ALCOAST 115/20 - MAR 2020 CONTRACTOR SERVICE DELIVERY DURING COVID-19

united states coast guard

R 310912 MAR 20
FM COMDT COGARD WASHINGTON DC//CG-91//
TO ALCOAST
UNCLAS//N01500//
ALCOAST 115/20
COMDTNOTE 1500
SUBJ: CONTRACTOR SERVICE DELIVERY DURING COVID-19
A. Contractor Performance During an Emergency Event, "A Guide For Program Managers
and Contracting Officers, dated January, 2012
B. Memorandum on Identification of Essential Critical Infrastructure Workers During
COVID-19 Response, DHS CISA, dated March 19, 2020
C. How to Enable CGVPN Connection
1. This ALCOAST announces the way we address Contractor Support and Contract
Management during COVID-19.
2. Allowing Contractor Employees to telework.
First and foremost, contractor employees should be teleworking to the maximum
extent practicable, just like Federal employees, especially when the work is
normally performed at a Federal worksite. Equally important, we should be flexible
in providing extensions to performance dates if telework or other flexible work
solutions, such as virtual work environments, are not possible, or if a contractor
is unable to perform in a timely manner due to quarantining, social distancing, or
other COVID-19 related interruptions. Therefore, contrating offcier's (KOs) and
contracting offcier's representative (CORs) should discuss the existing scope of
work and terms and conditions of all active service contracts to determine the
following:
    a. whether the work is of a nature that can be performed remotely (teleworking);
    b. what new or additional provisions or resources (if any) are necessary for
contractor employees to telework and
    c. what contract modifications are needed to enact any changes to provide for
contractor employees to telework if the decision is made that the work can be
performed remotely.
KOs and CORs are required to consult with pertinent requirement owners (e.g.,
operators, logisticians, acquirers and sustainers) to partner and make these
decisions expeditiously. REF (A), CONTRACTOR PERFORMANCE DURING AN EMERGENCY EVENT,
should be used by KOs/CORs in crafting applicable modifications to allow contractor
employees to telework. While not all services lend themselves to telework, stop-work
orders should be considered as a last resort and all efforts to offer maximum
flexibilities to our industry partners should be explored. During the pandemic,
any stop-work orders that are contemplated must be reviewed by the Head of
Contracting Activity (HCA) or Deputy HCA after Chiefs of the Contracting Offices
(COCO) review prior to execution. Two options are available for network access – VPN
and VDI. REF (C) contains instructionson enabling a VPN connection. Contract language
should be included in the contract to allow for telework flexibilities. Telework
is not exclusively working through the Virtual Private Network (VPN) or Virtual
Desktop Infrastructure (VDI). It might be via Outlook Web Access to email; using
CGPortal to access needed information; or completely “offline” reading, writing, or
take-home hardcopy work. Teleworking “off the net” for part of the day is strongly
encouraged. Reminder that contractor employees must take the same telework training
as government employees to be telework ready;
3. Identifying Mission Essential/Critical Contracts.
When it is mission-critical that a service contract continue during the COVID-19
pandemic, requirements owners must deem essential and KOs and CORS must contractually
implement those decisions. CG Chiefs of Contracting Offices (COCOs) will discuss the
unique needs to determine if a contract is essential or critical. REF (B), issued by
the Director of the Cybersecurity and Infrastructure Agency(CISA) MEMORANDUM ON
IDENTIFICATION OF ESSENTIAL CRITICAL INFRASTRUCTURE WORKERS DURING COVID-19 RESPONSE,
will assist CG senior leaders and COCOs in making decisions about designating existing
contracts as essential or critical. This guidance helps to identify the types of
contracts/services that should be deemed essential or critical during emergency
situations such as the current pandemic and includes language that can be leveraged.
4. Impact on Delivery of Service Contracts.
In this tumultuous environment, we realize there are many questions about the CG’s
ability to impose full service delivery. It is important to realize that contractors
must comply with federal and state laws in conjunction with guidance and direction
provided across all levels of government. The CG is taking steps to help ensure
workforce safety while maintaining continued contract performance in support of
agency missions, wherever possible and consistent with the precautions issued by the
Centers for Disease Control and Prevention (CDC). Achieving these important goals
and maintaining the resilience of our contracting base requires continued
communication between KOs, CORs, and contractors, and effectively leveraging
flexibilities and authorities to help minimize work disruption.
5. Points of contact:
    a. COR's and KO's can send questions to the CORServices@uscg.mil or
CG913Policy@uscg.mil email boxes.
6. Mr. M. Derrios, Senior Procurement Executive & Head of Contracting Activity (HCA), sends.
7. Internet release is authorized.