Intergovernmental Support Agreements

About Intergovernmental Support Agreements

The National Defense Authorization Act of 2013 (NDAA), as amended in 2015, authorizes the U.S. Department of Defense to enter into Intergovernmental Support Agreements (IGSAs). Section 331 of the NDAA established legislation for all military services to enter into public-public partnerships for installation support services, excluding security guard and firefighting functions. The law provides that services may be sole sourced to state and local governments that do not require the use of the Federal Acquisition Regulations (FAR).

How IGSA Impacts AbilityOne

The original intent of IGSAs was to utilize the excess capabilities of pre-existing services provided by local governments. DOD’s strategic use of IGSAs to achieve cost reductions goes beyond the intent of the statute and has negatively impacted the AbilityOne Program.

Here is an example of how IGSAs may be used in a way that negatively affects AbilityOne:

Because IGSAs are not FAR-based contracts, the DOD can avoid using the AbilityOne Program and paying federal wage rates for services set by the Service Contract Act (SCA), and instead use lower wage grades paid by the state or local government. (Service contracts awarded through the AbilityOne Program are subject to the SCA and federal wage determination.) As a result, excessive use of IGSAs as a cost-avoidance mechanism threatens job opportunities for people with disabilities.

SourceAmerica's Response to IGSA

To address the threat that the current IGSA policy poses to NPAs in the SourceAmerica network, SouceAmerica's Government Affairs team has developed an advocacy strategy to educate Congress on the challenges that IGSAs pose to the AbilityOne Program. SourceAmerica’s Government Affairs team has drafted legislative language to protect the AbilityOne Program from being circumvented by IGSAs and prevent future erosion of the Program by the DOD's current use of IGSAs. NPAs must be proactive and notify their SourceAmerica account manager if they are aware of any IGSA action that threatens the AbilityOne Program and may result in job loss for people with disabilities.