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Desparado

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Everything posted by Desparado

  1. My guess (and I'm sure Vern will correct me if I am wrong) is that it is because under a FFP it really doesn't matter to the gov't how much they pay for the items, since the price the gov't will pay is unchanged.
  2. Desparado

    2012 Acquisition Workforce Survey

    Upon further review, perhaps I should put this into context. If you are sending a nationwide survey to hundreds (if not thousands) of 1102s, the survey should not be 30-45 minutes and should not include text-box answers. With that many respondents, it is not practicable that the text box answers will really be taken into consideration. If you want to maximize participation, keep the survey to no longer than 15 minutes (as opposed to the 5 I stated before). Any longer than that and I believe most people lose interest and the validity of the responses decline as people get to the point where they are just answering questions quickly to get through the survey.
  3. A lot would depend on your agency's requirements for documentation requirements. It also depends if you're using the GPC as the purchase method or the payment method. If a FSS BPA is established, I would think that the payment method could be the GPC, but the purchase method was probably done via a RFQ or other type of solicitation. The BPA could easily be written to include the GPC as the payment method. As far as FPDS-NG goes, each agency handles differently. A few years ago when I worked for the Army, they would consolidate it quarterly and report. I agree with Vern (and really, who doesn't?) that more information is needed before a more detailed response could be given.
  4. Desparado

    2012 Acquisition Workforce Survey

    One reason. It is way too long. When you see that it takes 30-45 minutes to complete, a person thinks, "I don't have that much time" and they skip it. I think no survey should be longer than 5 minutes.
  5. Desparado

    FAR 12 vs. FAR 8

    You are correct that GSA Schedule contracts will lag when it comes to new clauses (as do most IDIQ-type contracts). The current policy is that the Schedule contracts be refreshed at least semi-annually. In regards to the second part of your question, an ordering activity may add any clause to their RFQ and resultant DO/TO as long as it does not conflict with clauses already in the Schedule contract. This makes it easy for DoD agencies to add the DFARS clauses where needed, as an example.
  6. Desparado

    Services on a construction site

    Subject Matter Expert is the most common use of SME that I'm aware of.
  7. There are rare circumstances where the GSA will establish the Basis Of Award (BOA) as a customer different than the MFC. The BOA is what GSA uses when enacting the Price Reductions Clause. An offeror should indicate to GSA why their MFC should not be their BOA. Most common reasons are different buying patterns or differing T&Cs than what the Government offers. Putting together a GSA offer is not a cheap or easy task, so perhaps you can try to have a conversation with the GSA office hosting the Schedule you are considering offering for prior to submitting an offer?
  8. Desparado

    GSA Administrator Resigns - IG Report

    I'm sure she knew there was a conference, and maybe even attended... but to think she knew about how much it cost, or the number of advance trips. I just can't believe anyone at her level would know about details at that level. But, being the head of the agency in disgrace, she did the "correct" thing and resigned.
  9. Desparado

    GSA Administrator Resigns - IG Report

    She is a political appointee in an election year. My guess is that she was "asked" to fall on her sword. My guess would be that she had no idea of anything about the details of this conference. Nobody at her level would.... imho
  10. Desparado

    SDVOSB/VOSB Protests and Question

    dcarver - Yes, the last question you ask is what I was curious with. Retreadfed - Very interesting point. GSA does not currently use the VetBiz program to certify businesses as VOSB/SDVOSB, but it appears that the contracting officer at the DO/TO level would need to do so as part of the process.
  11. Desparado

    SDVOSB/VOSB Protests and Question

    I apologize for the font issue.. Apparently when I copied/pasted the protest info, it messed things up somehow.
  12. Desparado

    FAR 12 vs. FAR 8

    Interesting, but I would also point out that GSA Schedule contracts include the commercial clauses (52.212-3, 4, and 5). What additional clauses is your colleague recommending including? It is GSA's goal to make the ordering process simpler and more expedient than when using open market procedures.
  13. My opinion is that the effective date is just that... the date it is effective, and therefore you should not issue any task orders until that effective date. Where I have worked it is common practice to exercise the option several weeks (or in the case of GSA, months) prior to expiration so that there is no risk in a lapse of service or expiration of contract.
  14. Desparado

    Open market items on FSS BPA's

    I've always thought this subpart was oddly written, and no, I have not done this. In my past most of the items I added for administrative convenience were under the micropurchase threshold and therefore I did not run into any issues. On a side note, have you discussed with the FSS Contractors about adding these items to their Schedule contract?
  15. Desparado

    Expeditor?

    I have worked for the Army, VA and GSA, and have never heard that term used.
  16. Before the recent change, I believe the language of 8.404(a) had been widely interpreted as "If Part 19 does not apply, then we can't set anything aside". Before the rewrite of 8.405-5, Agencies have always been able to give "evaluation preference" to socioeconomic categories, but now that the rewrite has occurred, they have the ability to actually set things aside.
  17. Based on the scenario provided, I believe once you document the justification for the single-award BPA, you have no obligation to post justifications for calls against that BPA. The BPA was fully competed, so I see no reason you would need to prepare any further justifications.
  18. Perhaps I am missing something in your question. From the way I read it, it appears that a competition was done, and then the quote the contracting officer elected to select is offering product A. In this case, the decision for a specific brand name was not made by the requiring activity prior to release of the RFQ. It is merely the product of the winning quote. If this is the case, I do not see where a brand name justification comes into play. Now the decision for a Single Award BPA (especially if the RFQ stated it would be Multiple) may be another issue, but that does not appear to be your question. Or is it?
  19. Desparado

    Paperless Contracting

    Our office is 100% paperless. All offers are received via an electronic offer system, we process everything electronically, and sign all documents (awards, PNMs, etc...) via a digital signature. The conversion was tough, especially for workers who are less computer-friendly, but eventually everyone in our office has come to enjoy working in a paperless environment. This has been a gateway to working more in a telework environment, as our agency has issued each of us a laptop and a blackberry and we can work from anywhere. Our electronic contract filing system was very slow when we first converted to it, but as they have improved capacity and processing speed, we have found it to be very easy to use.
  20. I work for a GSA Schedule contracting office, and I can attempt to address some of the issues here. Please note I do not work for the IT Schedule, so I cannot be specific as to the particular issue you raise. There are several reasons we may cancel a contract, but the two most common I have ran into is because either the Contractor has requested it in accordance with this previously cited clause, or because they fail to meet the minimum sales criteria. In any event, when the modification is entered into our contracting system, an effective date is also entered. As our system automatically feeds into FPDS-NG, I do not know (and to be honest have never researched) what that feed looks like. However, it is our office's opinion that once that effective date has been reached, no orders could be placed against the Contract, or options exercised. In fact, if a contracting office were to attempt to place an order or exercise an option when they get into FPDS, they should receive an error message that the Schedule contract number is not valid. Now, as far as your question regarding eLibrary goes, I would not automatically make the assumption that because a contract is not listed, it has been cancelled. Yes, in a perfect world, that would make sense, however there are a couple of other circumstances that can also cause a contract to not show up in eLibrary. The first is that if a Contractor has not updated their information in the last 2 years, their entry is deleted in the eLibrary system. This does not terminate or cancel their contract, but does stop their information from being displayed in eLibrary. The second is the standard "systems issues" which we encountered last January and could easily come again. If you run into a situation, the best advice I would give is to call the GSA Contracting officer or Schedule Supervisor for information if you run into this again.
  21. Desparado

    Administering BPAs, exercising "options"

    We have to keep in mind that FAR Part 8.4 was recently changed, and prior to that multiple-year single-award BPAs were permitted. Also, some agencies have issued waivers for long-term O&M BPAs (PBS is an example). There is a requirement (and has been for as long as I can remember) for an annual review of a BPA, which must be documented. See FAR 8.405-3(e). Other than that requirement, based on what you have described, there is no requirement for a formal "option exercising" process, imho. However, if this BPA was awarded after the re-write of FAR Part 8, I would agree with Napolik's comments.
  22. If it is an Open Market acquisition, you are not tied to your company's GSA Advantage prices. However, please note that if your federal customers find out that you sold the items at a higher price than you have on Advantage, your company's reputation will surely take a hit.
  23. Desparado

    Dan Gordon is leaving OFPP.

    Vern - I am curious as to your opinion of Dan Gordon's "Mythbusters" campaign. I was at the Coalition For Government Procurement's conference last week, and the entire theme of the conference was Mythbusters, and included Mr. Gordon speaking on the topic. I found the conversations interesting, but still have concerns.
  24. Another question: Was the GSA BPA a single-award or multiple-award BPA? See FAR 8.405-3© for ordering procedures against GSA BPAs. There are different rules for ordering against a single-award versus multiple-award BPAs. Hope this helps.
  25. Desparado

    Discouting GSA Rates

    I am assuming that your MFC and your Basis Of Award (BOA), which can be different, are in this case the same classification (for profit entities). By giving a deeper discount to a different class of customer, this may create a new MFC. If you are now giving non-profit entities a better price, they may now be deemed as the MFC. This would need to be disclosed when you prepare your next CSP-1 document (which could be at an Option, or at another time as your contract dictates). Now, although this new category of customer may end up being the new MFC, it may not in fact be the BOA if the buying patterns are different. This is definitely a discussion you should have with your GSA CO. I have many times seen situations where the MFC and/or the BOA may change depending on the mandatory disclosures on the CSP-1 document. I have also seen where the MFC is not the BOA because the buying patterns are significantly different.
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