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    The FAR covers A&A in both 37 and 2 but is silent on what is considered a consulting service. Is there any regulation that offers a clear definition between consulting services and A&A? If not, can you provide guidance on what turns a contract for consulting services into an A&A contract?


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    The FAR covers A&A in both 37 and 2 but is silent on what is considered a consulting service.  Is there any regulation that offers a clear definition between consulting services and A&A?  If not, can you provide guidance on what turns a contract for consulting services into an A&A contract?
     
    The short answer: Advisory and Assistance Services are in effect, Consulting Services.
     
    You are correct in your description that “Consulting Services” are not specifically defined as a separate or stand-alone entity within the FAR.  So, let’s begin by providing the following definitions for Consulting:
     
    1.  From the Cambridge dictionary:  “the activity or business of giving expert advice about a particular subject”
    2.  From Merriam-Webster:  “providing professional or expert advice
     
    And now, from FAR Part 2, the definition (in part) of Advisory and Assistance Services (A&AS):
    Advisory and assistance services” means those services provided under contract by nongovernmental sources to support or improve: Organizational policy development; decision-making; management and administration; program and/or project management and administration; or R&D activities. It can also mean the furnishing of professional advice or assistance rendered to improve the effectiveness of Federal management processes or procedures (including those of an engineering and technical nature). In rendering the foregoing services, outputs may take the form of information, advice, opinions, alternatives, analyses, evaluations, recommendations, training and the day-to-day aid of support personnel needed for the successful performance of ongoing Federal operations.

    So, from a definitional perspective, A&AS contracts are actually types of Consulting Services contracts.

    Concerning the second part of your question: “can you provide guidance on what turns a contract for consulting services into an A&A contract”:  as stated above, developing an A&AS requirement is in essence the creation of a Consulting Services requirement.  Further, I recommend that you review OMB Circular A-11, Section 83 for additional insight into the reporting requirements for and descriptions of A&AS.

    OMB Circular A-11 deals with the Preparation, submission and execution of the budget.
      Section 83 describes the “Object classes” by category in the classification system that presents obligations by the items or services purchased by the Federal Government.  Object class 25 involves “Other contractual Services” and contains Object Sub-class 25.1, Advisory and Assistance Services.  Of note, as you review OMB A-11, Section 83, the definitions and descriptors dealing with A&AS are very similar to what you will observe when reading FAR 2.1 and FAR 37.2. 
     
    You will also see various elements where OMB A-11 will make reference to “consulting” that equates back to A&AS.  For example, on page 23 of Section 83, Information Technology consulting services in the form of Management and professional support services, Studies, analyses, and evaluations or Engineering and technical services are to be classified as Advisory and Assistance services.


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