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Matthew Fleharty

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About Matthew Fleharty

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  1. Let's not forget that while size (or quantity) can increase complexity, complexity is also a function of clarity (or quality). I'd encourage anyone concerned with FAR complexity to visit http://www.plainlanguage.gov/ and read the "Federal Plain Language Guidelines." Those who do will likely find him/herself wondering what the FAR (and other Government regulations/documents) might look like if they followed such guidelines.
  2. Waiver of Amounts Due the Government

    How does FAR 1.602-2 override FAR 32.610?
  3. Special Standard of Responsibility Use & Application

    Well myfrogleaps that's what you sometimes get when you ask for free advice ("beggars can't be choosers"). I don't have any experience using Special Standards of Responsibility, but I'll try and set you down the right path: First, you should think about the difference between a standard for responsibility and an evaluation factor. The latter is supposed to focus on areas that will discriminate amongst potential offerors during the evaluation process while the former is a requirement for award eligibility (in all cases I'm aware of they are binary [e.g. Is the contractor debarred? Does the contractor have adequate financial resources to perform the subject effort?] so they're not discriminators, but they are hurdles an offeror must clear in order to receive a contract award). See FAR 15.304(b): Second, if you do a standard Google search for "Special Standards of Responsibility" one of the top returns is the following DFARS link (http://www.acq.osd.mil/dpap/dars/dfars/html/current/252237.htm) which provides an example of a Special Standard of Responsibility that is required when contracting for audit services. If you read the clause, it details necessary requirements for a potential contractor that intends to provide audit services, but those requirements would not be discrimators amongst the offerors as to which one offers the best value. That's presumably why they're treated as a responsibility standard instead of an evaluation factor.
  4. Types of orders

    There is tremendous variation/sloppiness in the use of acquisition terminology period. I learned a valuable lesson on "linguistic precision" as a 2Lt when my first PAR and SSDD were reviewed by my boss. The documents came back with more red ink than I had ever seen on any of my college papers due almost entirely to using various words inappropriately. For example, I used the words "price," "cost," and others interchangeably to try and improve the documents' flow and readability; however, the result was a set of documents rife with inaccuracies that made even less sense due to my monologophobia. My recommendation: call out and correct linguistic imprecision whenever you can. Hopefully it will make a lasting impression on the individual(s) and the entire workforce will gradually be better off for it.
  5. "Breakdown Activities" for the Contracting Workforce

    I initially had a similar reaction (which is why I was only able to quote one sentence from the article), but two weeks later I'm still stuck thinking about what contracting activities high performers perform better than low performers. Maybe I need a re-vector, in which case I'd be happy to hear any thoughts there as well. As for trying to clarify and elaborate, I'd like to leave the prompt broad (for now), but here are some examples of "breakdown activities" I've been considering (so much for trying not to "lead the witnesses"): Reading and interpreting contracts/regulations/statutes Deductive reasoning Negotiating An example of an activity that I don't think fits the bill: Using contract writing systems (PD2, ConWrite, etc.)
  6. I'm drafting some thoughts/recommendations on improving training for the contracting workforce and I'd like to solicit input from those of you who frequent these forums. Specifically, I'd like to know what each of you think are the "breakdown activities" for our workforce. "Breakdown activities" are defined as those "tasks that differentiate high and low performers." The term comes from an article in Harvard Business Review that I read last month - for those of you interested in the complete article, you can read it here: To Better Train Workers, Figure Out Where They Struggle. Thanks in advance for any input!
  7. Kickstarter and the GCPC

    Is anyone aware of any restrictions on the use of the Government Purchase Card when using Other Transaction Authority?
  8. Kickstarter and the GCPC

    I was there with the SMC team that morning, we must have just missed each other.
  9. That's an oxymoron Neurotic. Are you asking if you should modify the contract after award to increase the Target Cost based on the FPRP? Why does (or should) a contractor's proposed rates have to match their FPRP?
  10. Accountability Might Need a New Name

    If anyone is interested in a 20 minute primer on blockchain see the following: The professor in the podcast also wrote an article for HBR titled "The Truth About Blockchain" earlier this year that can be found here (may require login): https://hbr.org/2017/01/the-truth-about-blockchain
  11. TINA and Actuals

    Jake, Unfortunately I'm not surprised and I doubt you'll have much luck on your own even if you find this particular COFC decision to send to your contractor. I was in your shoes a year ago and made all the right arguments to no avail; however, what worked beautifully was elevating the issue up through leadership (if this procurement is as large as you say they'll be more than happy to help). Within a week I received complete and properly segregated actuals. So don't be afraid to ask for help - I suspect if you do you'll likely get exactly what you need. If that's unsuccessful, PM me and we can discuss further.
  12. Voting member of a source selection board?

    You should practice what you preach Seeker.
  13. Flowdown Clauses for Commercial Items

    I fought a similar and equally frustrating battle at my first assignment over which provisions/clauses might be necessary for inclusion in contracts for commercial items. FAR 12.301(d) has similar language: Yet still, individuals would use the entire FAR and DFARS provision/clause matrices when writing the solicitations/contracts. I couldn't (and still can't) understand how the definition of "notwithstanding" and the language that follows was unclear, but it doesn't surprise me that some are facing a challenge in this case given the similarities. I suppose this might be one of the procurement lore versus procurement rule issues and some people just get stuck in the way of doing things without knowing why or whether that way is proper or improper. It's such a shame that some would rather be right instead of doing things right.
  14. Read this. Read it NOW!

    I saw that, but based on his work with David Eaves and the inclusion of "by Steven Kelman," they presumably share the same thoughts (I know I wouldn't let a colleague put my name on an article or document without my review and consent).
  15. Read this. Read it NOW!

    Thanks for sharing Vern - I have Dr. Kelman's book "Unleashing Change" in my reading queue. Based on the thoughts in this article, I just may move it up a few spots.