The Federal Activities Inventory Reform (FAIR) Act of 1998 requires executive agencies to conduct an annual inventory of the commercial activities performed by federal employees and submit the report to the Office of Management and Budget (OMB). The circular also requires agencies to report their inherently governmental activities being performed by federal employees. This report is referred to as the "Inherently Governmental and Commercial Activities (IGCA)" Inventory. Since we are part of the Department of Defense (DoD), CSPO submits the report directly to the Office of Secretary of Defense (OSD) for review and consolidation with other DoD activities and military departments. OSD submits the annual report to OMB for review on behalf of the DoD. After OMB reviews and approves the agency's inherently governmental and commercial activities inventories, the agency is required to post the results on its public web site. The inventory reflects full-time equivalent (FTE) levels of effort, which is not the same thing as positions. An FTE is a manpower measure used within the Department of Defense to represent a year's worth of employee effort that equals 1,776 productive work hours, excluding holidays and leave.
An inherently governmental activity is an activity that is so intimately related to the public interest as to mandate performance by government personnel. These activities require the exercise of substantial discretion in applying government authority and/or in making decisions for the government. Inherently governmental activities normally fall into two categories: (1) the exercise of sovereign government authority or (2) the establishment of procedures and processes related to the oversight of monetary transactions or entitlements. A commercial activity is a recurring service that could be performed by the private sector, because it is not so intimately related to public interest to mandate performance by governmental personnel.