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REA'n Maker

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Everything posted by REA'n Maker

  1. I love it. Alternate Methodology: Thunderdome. Criteria: Must be Strong Like Bull to Win Contract.
  2. NIH seems to be resting on the premise that over 350 protests, 120 of which were sustained by GAO in one swoop 2 years into a procurement, is just fine and dandy. The way they shift the goalposts from "120 sustained protests" to "only three sustained allegations" is masterful (isn't that actually 3 allegations x 120 protests = 360 sustained allegations? 🤪) True innovation involves simplification, not more steps/failure points and increased document generation. That NIH methodology is absolutely ludicrous, evidenced by the fact that NIH has spent two years on this thing and still has not received proposals upon which an award can be made. That's krazy with a 'k'.
  3. Seems like the wish for competency testing has been granted with the new DAU curriculum overhaul. IRS has been using testing for quite some time and it seems to be successful*. (*I say this because it weeded out an incompetent GS14 from our agency who accepted an IRS job contingent on passing the exam - he didn't, and is now back at my agency. As a COR. 😭)
  4. Yeah formerfed I agree every experience is different but based on my experience in 25 agencies in all 3 branches of government, DoD is the place to be as an 1102. Why else does every civilian agency copy DoD to the point of teaching the proper use of WPN funding (!) in their 'training classes'? Civilian agencies definitely have fewer rules and regs but I also know of at least 2 agencies who believe that task orders are cost-type and delivery orders are FFP (I'm not making that up). I would advise the OP to look at the mission of whatever agency they are considering. Have a great weekend!
  5. From my experience, DoD is in general a better place for 1102s than the civilian side because DoD acquisition is vital to its mission. DoD also has acquisition curriculum, systems and processes in place that have been developed over several decades as well as a respect for basic stuff like the chain of command. The civilian side is a politically-driven money-wasting machine more concerned about where something is procured than what is procured.
  6. I would consider it a major victory if someone would develop a reliable clause logic engine- it's inherently a rules-based process, which should be extremely easy to automate. Yet to date, all we've gotten are useless macros that miss the most obvious clauses imaginable and in general crank out pages and pages of garbage (e.g., not selecting any Part 36 clauses for an A-E procurement) Having sat on the contractor side of the house for 20 years, I can affirmatively state that the people writing code for every Federal contract writing system don't have the slightest clue how these systems are to be used. My point being that I don't see AI being a factor in Federal procurement anytime soon.
  7. What is the business reasoning behind this question? To ensure a furniture leasing company doesn't have segregated facilities or what?
  8. In 1.108(c) context, my reference was closer to "ceiling price". "Maximum" is probably more applicable to quantities so not the best word choice.
  9. I know of several 1102's who have changed their job series but I have no idea how "difficult" it is. I would guess "not very".
  10. AKA total IDIQ value/contract maximum. It was intended to address stuff like the $7.5M CAS thresholds. I think it's a totally fair statement to say that CAS is applied at the task order level, but I also think that the determination to do so is in the IDIQ. It's sort of like how you make a SB set-aside determination at the IDIQ level even though you are actually setting aside the TOs. Assuming the maximum order value on a $100M IDIQ is over $7.5M, that would practically dictate CAS coverage. It's definitely not an exact science, or a science at all for that matter, but I've never heard of CAS coverage being a big deal to any vendor proposing on a $100M federal contract. Aren't CAS basically GAAP anyway?* That's not rhetorical; I honestly don't know for sure. (* I believe this construction is bizarre yet grammatically correct however I am also a product of the American public school system)
  11. I second that opinion. Isn't CAS coverage sort of like being pregnant, i.e., "partial" coverage makes no sense (per Don's comment above)? Considering CAS coverage is based on an entity (corporation, business unit, office, branch, etc.) and the total estimated value of all orders I don't know why it wouldn't be included in the overarching legal agreement with that entity which states the total estimated value of all orders.
  12. The DD254 is security guidance. What does the subcontracting plan say?
  13. This is modern contracting - click 'approve' in the system of record, sign the contract (not in the contract writing system however because for whatever reason no one has cracked the nut of tying a legal signature to a system of record approval) and keep your fingers crossed that there is no financial interface failure. My favorite is 'financial interface failure' on admin mods (don't ask me how because I don't know and apparently the system people don't either). I've had to hold stuff for days until it got unstuck. Honestly the current approach is no better than the old days of holding the award for execution until you got the hardcopy Financial Accounting Data sheet confirming funds availability. At least you knew before you signed that the decks were clear. Now ya' just clicks yer' button and ya' takes yer' chances that the IT gods are smiling on ya'. It is a travesty how 1102's are now supposed to be IT experts even though you'll be lucky to find a single shred of current guidance on a contract writing system and basic SOPs like the double-approval crap (my agency somehow neglected to provide any guidance on mods. Modifications are typically 75% of a typical contracting office's transactional workload, so no biggie, right?). Thats why we make the big bucks I suppose. 😁
  14. Isn't the actual problem here that an OF347 has no block for vendor countersignature, rather than "the contract writing system" per se? (which only enforces existing business rules). Have you considered using a SF1449 or sending the vendor an unsigned OF347 for concurrence prior to signature if it's non-commercial*? The "OF" is there for a reason after all (it's also a terrible, archaic document). I'm shocked the vendor knew they had a right to repudiate an order, so I guess somebody out there is paying attention after all. (* I would refer you to the "FAR doesn't say you can't use a 1449 for non-commercial" principle here if you're feeling especially bold.)
  15. Spot on. One of my pet peeves is the way the Government always tries to push its own inability to get its act together off onto the vendor community, whether it's releasing a critical procurement document at 11:59PM so we can count the "day" it was released, or assuming vendors can work all weekend to revise a proposal because of something we forgot to add until the last minute on a procurement that's been slogging along for a year or more. I'm surprised this doesn't happen more often considering the fact that anyone who can fog a mirror is apparently qualified to be a COR.
  16. No; I know exactly what I'm talking about which is why I rephrased my response. You are obviously referring to rather simple, predictable requirements, while I am referring to complex engineering and technical requirements where Travel is not the point of the contract. If your experience is different that does not mean "I do not know what I am talking about". Based on my breadth of experience throughout all branches of government, I'll go with my assessment of what constitutes "typical", your approval notwithstanding. And next time you take someone to task for their "limited understanding" you might want to base your own assertions on something other than your limited personal experience at DoD a long time ago. For example, my assertion is based on recent, first-hand, objective, down and dirty review of the active contracts of entire agencies over many years, not an overinflated ego which conflates personal opinion with fact. Self-awareness much?
  17. Fair enough; there is no regulatory reason Travel must be a reimbursable; in practice it typically is. (I'm not getting your point about 52.212-4 Alt I though) But as a business practice I fail to see why it would be done any other way. Price risk associated with Travel seems a bit obtuse.
  18. Anyone on travel would come home by September 30. Considering Travel is always covered as a reimbursable, I'm curious why contract type is a factor at all. The PWS is definitely different. It's in a different contract. In response to a different solicitation. With different terms. With a different PoP. With a different award date. With a different PIID. And a different price.
  19. My policy is that if there is any doubt, Christian likely doesn't apply. One thing I do know is that its application is very narrow. As previously stated, FAR 52.244-4 may apply to Architect-Engineer services contracts. If your award cover sheet is an SF252, you need to look for that clause as well.
  20. ya' think? I have a branch chief who followed Part 15 procedures for awarding task orders under a single-award IDIQ. Apparently, he had been doing this for years so when I took it over and pivoted everything to 16.505 you would have thought I cured cancer or something based on the reactions from the program office and vendor. I'll take the easy wins every time.
  21. Based on my thankfully limited experience, the government could avoid protests simply by communicating better with disappointed vendors. I've been told on more than one occasion that if the government had responded in good faith to vendor post-award requests for debriefing, they wouldn't have needed to file a protest to find out why they lost.
  22. FWIW, we were notified a couple weeks ago that one of our impending awardees (a non-profit) was not able to update their SAM registration through no fault of their own and not because of any technical glitches. Apparently, them new-fangled cyphering boxes the SAM administrators use to process registrations and update existing records on the interwebs are unable to keep up, and they have a "backlog" they are working through. I suspect one of the internet tubes is blocked up. Your government; marching boldly forward into the digital future. Said no one ever.
  23. Oh that's nothing. A CO in our office accidentally obtained a COR FAC-C Level III. I was the first one to notice her name in the agency's certified COR database, i.e., she wasn't aware until I told her. Turns out that when she was setting up her certification request on FAITAS she accidentally selected "FAC-COR", noticed the error, de-selected it, selected "FAC-C", and continued on. When she contacted our training coordinator after I saw her name in the COR database, the response was "yeah; so what's the problem?" Result is that she is now a proud FAC-COR/FAC-C Level III even though she never intended to obtain the COR cert nor has any plans to use it. This, ladies and gentlemen, is why we can't have nice things.
  24. It's a best practice (but not overwise a rule or regulation) for the government to include a requirement to ask for CO approval of LCATs which weren't part of a vendor's original proposal. I assume you looked in your contract for such language?
  25. Maybe "Put them on notice" is a better term than "effectively communicate"? OASIS for example has hundreds of SB & LB vendors. What do you do if someone objects? Assuaging the belligerence of even a small % of the OASIS vendors would be a huge task. My agency did an industry day for OASIS SB Pool 1 under NAICS 541611 and we had 95 participants.
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