Companies Can Challenge ‘Insourcing’ Decisions, Judge Rules
By Leah Nylen
May 9 (Bloomberg) -- Government vendors can challenge a federal agency’s decision to have
government employees perform work previously handled by contractors, a policy known as
insourcing, a judge ruled.
Judge Nancy B. Firestone of the U.S. Court of Federal Claims in Washington rejected the
Justice Department’s argument that decisions to insource jobs are matters of agency policy and
not subject to court review.
“Where a protester stands to lose future work for which it likely would have competed
because of” alleged errors in the review process, “the protester should have standing to challenge
the decision to insource,” Firestone said in a ruling unsealed on May 4.
The case is one of at least 11 lawsuits challenging the Obama administration’s insourcing
efforts and filed in federal courts in the last 18 months, according to the Justice Department. The
Pentagon has hired about 3,000 people through insourcing, procurement director Shay Assad
said in March.
President Barack Obama has said the government should take back more tasks that have been
outsourced to private companies, a practice that had been increasing for 30 years.
“This is a very important decision,” Jacob Pankowski, chair of the government contracts
practice group at Greenberg Traurig LLP in Washington, said in an interview. “The Court of
Federal Claims has taken jurisdiction over insourcing decisions and has declared that interested
parties have standing.”
That means “companies do have a venue to challenge government insourcing decisions,” he
said.
Support Services
Santa Barbara Applied Research, based in Ventura, California, sued the Air Force in the
Court of Federal Claims in February, arguing that a decision to insource a $99 million contract
for support services at eight bases was unfair.
Congress passed a law in 2008 requiring the Pentagon to implement guidelines on how to
determine whether to use civilian employees or contractors. Defense Department officials issued
guidance in May 2009 instructing agencies to consider converting existing contracts to jobs for
civilian personnel in cases where a cost analysis showed such a move would save money.
The Air Force notified Santa Barbara Applied Research in June that it would be insourcing
work under its contract. Lawyers for the company argued in court papers that the Air Force
incorrectly calculated the cost savings from the switch.
While ruling that Santa Barbara Applied Research has the right to sue, Firestone rejected the
company’s arguments in the case, finding that the Air Force’s analysis of the cost savings was
reasonable because the agency followed the Defense Department’s guidelines on insourcing.
Paul Khoury, a partner at Wiley Rein LLP in Washington who represented Santa Barbara
Applied Research, declined to comment.
‘True Cost’
In the decision, Firestone said it was reasonable for the agency to consider only costs to the
Department of Defense rather than the federal government as a whole.
“If that stays the policy, none of the insourcing projects will accurately reflect the true cost to
the government,” said Edward Kinberg an attorney with Kinberg & Associates LLC in
Melbourne, Florida, who is representing a company in another insourcing case.
“It overstates the amount of savings from insourcing and creates the impression that more
money is being saved than is actually being saved or that there are savings where in fact there are
none,” he said in an interview.
Daniel I. Gordon, administrator for federal procurement policy at the White House Office of
Management and Budget, is drafting regulations that may define the functions that only federal
employees may perform. Final rules haven’t been issued.
Small businesses are being hurt by insourcing, according to Robert A. Burton, a partner at the
Washington law firm Venable LLP and a former federal procurement policy official.
“In my 30-year career, I have not really seen an initiative like this whereby the government is
proactively hurting small business,” Burton said in an interview. “I think it’s very easy to argue
there’s a public policy problem.”
The case is Santa Barbara Applied Research Inc. V. U.S., 11-cv-86, U.S. Court of Federal
Claims (Washington).
© 2011 BLOOMBERG L.P. All Rights Reserved
Tuesday, May 24, 2011
Reprint of Inside Defense Article
DoD 'Inadequately Prepared' To Execute Services Contracts, a $200 Billion Activity
By Jason Sherman, Inside Defense, May 9, 2011
The Defense Department is "inadequately prepared to acquire and execute" contracts for services, a
bundle of business that accounts for more than 50 percent of the Pentagon's $400 billion procurement
budget, according to an influential DOD advisory panel.
A Defense Science Board task force, in a new report, recommends "urgent" action to remedy what it calls
a severe imbalance between the acquisition regulations, laws, policies, standards, training, education and
management structures for weapon systems and the institutional capacities needed for efficient and
effective purchase of services.
"Major change is needed to enable DOD to acquire and use services far more effectively and efficiently,"
the Defense Science Board Task Force on Improving Services Contracting concludes in a 67-page
report. While current acquisition regulations empower the defense secretary to implement many changes
recommended by the task force, new legislation "would be extremely valuable "to demonstrate
congressional support" for a new services acquisition system, the report states.
The Pentagon's substantial reliance on services acquisition contracts are a result of two trends, according
to the task force: the personnel drawdowns of the 1990s and the intense demands of combat operations
in Afghanistan and Iraq.
"In past decades, enlisted personnel cut grass, peeled potatoes and carried out most defense services,"
the report states. "Today, with a smaller all-volunteer force, many of these services are contracted out.
This systemic change means the system must also change."
Jacques Gansler, a University of Maryland professor and the Pentagon's acquisition executive from
November 1997 to January 2001, chaired the task force.
Under the Pentagon's inventory of services contracting, the military in FY-09 spent $53.1 billion on
"knowledge-based" services, the report says, along with $41.4 billion on research and development;
$30.4 billion on facility-related services; $29.2 billion on construction; $19.6 billion on electronics and
communications; $14.2 billion on medical services; and $6.3 billion on transportation.
The Pentagon's system for categorizing its services contracts lacks fidelity and -- because definitions and
standards are broadly framed in current policy -- "inappropriately" group activities as diverse as routine
training and education projects with expeditionary logistics management contracts, according to the task
force.
Such arrangements limit the ability of senior acquisition managers to analyze service-contract spending
and draw meaningful performance insights, states the report.
Neither the Federal Procurement Data System nor the Pentagon's classification system for categorizing
defense services "are sufficient to guide policy for the entire array of service contracts," states the report,
which calls for the Defense Department to establish a "meaningful taxonomy" to track services
contracting.
"It is important to note that 'one size does not fit all' and that some types of services will need different
policies and guidance than others," the report states.
The task force began its work on Dec. 4, 2009, in response to a requirement in the fiscal year 2010
Defense Authorization Act requiring an independent assessment of DOD's services procurement
enterprise.
Defense Secretary Robert Gates in February 2010 asked the task force --whose vice chairmen were
retired Army general Paul Kern and Phil Odeen, a consultant and former defense industry executive -- to
also consider what services should be contracted to private firms and which should be performed by the
government.
To that end, the task force recommends "new and more detailed guidance is needed that clarifies the
inherently governmental functions that should always be performed by government personnel."
"The workforce is inadequately prepared to acquire and execute services contracts," Gansler bluntly
states in a March 29 cover letter accompanying the report. New "guidance, training and experience are
needed," it adds. The
report notes that senior Pentagon acquisition leadership "currently gives little attention to services, and
almost all senior officers need training in this area."
The task force also recommends a number of actions to strengthen the skills and capabilities of the entire
workforce involved in services contracting.
Lastly, to support wartime operations, the task force recommends DOD establish separate policies and
processes to "improve management and oversight of contingency contracting." These steps include
creating "a single playbook" that contains "all relevant acquisition information" for use "in time-critical
situations"; delegating limited contracting authority to enable nimble response; and including service
contracting during training and military exercises. In addition, the report calls for contingency contracts to
be identified "as a separate element in the procurement tracking system."
The report notes that the Defense Department "has already stepped out to address" many of the issues
raised by the task force. The military services, for example, have appointed executives to focus on
services contracting.
And the office of defense procurement and acquisition policy in the Office of the Secretary of Defense has
drafted a "Roadmap for the Acquisition of Services" and begun management reviews of the acquisition of
services.
"These are very positive steps," the report notes.
© 1999-2011. Inside Washington Publishers
By Jason Sherman, Inside Defense, May 9, 2011
The Defense Department is "inadequately prepared to acquire and execute" contracts for services, a
bundle of business that accounts for more than 50 percent of the Pentagon's $400 billion procurement
budget, according to an influential DOD advisory panel.
A Defense Science Board task force, in a new report, recommends "urgent" action to remedy what it calls
a severe imbalance between the acquisition regulations, laws, policies, standards, training, education and
management structures for weapon systems and the institutional capacities needed for efficient and
effective purchase of services.
"Major change is needed to enable DOD to acquire and use services far more effectively and efficiently,"
the Defense Science Board Task Force on Improving Services Contracting concludes in a 67-page
report. While current acquisition regulations empower the defense secretary to implement many changes
recommended by the task force, new legislation "would be extremely valuable "to demonstrate
congressional support" for a new services acquisition system, the report states.
The Pentagon's substantial reliance on services acquisition contracts are a result of two trends, according
to the task force: the personnel drawdowns of the 1990s and the intense demands of combat operations
in Afghanistan and Iraq.
"In past decades, enlisted personnel cut grass, peeled potatoes and carried out most defense services,"
the report states. "Today, with a smaller all-volunteer force, many of these services are contracted out.
This systemic change means the system must also change."
Jacques Gansler, a University of Maryland professor and the Pentagon's acquisition executive from
November 1997 to January 2001, chaired the task force.
Under the Pentagon's inventory of services contracting, the military in FY-09 spent $53.1 billion on
"knowledge-based" services, the report says, along with $41.4 billion on research and development;
$30.4 billion on facility-related services; $29.2 billion on construction; $19.6 billion on electronics and
communications; $14.2 billion on medical services; and $6.3 billion on transportation.
The Pentagon's system for categorizing its services contracts lacks fidelity and -- because definitions and
standards are broadly framed in current policy -- "inappropriately" group activities as diverse as routine
training and education projects with expeditionary logistics management contracts, according to the task
force.
Such arrangements limit the ability of senior acquisition managers to analyze service-contract spending
and draw meaningful performance insights, states the report.
Neither the Federal Procurement Data System nor the Pentagon's classification system for categorizing
defense services "are sufficient to guide policy for the entire array of service contracts," states the report,
which calls for the Defense Department to establish a "meaningful taxonomy" to track services
contracting.
"It is important to note that 'one size does not fit all' and that some types of services will need different
policies and guidance than others," the report states.
The task force began its work on Dec. 4, 2009, in response to a requirement in the fiscal year 2010
Defense Authorization Act requiring an independent assessment of DOD's services procurement
enterprise.
Defense Secretary Robert Gates in February 2010 asked the task force --whose vice chairmen were
retired Army general Paul Kern and Phil Odeen, a consultant and former defense industry executive -- to
also consider what services should be contracted to private firms and which should be performed by the
government.
To that end, the task force recommends "new and more detailed guidance is needed that clarifies the
inherently governmental functions that should always be performed by government personnel."
"The workforce is inadequately prepared to acquire and execute services contracts," Gansler bluntly
states in a March 29 cover letter accompanying the report. New "guidance, training and experience are
needed," it adds. The
report notes that senior Pentagon acquisition leadership "currently gives little attention to services, and
almost all senior officers need training in this area."
The task force also recommends a number of actions to strengthen the skills and capabilities of the entire
workforce involved in services contracting.
Lastly, to support wartime operations, the task force recommends DOD establish separate policies and
processes to "improve management and oversight of contingency contracting." These steps include
creating "a single playbook" that contains "all relevant acquisition information" for use "in time-critical
situations"; delegating limited contracting authority to enable nimble response; and including service
contracting during training and military exercises. In addition, the report calls for contingency contracts to
be identified "as a separate element in the procurement tracking system."
The report notes that the Defense Department "has already stepped out to address" many of the issues
raised by the task force. The military services, for example, have appointed executives to focus on
services contracting.
And the office of defense procurement and acquisition policy in the Office of the Secretary of Defense has
drafted a "Roadmap for the Acquisition of Services" and begun management reviews of the acquisition of
services.
"These are very positive steps," the report notes.
© 1999-2011. Inside Washington Publishers
Reprint Of Insourcing Article
House Panel Proposes Adding Experts to Competitive Sourcing
Personnel and readiness undersecretary would get preliminary planning responsibilities
By Matthew Weigelt May 10, 2011
House Armed Services Committee Chairman Rep. Bob McKeon (R-Calif.) has proposed that a broader
segment of senior Defense Department officials get involved in the competitive sourcing process that pits
the private sector against the public sector for federal government work.
McKeon wants to give the undersecretary of defense for personnel and readiness the responsibility to
issue guidance and procedures for preliminary planning for competitions between contractors and
federal employees, according to a committee document released May 9 with descriptions of
provisions in the forthcoming fiscal 2012 National Defense Authorization Act. The exact language has
not been released.
“The committee believes that preliminary planning for public-private competitions should include an
increased and more active role for the manpower and personnel communities, which have greater
expertise in determining manpower requirements, whether military, civilian, or contractor personnel,” the
report states.
The undersecretary of defense for acquisition, technology, and logistics is now responsible for all
elements of public-private competitions, which are under the Office of Management and Budget Circular
A-76.
The undersecretary of defense for acquisition, technology, and logistics still would conduct the
acquisition component of the process because the necessary procurement expertise.
In more proposed changes, the committee would like to have the undersecretary for acquisition realign
the responsibility for the competitions from the deputy undersecretary for installations and environment
to the director of defense for procurement and acquisition policy.
Meanwhile, it’s early in the process for making the authorization bill law. The Armed Services
Committee has yet to approve the bill, and the Senate has not released its version of the measure.
© 1996-2011 1105 Media, Inc. All Rights Reserved.
Personnel and readiness undersecretary would get preliminary planning responsibilities
By Matthew Weigelt May 10, 2011
House Armed Services Committee Chairman Rep. Bob McKeon (R-Calif.) has proposed that a broader
segment of senior Defense Department officials get involved in the competitive sourcing process that pits
the private sector against the public sector for federal government work.
McKeon wants to give the undersecretary of defense for personnel and readiness the responsibility to
issue guidance and procedures for preliminary planning for competitions between contractors and
federal employees, according to a committee document released May 9 with descriptions of
provisions in the forthcoming fiscal 2012 National Defense Authorization Act. The exact language has
not been released.
“The committee believes that preliminary planning for public-private competitions should include an
increased and more active role for the manpower and personnel communities, which have greater
expertise in determining manpower requirements, whether military, civilian, or contractor personnel,” the
report states.
The undersecretary of defense for acquisition, technology, and logistics is now responsible for all
elements of public-private competitions, which are under the Office of Management and Budget Circular
A-76.
The undersecretary of defense for acquisition, technology, and logistics still would conduct the
acquisition component of the process because the necessary procurement expertise.
In more proposed changes, the committee would like to have the undersecretary for acquisition realign
the responsibility for the competitions from the deputy undersecretary for installations and environment
to the director of defense for procurement and acquisition policy.
Meanwhile, it’s early in the process for making the authorization bill law. The Armed Services
Committee has yet to approve the bill, and the Senate has not released its version of the measure.
© 1996-2011 1105 Media, Inc. All Rights Reserved.
Reprint of Defense Industry Report
DoD Needs Better Methodology For Making Insourcing Decisions
By Marina Malenic May 18, 2011
The Defense Department’s method for estimating the costs of contractors versus full-time
government employees for use in making effective insourcing decisions is flawed, according to a
nonpartisan Washington, D.C., think tank.
The Center for Strategic and International Studies released a report yesterday that analyzed a
directive issued earlier this year by which the Pentagon estimates and compares the costs of
contractors versus government personnel. Among the key shortcomings to the current
methodology--slated to be replaced by a new system in September--is the inability to fully
account for associated overhead.
For example, the current system does not factor the full cost of government-owned assets, while
at the same time including those costs for contractors. Also, the loss in tax revenue that would
otherwise be paid by contractors is not considered under the current regime.
“All of the critical elements of cost should be considered before making a decision about
insourcing,” CSIS Director David Berteau said during the report rollout in Washington.
“When goverment brings in an activity, it loses track of the true costs associated with it,” Bertau
added.
The report suggests that the department introduce a “statement of work” with defined
performance parameters as a common starting point for deciding whether a particular type of
work is better suited for contractors or government personnel. More frequent and accurate
personnel cost estimates should then be conducted in order to make more accurate comparisons.
The report also specifies that management and oversight, information technology and human
resources should be factored into any cost comparison for private versus public workers.
Still, Berteau acknowledged, the Pentagon’s civilian acquisition workforce has been
“devastated” over the course of the past decade.
“It needs to once again develop a robust, better educated work force,” he said. “Even if it costs
you more, we’re saying build up that work force.”
Copyright © 2011 Access Intelligence, LLC. All rights reserved.
By Marina Malenic May 18, 2011
The Defense Department’s method for estimating the costs of contractors versus full-time
government employees for use in making effective insourcing decisions is flawed, according to a
nonpartisan Washington, D.C., think tank.
The Center for Strategic and International Studies released a report yesterday that analyzed a
directive issued earlier this year by which the Pentagon estimates and compares the costs of
contractors versus government personnel. Among the key shortcomings to the current
methodology--slated to be replaced by a new system in September--is the inability to fully
account for associated overhead.
For example, the current system does not factor the full cost of government-owned assets, while
at the same time including those costs for contractors. Also, the loss in tax revenue that would
otherwise be paid by contractors is not considered under the current regime.
“All of the critical elements of cost should be considered before making a decision about
insourcing,” CSIS Director David Berteau said during the report rollout in Washington.
“When goverment brings in an activity, it loses track of the true costs associated with it,” Bertau
added.
The report suggests that the department introduce a “statement of work” with defined
performance parameters as a common starting point for deciding whether a particular type of
work is better suited for contractors or government personnel. More frequent and accurate
personnel cost estimates should then be conducted in order to make more accurate comparisons.
The report also specifies that management and oversight, information technology and human
resources should be factored into any cost comparison for private versus public workers.
Still, Berteau acknowledged, the Pentagon’s civilian acquisition workforce has been
“devastated” over the course of the past decade.
“It needs to once again develop a robust, better educated work force,” he said. “Even if it costs
you more, we’re saying build up that work force.”
Copyright © 2011 Access Intelligence, LLC. All rights reserved.
Reprint of CSIS report on DOD/ insourcing
CSIS Study Pounds Final Nail into Insourcing’s Coffin
Daniel Goure, Ph.D. Thursday, May 19, 2011
For the past two years the Department of Defense (DoD) has been pursuing a mirage. This
false vision is that the Pentagon can both save money and perform better by replacing a
significant fraction of its private contractor workforce with government employees. The
Secretary of Defense, Robert Gates, led the charge in 2009 by declaring that the department
would reduce its number of service support contractors by about 33,000, replacing them
over a five-year period with 39,000 new full-time government employees. This decision was
based, in large part, on the notion that DoD had become excessively dependent on
contractors -- some of whom, it was asserted, were performing functions that could be
deemed inherently governmental in character. But in addition, Secretary Gates claimed that
replacing contractors with government employees would produce an average savings of 40
percent (a number later reduced to 25 percent).
Within a relatively short time it became evident that the belief in the relative costeffectiveness
of public over private workers was indeed a mirage. In mid-2010, Secretary
Gates planted the first nail in insourcing’s coffin, declaring that "as we were reducing
contractors, we weren't seeing the savings we had hoped from insourcing." DoD suffered
from the mistaken belief that by simply swapping the fully burdened costs of private sector
contractors with less than fully burdened personnel costs for government employees that it
was saving money. But of course the government was paying those other costs, just from
different accounts. Moreover, as studies by the CATO Institute and Heritage Foundation
showed, the cost of federal employees, almost without exception, was higher than for private
sector workers.
The Secretary added a second nail to the coffin when he halted his effort to hire tens of
thousands of new federal employees in 2010 to find $100 billion in cost savings in the
defense budget. More nails have been added by Deputy Secretary Lynn and Under Secretary
Carter in their efforts to make the department more efficient. These officials have
rediscovered the profit motive and the sharing of cost savings as valuable incentives to
greater efficiency. Of course, the profit motive doesn’t apply when the work is performed by
government workers.
The military services began to provide nails of their own. In February, 2011 Army Secretary
McHugh sent out a memo that sharply curtailed his service’s insourcing activity. McHugh
reserves the right to personally approve any insourcing proposal across the Army. Any
proposals for further insourcing had to include careful study of alternatives to insourcing,
the number of civilian federal employees the proposal would require, proof that funds are
available to support those permanent civilian functions and a comprehensive legal review.
Similarly, a report of a meeting between defense officials and Pentagon reporters quoted
one official as saying, “The insourcing that hasn’t taken place by now probably will be held
to the fiscal year 2010 level. At least in the Air Force, insourcing pretty much is going to be
stopped.”
Now it appears that the final nail has been provided by a new study from the Center for
Strategic and International Studies. The study makes clear that DoD’s approach to making
comparisons between public and private sector work was fundamentally flawed. Ultimately,
the study suggested that there was no basis for DoD’s assertion that it could save money by
insourcing. The study makes the point that the private sector had been asserting for almost
two years, “If the true cost of the public performance of commercial services cannot be
determined, any budget-driven insourcing decision becomes immediately suspect.” It then
goes on to ask the proverbial $64,000 question: “How can DoD claim it is saving 40
percent, or 25 percent, or any amount via insourcing private sector positions when it does
not know how much the newly insourced function will cost?”
There is still work to be done to repair the damage caused by more than two years of
misplaced insourcing decisions. Beyond that, DoD needs to take a fresh look at how it
manages a defense industrial base that insists on a variety of public and private sector
entities with a wide range of capabilities. If efficiency is truly the name of the game, then for
example, DoD needs to reconsider its policy of requiring that the overall sustainment
workload be divided 50/50 between the two sectors. As part of the current comprehensive
Daniel Goure, Ph.D. Thursday, May 19, 2011
For the past two years the Department of Defense (DoD) has been pursuing a mirage. This
false vision is that the Pentagon can both save money and perform better by replacing a
significant fraction of its private contractor workforce with government employees. The
Secretary of Defense, Robert Gates, led the charge in 2009 by declaring that the department
would reduce its number of service support contractors by about 33,000, replacing them
over a five-year period with 39,000 new full-time government employees. This decision was
based, in large part, on the notion that DoD had become excessively dependent on
contractors -- some of whom, it was asserted, were performing functions that could be
deemed inherently governmental in character. But in addition, Secretary Gates claimed that
replacing contractors with government employees would produce an average savings of 40
percent (a number later reduced to 25 percent).
Within a relatively short time it became evident that the belief in the relative costeffectiveness
of public over private workers was indeed a mirage. In mid-2010, Secretary
Gates planted the first nail in insourcing’s coffin, declaring that "as we were reducing
contractors, we weren't seeing the savings we had hoped from insourcing." DoD suffered
from the mistaken belief that by simply swapping the fully burdened costs of private sector
contractors with less than fully burdened personnel costs for government employees that it
was saving money. But of course the government was paying those other costs, just from
different accounts. Moreover, as studies by the CATO Institute and Heritage Foundation
showed, the cost of federal employees, almost without exception, was higher than for private
sector workers.
The Secretary added a second nail to the coffin when he halted his effort to hire tens of
thousands of new federal employees in 2010 to find $100 billion in cost savings in the
defense budget. More nails have been added by Deputy Secretary Lynn and Under Secretary
Carter in their efforts to make the department more efficient. These officials have
rediscovered the profit motive and the sharing of cost savings as valuable incentives to
greater efficiency. Of course, the profit motive doesn’t apply when the work is performed by
government workers.
The military services began to provide nails of their own. In February, 2011 Army Secretary
McHugh sent out a memo that sharply curtailed his service’s insourcing activity. McHugh
reserves the right to personally approve any insourcing proposal across the Army. Any
proposals for further insourcing had to include careful study of alternatives to insourcing,
the number of civilian federal employees the proposal would require, proof that funds are
available to support those permanent civilian functions and a comprehensive legal review.
Similarly, a report of a meeting between defense officials and Pentagon reporters quoted
one official as saying, “The insourcing that hasn’t taken place by now probably will be held
to the fiscal year 2010 level. At least in the Air Force, insourcing pretty much is going to be
stopped.”
Now it appears that the final nail has been provided by a new study from the Center for
Strategic and International Studies. The study makes clear that DoD’s approach to making
comparisons between public and private sector work was fundamentally flawed. Ultimately,
the study suggested that there was no basis for DoD’s assertion that it could save money by
insourcing. The study makes the point that the private sector had been asserting for almost
two years, “If the true cost of the public performance of commercial services cannot be
determined, any budget-driven insourcing decision becomes immediately suspect.” It then
goes on to ask the proverbial $64,000 question: “How can DoD claim it is saving 40
percent, or 25 percent, or any amount via insourcing private sector positions when it does
not know how much the newly insourced function will cost?”
There is still work to be done to repair the damage caused by more than two years of
misplaced insourcing decisions. Beyond that, DoD needs to take a fresh look at how it
manages a defense industrial base that insists on a variety of public and private sector
entities with a wide range of capabilities. If efficiency is truly the name of the game, then for
example, DoD needs to reconsider its policy of requiring that the overall sustainment
workload be divided 50/50 between the two sectors. As part of the current comprehensive
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