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Blog Comments posted by Desparado
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As I said in 2016, thank you....
This site is more helpful than you can probably even imagine.
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This wasn't a matter of the Government being a "500lb gorilla". It is the matter of the Government's ability to determine its needs, and not the contractor's right to deliver whatever the heck they want to. There are several legitmate reasons that the Government may have only wanted 4,000 gallons instead of 7,500. Perhaps they were only funded for that amount? Perhaps that was the amount that would carry them to fiscal year-end? Perhaps that was all they needed at this time? Whatever the reason the Government should always have the right to determine its need.
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It always amazes me how many times an offeror will wait until the last possible moment (in some cases, literally the last few minutes) before submitting an offer. I've had people walk in the door 3 minutes late to a bid opening and complaining because their watch had a different time than the clock in the bid opening room. Crazy...
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"...must purpose certain products and services from designated non-profits that employ blond and otherwise severely disabled people." I'm so glad that I am dark-haired!
On another note, the JWOD/AbilityOne program helps a lot of people with disabilities and so a win for the SDVOSB can also be seen as a loss for the disabled.
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Perhaps I'm just a negative person, but I find this program very problematic. First, the title, "All-Small" is misleading because of the fact that it will be a large business that is the "mentor" in most if not all cases. I understand why that term is used but I still contend it is misleading.
My biggest issue with this however is that this will create an easy avenue for pass-throughs. A large business can become a "mentor" to a small and then do the majority of the work and just pay the "protege" a nominal fee. Personally, I am not a fan of this program as I see that this has far too much opportunity for abuse.
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Simple. Lazy contracting officers trying to verify if a business truly is small based on the NAICS and so if that specific NAICS is listed, it's easy to do. Some COs even make that a solicitation requirement.
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On 8/2/2016 at 1:59 PM, Don Mansfield said:
I do not see any additional costs for what I am proposing. I do see savings each time a student opts not to attend a class and prepares for the examination on their own, though.
The additional costs that I was thinking of are for all these 1102s that switch specialties. Many agencies use the silo approach to contracting. Under this scenario when someone gets a promotion or transfer and moves from products to construction, or to services, or to some other specialty they would need to get another certification. If they don't test out, that means more dollars for training. I'm not saying that's a bad thing, but the extra cost is something that would need to be figured into the decision process.
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So if I understand the proposed solution correctly, if an 1102 were to move from an office that did installation support (like a military installation) using primarily Simplified Acquisition to an office with another agency (or perhaps the same one) and started working A/E actions, they would need to complete an additional Level II course.
How would this work in smaller offices where the 1102 has to do several types of contracting? When I started out at a military installation I did Simplified Acquisition, Construction, Services and IT Acquisition all on any given day. Under this scenario would I have had to be Level II qualified in all these areas? I think having specialized certifications would create problems for the agencies and the workforce.
Although the current system is far from perfect, if it is going to be changed it will need to be flexible enough to facilitate all types of offices. With all its faults (and I admit there are many), the current system does provide some basic foundational contracting principles that can expand to most (if not all) types of contracting. The costs to administer a specialized program is something else that would have to be considered. With the trend of movement of 1102s that I've seen over the last few years, people would be constantly taking training/tests for new certifications.
Intriguing idea, but I don't know how it would work from a practical standpoint.
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WIFCON is an incredibly valuable resource. I was told early in my career to check this site daily and I have since given that same recommendation to every 1102 I encounter, whether they be my employees or just fellow contracting professionals. I enjoy reading the protests (sick, I know) and I learn from them on a daily basis. The value of the discussion board is immeasurable (not that I'm looking to pay a lot for it, but I would pay some if the site had to go that way in the future). Having the input of people like yourself, Vern, Joel, H2H and many others on various contracting topics is amazing. Thank you for all that you do!
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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.
GAO Says SBA Certificate of Competency is (Usually) Outside its Jurisdiction
in SmallGovCon.com
A blog by Koprince Law LLC in General
Posted
Your inference was correct. All factors were evaluated on a pass/fail basis for this LPTA acquisition.