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Consolidated FAR/DFARS/DFARS PGI/DoD Class Deviations

Don Mansfield

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I'm looking for feedback on a tool that I'm creating for DoD. Basically, it would be a single document that would contain the FAR, DFARS, DFARS PGI, and DoD Class Deviations. The concept is similar to that used in the General Services Administration Acquisition Manual (GSAM), where both regulatory (GSAR) and nonregulatory information is integrated into one document and distinguished by shading. The main difference is the document that I envision also contains the FAR. I've attached a sample of what an integrated FAR subpart 1.1, DFARS subpart 201.1, and DFARS PGI subpart 201.1 would look like. Take a look and let me know what you think. I'd appreciate any feedback, but I'm particularly interested in the following:

1. Would you use such a tool?

2. Is there a better way to distinguish between FAR, DFARS, and DFARS PGI text than the use of shading?

3. Do you have any ideas to make the tool better (more useful)?

Consolidated FAR, DFARS, DFARS PGI, DoD Class Deviations.docx



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I applaud your effort, but wow!

If a tool was offered to me, I would want it to be an electronic tool, not a Word .docx document.

I would not use it unless I trusted it.  How can anyone trust that the document is up-to-date?

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I envision the document in both PDF and HTML formats. I would just use Word to create it.

As far as knowing if it were up to date, I envision an identifier like this:

Current through 26 February 2016

FAC 2005-86

DPN 20160226

CD 2016-O0006

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I still see it as a lot of work, and I am having a hard time seeing the utility of the effort.  But that's just me.  I prefer to rely on original source information rather than homemade desk-guides and so forth, however well-intentioned, because I have learned that it is hard to get these things right and it is almost impossible to keep them up-to-date...

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Don,

would it be possible to create something similar to the dpap dfars/pgi split frame view that would show the far, dfars, and pgi in a triple pane view? 

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I'm sure it's possible. The Navy used to have a FAR/DFARS/NMCARS side-by-side comparison tool where you could view all three at once. You think that would be more user-friendly? You would have to scroll in each window.

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IMO it would be easier, but I can ask folks around my agency of about 80 people ranging from brand new 1102s to folks that have 25-30 years of experience and give you some boots on the ground feedback. 

I appreciate you taking the time to put this together, I use the rewrite of 52.212-1 tailored to SAP buys that you and Vern put together whenever I have to do sap orders so thank you for that as well. 

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1.  If I were with DOD, probably.

 

2.  Your left hand column and subpart numbering already address this.  Shading may not work well for printing nor for copy/paste into Plain Text emails (to my recollection this is fairly standard in DOD).  And the left hand column would create problems as well with copy/paste.

 

3.  No.

 

4.  For maintenance, you’ll need to consider how to align/annotate the DFARS entries if it’s not up to date with the FAR.  For example, FAR 1.7 may become FAR 1.8 while DFARS is still 201.7.

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I'm all for it, not because it will help anyone, but because it will show how ridiculous the DOD acquisition statutory/regulatory/policy scheme has become.

Congress, the White House, USD/AT&L, DPAP, and the service policy staffs have conspired to make DOD acquisition absurd. None of their voluminous rules have succeeded in making DOD a top notch acquisition organization. It should be no surprise that the F-35 still isn't ready for combat after 20 years of development.

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Two quick thoughts from my first read which are spin-offs of those already offered.

The example is an easy read and would be useful but I wonder what the view/document might look like when you get to another FAR Part that has a significant amount of DFAR/PGI/Class Deviations?

Not sure if my personal experience is completely up to date and this thought varies from office to office but have visited some where folks have two screens from which they view the FAR and an agency's supplement side by side.   Understand the DoD has the PGI as well but with this thought in mind I am having some difficulty in wrapping my mind around how the proposed idea would work for the two screen folks.

 

 

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Circa 1990, as a member of the FAR Council, we suggested something similar where all levels of regulatory material, as well as non-regulatory explanatory statements (ala UCC), guides, and other related were "collocated" electronically and connected by hyperlink (as opposed to physical co-location and shading). As a companion concept we also suggested a reduction in regulatory requirements and the expansion of explanatory statements and guides. Of course, the concepts were quickly rejected. In today's world, I'd suggest the addition of integrated process maps so that detailed methods and processes applying the rules could be followed by practitioners.

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I think it's a great idea! And echoing what Vern already said, it will show how cumbersome DoD statutory/regulatory/policy is for a working professional. I don't envy the person tasked with compiling or maintaining the tool.  As you build the tool, parts you have already consolidated are going to be updated as you are compiling other parts (i.e. assuming you work by part in numerical succession, as you are compiling Part 15, DFARS Part 5 will be updated).   

1. Yes, I would use such a tool if it were user friendly. In my opinion this would mean having the tool web based, similar to the Air Force Hill FAR site, with the FAR Parts listed on the side of the screen while viewing the content in the center of the screen and able to scroll through an entire part without having to click on each individual subpart (like acquisition.gov).  Although not entirely necessary it could have links to the actual regulations on the top; similar to how the Air Force site allows you to switch between FAR, DFARS, NMCARS, AFARS, etc.

2. I think shading is sufficient for distinguishing between the different regulations, and it is useful to have regulation cited on the left, otherwise a reader would need to refer back to some legend every the used the tool if they were not a frequent user.

3. To make the tool more useful, do you plan to incorporate clauses? Or a clause matrix? While the matrix isn't full proof, it is a tool to help start looking at clauses for RFP's, exporting it to excel makes it even more useful.  I think a consolidated clause matrix across the regulations would be a powerful tool, although possibly a separate project from your current endeavor.

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1 hour ago, Confused1102 said:

3. To make the tool more useful, do you plan to incorporate clauses? Or a clause matrix? While the matrix isn't full proof, it is a tool to help start looking at clauses for RFP's, exporting it to excel makes it even more useful.  I think a consolidated clause matrix across the regulations would be a powerful tool, although possibly a separate project from your current endeavor.

I'm working on a consolidated clause matrix, too.

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Sadly, although I think this is a great idea, it doesn't sound like it will include the sub-DoD supplements (AFARS, AFFARS, etc...) so a contract specialist still won't have a one-stop shop for the FAR and its DoD supplements.

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