; 5) assistance with developing Paperwork Reduction Act (PRA) packages; 6) assistance with drafting or revising regulation text based on policy decisions provided by the Agency; and 7) other related analyses. These subtasks include, but are not limited to the following activities: Propose, establish and maintain a matrix and supporting process for comment revisions, as they relate to the triggering events, the NPRMs, and the Final Rules. The matrix and process may include, but is not limited to: i. Provide general description of the rule-making provisions to indicate which the sections will need to be revised. For example, the Contractor may indicate whether the statutory provisions can be codified without change or whether ETA might need to develop regulations that interpret the provisions . Create relevant and timely crosswalks with the action identified for regulatory change. When requested, determine, propose and implement a methodology to conduct an economic analysis for the proposed rule or rule change. When requested, determines, propose and implement a methodology to conduct a cost benefit analysis for the proposed rule or rule change. Develop and propose a timeline, and complete the appropriate Paperwork Reduction Act documentation for Departmental clearance and submission to the Office of Management and Budget (OMB). Provide assistance with drafting or revising regulation text for each proposed rule or rule change to respond to the triggering event. Provide additional NPRM drafting support and cover the following activities: Coordinate and draft sections of the NPRM regulations and preambles with program office input. Conduct an economic analysis and provide contextual language for the NPRMs. Provide economic analysis support and additional documentation, as needed, during Departmental clearance and OMB passback. Produce a cost-benefit analysis and provide contextual language for the NPRMs, as needed. Draft supporting statements and justification for OMB approval, as needed. Use an additional FDMS (or other government-approved system), comment receipt, processing and posting to cover the following activities: i. Read the comment submissions for threats and unintended PII to determine whether these comments should be redacted or posted. 11. Post electronic comments to regulations .gov. or other relevant governmental system if replaced. iii. Scan hard copy comments received and adding them into FDMS (or other government approved system), with required meta-data analysis. Post scanned comments through FDMS to regulations.gov*(or other government approved system). Provide additional Final Rule support (beginning after publication of the NPRM) and cover the following activities. i. Conduct public comment analysis. 11. Group comments by section and subject matter and other criteria for analysis (using a comment coding system to develop draft outline for sorting comment, etc.) Salient Features of a Comment Coding System are as follows: A database and Web-based tools, which is capable of sharing access to the rulemaking comments, analyzing and sorting the content of the comments; providing data that will allow preparation of comment summaries, and tracking the progress and dispensation of each public comment received. The secure Web-based software product should provide Federal staff with real-time access over the Web to results of the contractor's comment sorting and analysis based on appropriate levels of systems, privileges (e.g. read only, edit, approve) within the software. As requested, the Contractor shall: Complete comment analysis (full-detailed analysis, with summary and executive summary of comments and drop in language for consolidated comments for preamble to the final rule). Print the final docket of comments for the record. Coordinate and draft sections of the Final rule regulations and preambles with program office input. Conduct an economic analysis and, as requested, provide drop in language for the Final Rules. Produce a Cost-Benefit Analysis and, as requested, provide drop in language for the Final Rules Small Business Administration (SBA) certification (if needed). The contractor will use the practices set forth in the SBA's Office of Advocacy, Regulatory Flexibility Act guide entitled, "Implementing the President's Small Business Agenda and Executive Order 13272, May 20 12," to assist in preparing the necessary information for certification to SBA. Once the certification decision is made, the contractor may be asked to assist in preparing necessary documentation to notify the Office of Advocacy and publish the certification in the Federal Register. Develop and propose a timeline, and complete the appropriate Paperwork Reduction Act documentation for Departmental clearance and submission to OMB. Provide assistance with drafting or revising regulation text for each proposed rule or rule change to respond policy decisions provided by the Agency Other services necessary to the final development of the DOL/ETA rules Other Regulatory Development and Implementation Support Services. The contractor shall provide other regulatory, analysis, and business process support services that may be required for the development and implementation of the final regulations. Other development and implementation support services, may include developing or improving on a plan, method, or design for the rulemaking analysis and business processes to ensure that tasks identified for accessing and conducting training and technical support, managing the comment submissions, analyzing and sorting comment content, and comment summary reports to meet Agency requirements. Contractor Key Personnel Requirements The contractor shall provide the necessary personnel to accomplish each task listed in the statement of work. The key personnel positions and their required time commitment and qualifications are as follows: Principal Consultant Duties: Experience includes leading large and/or complex project teams and providing services in one or more relevant service areas, including: consulting services, facilitation services; survey services; training services; and program integration and project management services. Expert in the use of relevant analytical, methodological, and management tools needed to organize, perform and deliver the services being provided, such as statistical analysis software packages, instructional system design methodologies, or evaluation methodologies. This position is responsible for planning and delivering the relevant set of services. In this role, this person understands the customer requirements, translates those requirements into plans for performing services, supervises the performance of services, performs services, provides advice and counsel, and provides quality control and oversight. Under circumstances in which the project allows (such as the services being relatively straightforward), this position may delegate a portion of this role to the Senior Consultant, while retaining overall responsibility for the services being provided. Experience Level: I 0 years of relevant work experience in one or more of the following service areas: business administration, public policy, economics, political science, communications, planning, statistics, technology and policy. Master's Degree in business administration, public policy, economics, political science, communications, planning, statistics, technology and policy, or related discipline. Project Director Duties: Performs day-to-day management of contract support operations that possibly involves multiple tasks and groups of personnel at multiple locations, on a single project. Demonstrates an ability to lead large and/or complex project teams and provides services in one or more of the following relevant service areas, including: consulting, facilitation; survey development; training; and program integration and project management. Proves expertise in the use of relevant analytical, methodological, and management tools needed to organize, perform and deliver the services being provided, such as comment and coding databases, research methods and models, statistical analysis software packages, instructional system design methodologies, or evaluation methodologies. Experience Level: 12 years of relevant work experience in one or more of the following service areas: business administration, public policy, economics, political science, communications, planning, statistics, technology and policy. Master's Degree in business administration, public policy, economics, political science, communications, planning, statistics, technology and policy, or related discipline. Senior Consultant Duties: Assists project director with leading teams and provides support for complex projects in one or more of the following relevant service areas, including: consulting, facilitation; survey development; training; and program integration and project management. Proficient in the use of relevant analytical, methodological, and management tools needed to organize, perform and deliver the services being provided, such as comment and coding databases, research methods and models, statistical analysis software packages, instructional system design methodologies, or evaluation methodologies. Experience Level: 10 years of relevant work experience in business administration, public policy, economics, political science, communications, planning, statistics, technology and policy. Master's Degree in business administration, public policy, economics, political science, communications, planning, statistics, technology and policy, or related discipline. Consultant Duties: Experience includes working on project teams to provide services in one or more relevant service areas, including: consulting services, facilitation services; survey services; training services; and program integration and project management services. With direction from project leaders, capable of using relevant analytical, methodological, and management tools needed to organize, perform and deliver the services being provided, such as comment and coding methods and models, statistical analysis software packages, or evaluation methodologies. Experience Level: Six years of relevant work experience in business administration, public policy , economics, political science, communications, planning, statistics, technology and policy. Bachelor's degree in business, public policy, economics, political science, communications, planning , technology and policy, math, statistics, engineering, physical science, or related discipline. Senior Analyst Technical Writer Duties: Position requires effective task participation and good writing and communication skills. Incumbents in this position begin working under close supervision and, over time, function with greater independence. Prepares draft sections of deliverables and proposals. Incorporates review comments into final deliverables. Coordinates progress with other work team members. Incumbent performs data collection (survey work, library research, computer research) and may perform computer programming and analysis. Experience Level: 8 years of relevant work experience in one or more of the following service areas: business administration, public policy, economics, political science, communications, planning, statistics, technology and policy. Bachelor's Degree in business administration, public policy, economics, political science, communications, planning, statistics, technology and policy, or related discipline. Junior Consultant/Analyst Duties: Experience includes working on project teams to provide services in one or more relevant service areas, including: consulting services, facilitation services; survey services; training services; and program integration and project management services. Under direction from project leaders, capable of assisting in the use of relevant analytical, methodological, and management tools needed to organize, perform and deliver the services being provided, such as comment and coding methods and models, statistical analysis software packages, or evaluation methodologies. Experience Level: Two years of relevant work experience in business, public policy, economics, political science, communications, planning, statistics, technology and policy. Bachelor's degree in business, public policy, economics, political science, communications, planning , technology and policy, math, statistics, engineering, physical science, or related discipline. Trainer/ Training Specialist Duties: As a junior staff person, this position has limited fulltime work experience, which may include working on project teams to provide relevant services. With close supervision from project leaders, capable of assisting in data collection, analysis and writing. Experience Level: One year of relevant work experience in business, public policy, economics, political science, communications, planning, statistics, technology and policy. Bachelor's degree in business, public policy, economics, political science, communications, planning, technology and policy, math, statistics, engineering, physical science, or related discipline. Administrative Support Duties: This position requires general experience and capabilities supporting project teams. Incumbent is capable of working with close supervision to provide support for: typing, copying, meeting scheduling, and similar related activities. With close supervision from project leaders, performs a variety of tasks, including typing, copying, meeting scheduling, and related activities in support of a project. Experience Level: Two years of relevant work experience in business, public policy, economics, political science, communications, planning, technology and policy, math, statistics, engineering, physical science, or related discipline. High School Diploma PERIOD OF PERFORMANCE The period of performance tor this BPA will be Five years (60 months) from the date of the BPA award. PLACE OF PERFORMANCE Work shall be performed at the contractor's site with meetings held at the U.S. Department of Labor Frances Perkins Building (FPB) in Washington, DC if requested by COR and program office. DELIVERABLES AND REPORTS Deliverables and reports will be determined on task order by task order basis. Deliverables are identified in Section “TASKS” and may also include: NPRM draft sections; Issue outlines; Excerpts by issue reports; Executive summary reports of comments; Economic analyses; Cost-benefit analyses; Final Rule draft sections, as needed; PRA supporting statement and other materials, as needed; and Other deliverables - as determined in the task orders. Progress Reports. In addition, the contractor shall provide brief written monthly updates on contract activities and shall hold quarterly production meetings with DOL as needed to discuss progress, issues, and effective strategies. Status Reports. Monthly Status Reports must be submitted no later than 15 days following the end of the reporting period. The reports shall include all activities conducted during the reporting period, activities planned for the next reporting period, brief financial update, and any anticipated problems or obstacles encountered. The reports may be provided via email to the COR. ACCEPTANCE OF DELIVERABLES The Government will accept or reject the deliverable by giving written notice. In the event of rejection of any deliverable, the COR, giving the specific reason(s) for the rejection shall notify the Contractor in writing within five working days of receipt of deliverable. The Contractor shall correct the rejected deliverable and return it to the COR within five working days, or a number of days specified in the written notice by the COR. DISPOSITION OF MATERIAL Upon termination or completion of all work under this BPA, the Contractor shall prepare tor shipment, deliver FOB destination, or dispose of all materials received from the Government and all residual materials produced in connection with the performance of this BPA as may be directed by Contracting Officer, or as specified in other provisions of this BPA . All materials produced or required to be delivered under this BPA become and remain the property of the Government. PRINTING (1) The contractor shall not engage in, nor subcontract for, any printing in connection with the performance of work under this Blanket Purchase Agreement. The intent of this and other printing limitations is to eliminate duplication of final documents. The contractor may perform a requirement involving the duplication of less than 5,000 copies of only one page, or less than 25,000 copies of multiple pages in the aggregate, using one color (black). Such pages shall not exceed the maximum image size of I 0-3/4 by 14-1/4 inches, or II by 17 paper stock. Duplication services below these thresholds are not considered printing . If performance of the task order will require duplication in excess of these limits, the contractor must immediately notify the contracting officer. The contracting officer will provide instructions to the contractor. The contractor may perform a requirement involving the multi-color duplication of no more than I 00 pages in the aggregate using color copier technology Such pages shall not exceed the maximum image size of I 0-3/4 by 14-1/4 inches, or 11 by 17 paper stock. Duplication services below these thresholds are not considered printing . If performance of the contract will require duplication in excess of these limits, the contractor must immediately notify the contracting officer. The contracting officer will provide instructions to the contractor. The contractor may perform the duplication of no more than a total of 100 diskettes or CO-ROM's. Duplication services below these thresholds are not considered printing. If performance of the contract will require duplication in excess of these thresholds, the contractor must immediately notify the contracting officer. The contracting officer will provide instructions to the contractor . AWARD TYPE This is a BPA, under which labor hour, firm fixed price and time and materials task orders will be issued. TRAVEL The Government will not provide travel reimbursement to the Contractor for employees performing their primary duties on-site at DOL facilities. PUBLICATION OF MATERIALS The Contractor may not publish any works prepared under this Blanket Purchase Agreement without prior written approval of the Contracting Officer. However, if the Contractor has requested such approval but has not received a response from the Contracting Officer within nine months after final submission of the report to the Department of Labor, then the Contractor may publish their findings with the disclaimer included below. A final submission is a document that addresses or remedies all internal or ETA-initiated peer review recommendations or comments. Further, in any publication, the Contractor shall acknowledge the support of the Department of Labor with the following statement: "This project has been funded, either wholly or in part, with Federal funds from the Department of Labor, Employment & Training Administration under Task Order Number TBD the contents of this publication do not necessarily reflect the views or policies of the Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement of same by the U.S. Government." Where the contract requires the submission of memos and reports or related materials, in addition to printed (hard) copies, digital copies are required to facilitate the retention of electronic copies of these reports for future use, allow for website posting, and meet requirements of section 508 of the Rehabilitation Act to provide accessibility to people with disabilities. Unless the COR specifies differently, two digital copies of any report over 25 pages shall be delivered in media readable by Windows-based programs. Specifically, two copies should be delivered: one copy shall be formatted in Microsoft Word and the second shall be in the Portable Document Format (PDF). Do not submit reports in HTM L. In order to meet section 508 accessibility requirements, the Contractor shall provide summary narrative text description or a data table describing each complex graphic (e.g., pie graphs, line graphs, maps, bar graphs, flow charts) in a separate Word/Excel document. Label each figure or graphic with a title and corresponding page number. Additional information about accessibility standards related to section 508 may be found at http:// \\ ww.wcbaim.org/standards/508/chcckli st. The document provides the actual standard along with the most widely accepted interpretation for each standard ofthe Section 508 Web Guidelines. TASK ORDERS The BPA holder shall furnish all the necessary qualified personnel, materials, facilities and management resources to furnish the services set forth in the Statement of Work (SOW) within the terms specified and at the labor rates. It is understood and agreed that the BPA holder shall provide Time and Materials, Labor Hour and Firm fixed price proposals when requested by the Contracting Officer (CO). The contractor's proposal shall be priced using labor rates and labor categories herein provided. Notwithstanding any other provision, the BPA holder shall maintain sufficient accounting records for verification of the hours and categories of labor incurred in the performance of each order (when applicable). It is further understood and agreed that the accounting records shall be available for Government review during the performance of the contract and until three years after final payment under the contract. In the event subcontract labor is included in the labor effort contained in paragraph (c) above, the foregoing records provisions shall be included in all applicable subcontracts. In the case of Time and Materials and Labor Hour Task Orders, payment under individual orders for CLINs (to be specified in order) will be in accordance with FAR 52.232-7 entitled "Payments under Time-and-Materials and Labor-Hour Contracts." Withholding of amounts due as contemplated by the clause will apply to the total contract and not to individual orders. Withholding will not exceed $50,000.00 for the entire contract, regardless of the number of orders issued against the contract, and will apply to the first order and continue until the maximum withholding amount is reached. To facilitate closeout of early orders, the amount withheld may be transferred to any subsequent active order. Ceiling price, as used in the clause, applies to each individual order, not to the total contract. NONPERSONAL SERVICES The services required under the Agreement may include professional and management services within the definition provided by FAR, Part 37. The Government will neither supervise Blanket Purchase Agreement holder employees nor control the method by which the BPA holder performs the required tasks. Under no circumstances shall the Government assign tasks to, or prepare work schedules for, individual Blanket Purchase Agreement holder employees. It shall be the responsibility of the Blanket Purchase Agreement holder to manage their employees and to guard against any actions that are of the nature of personal services, or give the perception of personal services. If the Blanket Purchase Agreement holder feels that any actions constitute, or are perceived to constitute personal services, it shall be the Blanket Purchase Agreement holder's further responsibility to notify the Contracting Officer immediately. These services shall not be used to perform work of a policy/ decision making or management nature. All decisions relative to programs supported by Blanket Purchase Agreement holders will be the sole responsibility of the Government. Support services will not be ordered to circumvent personnel ceilings, pay limitations, or competitive employment procedures. TERM OF BPA This Blanket Purchase Agreement may not exceed Five Years (60 months) from date of award. There are four option years in this Blanket Purchase Agreement. The Blanket Purchase Agreements are not contracts. If the Blanket Purchase Agreement holder fails to perform in a manner satisfactory to the U.S. DEPARTMENT OF LA BOR {DOL) Contracting Officer, this Blanket Purchase Agreement may be canceled with fifteen (15) days written notice to the Blanket Purchase Agreement holder by the U.S. DEPARTMENT OF LABOR {DOL) Contracting Officer. OBLIGATION OF FUNDS This Blanket Purchase Agreement does not obligate any funds. The Government is obligated only to the extent of authorized task orders actually issued under the Blanket Purchase Agreement by the Contracting Officer. AUTHORIZED USERS Government Contracting Officers representing U.S. DEPARTMENT OF LABOR (DOL) are the only users authorized to place orders under this Blanket Purchase Agreement. Any authorized user shall only be allowed to issue an order under this Blanket Purchase Agreement if funds are certified and the Blanket Purchase Agreement awarding office's Task Order number is assigned. Blanket Purchase Agreement holders shall not accept or perform any purported order that does not contain a Task Order number.