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About MV2009

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  1. MV2009

    Staying in vs leaving

    Joel, We’ve done command wide as well as individual events for specific contract actions. For purposes of this discussion, I was referring to the individual events for a specific action.
  2. MV2009

    Staying in vs leaving

    FrankJon, you are correct and I’ll try to clarify what I intended. Organizational success is dependent on a lot of variables. Employee morale is an important variable towards obtaining that success. If individuals do not feel like the work they are doing is meaningful, the work product quality may decrease. If the buyer receives no feedback from industry on the requirement or only one offeror responds to a competitively solicited action, it can have an adverse impact on morale as an inidivual may feel helpless in achieving its objective to provide best value to the government and taxpayer. I understand there is more to it as there are internal items (management, contracting officers) that impact employee morale significantly as well. Since these internal items require an in-depth look and assessment of the organizational, which cannot be provided here. I was seeking an answer to the following: How do you promote competition in markets where suppliers do not seem very interested in responding to solicitations? Are there items in the notice or at the industry day event that need to be explicitly written or said to promote feedback and questions from industry? I did wonder if it was a perception issue but after reading here_2_help post, its clear that is unlikely the reason.
  3. MV2009

    Staying in vs leaving

    The "Ethics and Transparency" thread posted by Eagle93 led a number of people to recommend for the individual to head for the exits and do not look back. I wanted to see what steps the community would recommend if the individual sought to improve the organization vice leaving. Reading and gaining the technical knowledge and demonstrating what you learned will be the most important elements to gain respect within your office but how does the individual change the perception of the office that industry may have? Revising the requirements is key but the lack of interest from industry regarding the requirements makes me believe there is more to the story than just the requirements being revised.
  4. MV2009

    Interview Guidance

    If you want to set yourself apart, research the place you are applying for by finding slides or info on that contracting office by searching the web and then use FBO to look up current and archived FBO notices to see the type of work they do. A lot of people are just applying these days without knowing much about the office they are applying for.
  5. MV2009


    Sal, First, I recommend you email the contracting officer notifying them that you are aware of your invoice being rejected and would like to understand why was it rejected as you performed the effort authorized by the contracting officer. If you are unable to receive a response you can always file a claim. In the future, I would recommend requesting the contracting officer to put their verbal direction in writing prior to start working. At a minumum, you should put an email together documenting your discussion with the contracting officer and request acknowledgement of receipt prior to start working. This will strengthen your case if a claim is required and it becomes a battle of he said she said and reduces any potential ambiguity.
  6. MV2009

    CDRL Debate

    A question was asked if DD Form 1423s should be used on solicitations for commercial services/products under FAR Part 13. One side stated that CDRLs (Contract Data Requirements List) are never incorporated on commercial services/products and would not support CDRLs on any FAR Part 13 acquisition. The other side stated CDRLs can be incorporated on commercial acquisitions but depends on what the CDRL is asking for. Since I am arguing on the latter side, I wanted to lay out my thoughts and see if anyone wants to add to it or say where I am off base. I appreciate any help. 1) The purpose of DoD 5010.2-M, Procedures for the Acquisition and Management of Technical Data, is to provide a uniform approach to the acquisition and management of data required from contractors. Within DoD 5010.2-M, it states "It should be noted that DiDs DI-TMSS-80527 and DI-TMSS-80528 are the only authorized DiDs to be used when the procuring commercial-off-the-shelf (COTS) manuals." 2) It is not uncommon that commercial services (outside of the DoD) require data to be furnished during and/or at the end of performance. If the DoD has uniform set of items it wants in its report, this to be no different than Walmart or any large business requiring certain content to be in its deliverable company wide to ensure consistency. The only difference is where the Government calls it out (i.e. in the DiD) This may just be a terminology debate but it does not make sense that CDRLs could not be used in commercial services.
  7. Tomahawk, Based on Vern's comments of the RFP, there are some contract writing systems that require every line item to specify a contract type whether it is priced or not-priced. For the contract writing system I am thinking of, this was part of a mass update that will not allow the line item to go on the contract without the contract type. Not sure if this is the exact situation because I haven't seen the RFP but wanted to let you know as this may appear depending on the contracting agency's contract writing system. As previously noted, industry should always ask questions. Ultimately, the awardee and the Government will live with the contract so at the very least industry's questions should force the CO to think about the question.
  8. What piece of advice would you give to a new contract specialist entering the workforce based on your career? Also, what piece of advice, if different, would you give to a recently warranted Contracting Officer?
  9. MV2009

    Read this. Read it NOW!

    Interesting read. Federal contracting is managing scared and that is no way to manage a business. The net results of doing so are fear, delays, and mistakes. If you want to look for improvements in contracting start with looking at aligning the incentives of the acquisition team and focus with the end state in mind. FAR Part 1 is clear we need to manage risk not avoid it.
  10. MV2009

    Paragraph i of FAR 52.232-22

    Retreadfed, I agree with you the point is to fund up to the contract value but if I don't know if the funds will ever come outside of the guarantee received prior to award, its bad practice to encourage performance to continue. Vern, you are correct that the costs associated with the stop work and restarting the work or contractor requesting termination would be more expensive. I don't know why it is hard for agencies to fully fund or provide accurate and realistic funding increments.
  11. MV2009

    Paragraph i of FAR 52.232-22

    Agreed. I assume the intent behind this paragraph was to address when the additional funds would be added to the existing line item on contract or to provide clarity in case the Government was silent. The inclusion of this paragraph in this clause is interesting as it gives the contractor the flexibility to work at risk with an option to get reimbursed. If the contractor wants to work at risk, that should be a business decision outside of the contract and I don't understand why the Government would want to discuss handling this in the clause. To me, it seems like the paragraph, encourages the contractor to continue working if it knew that additional funds would be allotted.
  12. MV2009

    Paragraph i of FAR 52.232-22

    I'm on the government side of the equation and interpret the info SLIN the same way you do. On separately priced SLINs, the PoP should be considered direction from the Contracting Officer and thus would make costs incurred at risk prior to the start date of the new SLIN unallowable for that line item.
  13. MV2009

    Paragraph i of FAR 52.232-22

    I've seen agencies do either approach when performing incremental funding modifications on service contracts...the reason being the long lines of accounting are different. (I.e the initial funding was done in FY16 and the next increment will be done in FY17). I can provide further detail if my response is insufficient.
  14. I have been looking for the answer and am hoping someone here can explain the intent behind paragraph i of 52.232-22 as well as its purpose. As written, is this paragraph saying that if the contractor incurs cost that are in excess of the amount previously allotted by the Government those costs shall be allowable to the same extent as if incurred afterwards unless the Contracting Officer issues a termination or other notice and directs that the increase is solely to cover termination or other specified expenses? It appears the formatting is off in the clause, otherwise its not clear to me what subparagraph (i)(1) is saying. Assuming its formatting, the Contractor could work at risk and would be reimbursed when the Government provides additional funding unless the Contracting Officer directs otherwise? If so, lets take the following examples and get your thoughts on it: 1) Funding is added to the contract by adding a new informational SLIN (PoP at the priced CLIN level remains unchanged) and Contracting Officer provides no direction outside of the effective date of modification. Since PoP is not specified at the informational SLIN level, can the contractor bill for costs incurred prior the additional funds being allotted on contract? 2) Funding is added to the contract by adding a new separately identifiable line item with a PoP identified at the line item level. Does the PoP specified at the line item count as guidance from the Contracting Officer?
  15. MV2009

    Core Competencies? Outsourcing?

    Amazon understands the risk to its business model and is trying to limit its exposure. When your core competency is dependent on external forces outside of that competency, it is critical your business looks at ways to minimize its risk to those forces. This is especially true when consolidation occurs in your supplier networks. The Government needs to be aware and consider this especially in SETA contracting for highly technically skilled program offices.