In the proposed priority for establishing a Rehabilitation Research and Training Center (RRTC) on Community Living Policy at section (f) (ii) ‘Types of Priorities’ are discussed. It is unclear in this section if the three priority types (Absolute, Competitive or Invitational) apply to establishing the RRTC on Community Living Policy, specific services or products in support of the outlined goals or both. I hope it applies to both. In addition, I recommend that the invitations for competitive applications incorporate performance-based acquisition principles outlined in the May 22, 2007, Office of Management and Budget Memorandum for Chief Acquisition Officers and Senior Procurement Executives, Using Performance-Based Acquisition to Meet Program Needs – Performance Goals, Guidance, and Training. The memorandum provides links to guides and tools to assist in developing a performance-based statement of work and resulting contract. The scope of what is proposed in establishing a RRTC to engage in research, statistical analyses and modeling, knowledge translation, development of informational products, and dissemination to contribute to increased access to, and improved quality of, long-term services and supports for individuals with disabilities lends itself to the performance-based approach to encourage innovation and competitive pricing in the arena of Community Living Policy. The intent of performance-based contracting is to provide flexibility for innovative solutions. This is especially beneficial when looking to generate new knowledge and services to support individuals with disabilities. This approach allows the flexibility for innovation because it focuses on a description of needs in terms of what is to be achieved and not how it is done. Writing a proposed contract from the view of desired outcomes does take longer to develop but the increased flexibility and controls on products is well worth the effort.
Comment on FR Doc # 2013-11430
This is comment on Proposed Rule
Proposed Priorities: Rehabilitation Research and Training Center Program
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Public Submission Posted: 06/20/2013 ID: ED-2013-OSERS-0070-0002
Jun 14,2013 11:59 PM ET