Purpose
- This order establishes minimum requirements for the Office of the General Counsel (OGC) review of agency actions.
- OGC may establish supplemental appendices to provide further guidance for different organizations where necessary. Supplemental appendices may be used to specify additional actions or thresholds for legal services, but may not limit or reduce thresholds as provided in Appendix A to this Order.
Background
OGC, as defined in this Order, is the sole and exclusive authorized provider of legal services, review, and advice to agency personnel in the course of agency operations, except for the Office of Inspector General (OIG) and as designated by the General Counsel or otherwise provided by statute. Agency officials may rely upon the advice of counsel on legal issues, but are responsible for other aspects of decisions, including the exercise of sound business and policy judgment.
Applicability
This Order applies to all GSA employees as they perform their duties, with the exception of the Office of Inspector General (OIG), given its independence under the Inspector General Reform Act of 2008 (5 U.S.C. §§ 401-424).
Cancellation
GSA Order ADM 5000.4B, November 14, 2014, is canceled.
Summary of Changes
Updated Order includes several editorial and substantive changes. Major substantive changes include:
- Removes references to regional divisions.
- Makes the Order applicable to the Civilian Board of Contract Appeals.
- Authorizes only the General Counsel to waive the requirements under this Order.
- Removes most FAR citations.
- Requires legal review of several new categories of matters.
- Changes dollar threshold in many categories.
- Changes the standard to review contract modifications and removes the dollar threshold.
- Specifies types of contract modifications that are not subject to review.
Roles and Responsibilities
All OGC employees and employees in the Services and Staff Offices (SSOs) are responsible for executing and complying with the requirements of this Order.