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FAR-flung 1102

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  1. FAR-flung 1102

    Can you pay "subscription" contracts in advance?

    I don't know if this is for DoD, but you may want to check out the DoD FMR on this topic. The latest version I have at hand is: 10_04_Jul10.pdf
  2. FAR-flung 1102

    FAR 52.232-25 Alt 1 Payment Days Authority

    What is the socioeconomic status of the contractor?
  3. FAR-flung 1102

    Multi-year Service Contracts?

    One thing to keep in mind with lengthy contracts involving transfer of capital assets in addition to recognizing the wasting value capital assets (which will be a primary concern of the contractor) is a capital asset's residual value at contract end. How this is handled differs according to situation at hand. Privatization efforts for utilities and housing involve analysis of wasting assets and their residual value. FAR Part 41 regulated utility service contracts already consider capital contribtion, so this tends not to be an issue with regulated utilities. Typical commercial leases involve competition and a lease vs buy analysis which should highlight any problems on this front. Incidentally, energy savings contracts don't present the same concern over residual value since there is no transfer of government assets (the improvrments remain government property). Unlike all of the above, a first time or innovative effort at a long term contract involving capital assets (in lieu of a simple fee for service where the government retains the asset) may be difficult to fund (constraints of fiscal law on capital contribution) and may suffer for falling outside of any existing regulatory or established privatization review process. Government shouldn't want to transfer assets to a contractor without considering the residual value at the end of the contract, but it may, ironically, be more difficult for government to fund the effort when giving formal recognition to the residual value of capital assets. Not doing so can be a very expensive mistake.
  4. FAR-flung 1102

    A Hiring Challenge

    Vern, 1) Yes, its reasonable. It;s a demonstration that a job candidate can perform in the waters in which the service contractor must swim to effectively compete for so many of the potential awards. A lot of service acquisitions have become essay contests. 2) I would accept the challenge. 3) I will think I did well on the essay, but have a high degree of uncertainty about the accuracy of that opinion.. After the interview, my uncertainty may lesson and I will probably think I did well overall. On the job, I expect that I will do very well.
  5. FAR-flung 1102

    Will Federal Acquisition Lead the Blockchain Revolution?

    jonmjohnson , What you and the author of the article describe is a limited portfolio of applications for Blockchain solutions. Hype, to the extent that it exists in any corner, does not alter the basic observation, simply put, that Blockchain should be applied only by those who understand it and only in areas where it will work. In considering the application I have suggested for Blockchain, your points remind me of the old saw about Microsoft products...these are “features not bugs”. Yes, there is essentially only one way to apply Blockchain and only one reason to do it. So, look at that one way and examine that one reason for an accountability system (accounting for every acquisition dollar within the confines of DoD)...to me such a forced fit is a major part of the appeal and not a fatal flaw. This system is not to be all things to all people. I remember learning once that when Army went to implement the standardized GFEBS finance system, they figured that they were replacing 64 different legacy systems. A forced fit in DoD finance is nothing new. Are you convinced Blockchain wouldn’t work well as an accountability system within DoD?
  6. Vern, I think this one’s to me not FrankJon... Yep,it’s a conceptual thing. I m saying that something is missing. Like a lot of stuff, the missing parts may not be obvious until and unless we see what the thing can’t do. My point is that the view of competitive advantage that you have subscribed to scarifices or gives up something else which may be very valuable...This need not be the case. I have tried to describe the term’s other implications, but I have failed. I’m not fatigued, but I’m not effective either. Thank you all for entertaining these thoughts.
  7. Static vs. Dynamic Analysis Snap Shot vs. Moving Picture Long Run vs. Short Run Considerations Transactional vs. Strategic Analysis That last distinction includes opportunity for recognition that a business can better succeed over its competitors over time. Are we willing to consider what happens over time? Vern, it seems to me you are sticking to an analysis of the transaction and not what happens to the business over time. Why do so? I do so because I want insight into what keeps a business competitive and in business. When looking for analysis tools I’m not quick to exclude tools and techniques that may help. I’m looking to learn something I don’t already know...broadening my considerations, reversing or revising the assumptions and playing with definitions are all part of the tool box. I want a big tool box. It seems that making and advocating Policy positions is different...that’s where we narrow our considerations considerably; we use a few quality tools. Policy requires decisions and advocacy and by implication, if not in fact, choosing winners and losers...hopefully with the opportunity for feedback and revision, since the feedback loop is the most important part of any iterative process.
  8. Retreadfed, These two ideas ((1) "the ability to conduct effective, timely, TINA sweeps" and (2) "Litigation avoidance as a competitive advantage in the marketplace.") seem very clear to me and I am not sure why they may not seem clear to others. My first guess is that treating them specifically will not help, but that discussing a possible difference in our viewpoints might. I think some others may treat the word string competitive advantage in serial fashion where I see it as a single term ( a composite or term of art). When treated as two separate words "competitive" remains a strict qualifier which then minimizes the word "advantage"..such a reading would lead one down a certain alley...I can visit that alley, but I know another one that has a certain advantage I'll now discuss (pun intended). Instead, I understand the composite of these two words "competitive advantage" to be a term itself; it is a valuable concept and an analysis tool...Valuable and specialized enough, I guess, to call it a "term of art." For this reason I am unconcerned about using the term in the limit case of a single source...this because in many instances, this very limit case was a precise aim of the business' pursuit of a competitive advantage...and as a result is sometimes the short run result of a business' successful focus. If none of that helps them maybe we could next look at the various kinds of competitive advantage to see the term at work. There are many kinds of competitive advantage...I started with a mention of just two examples: patents and data rights both may form the basis on which a business may legally hold rights that exclude or limit the competition it faces in the marketplace. I think it is one of the most valuable ideas for the proprietors of any business to know what sets their business apart in the marketplace in general and in an individual transaction in particular. Of course there are other concepts, market forces, and constraints to consider, but competitive advantage is an important one .
  9. Vern asks the questions; “How can there be a competitive advantage if there is no competition? Why is it too hard for you to explain?  How long do we assume stasis? Does anyone take issue with the idea that the ability to deliver a sole source solution is a competitive advantage for a business and is subject over time to pressures of the marketplace? Compettve advantage is a useful analytical tool and is in my view not misapplied here. Monopoly, competition, competitive advantage, barriers to entry, the principle of substitution.... conceptually this is pretty basic B-School stuff. Think patents, data rights and a myriad of other real world situations...should we fail to recognize, or disregard the useful concept “competitive advantage” or perhaps insist that it be renamed before discussing the short run case of its limit (upper bound) which is monopoly or sole source? I don’t think so.
  10. Since timing is (almost) everything might this rule to be certified within five days constitute "a new requirement for a certification"? If so, see FAR 1.107 Certifications: "1.107 Certifications. In accordance with 41 U.S.C. 1304, a new requirement for a certification by a contractor or offeror may not be included in this chapter unless— (a) The certification requirement is specifically imposed by statute; or (b) Written justification for such certification is provided to the Administrator for Federal Procurement Policy by the Federal Acquisition Regulatory Council, and the Administrator approves in writing the inclusion of such certification requirement."
  11. The five day deadline for sweeps is a mighty incentive for a major contractor to pursue in earnest their own Blockchain Accountability System, similar to the idea advanced earlier on Wifcon for DoD to consider for itself: If a contractor implemented their own blockchain accountability system, every dollar could speak for itself...the contractor could determine their cost data (every use of every dollar) in near real time with such breadth and granularity that audience & report purpose, not system functionality, could determine the nature of any report: whether that is accountability, management reporting, or audit functions.
  12. No definitely it's not the cat's meow...and I want it to become it to become a thing of the past, but I am afraid of what comes next if we do not reign in a few tendencies first. The "Severeid Effect" (So many of today's problems started out as yesterday's solutions) permeates Washington's political process like an oor. Almost nobody in power is willing to look for inconvenient truth. Its not mine to play kingmaker or Lord of the Realm, but I really do believe that if we kill the FAR Part 19 process right now, we also create a vacuum that small businesses are largely unable to fill. It's just that we create in our current bureaucracy so many problems that only large business has the ability to understand or solve. My main problem with how we treat small business lies in our byzantine systems and processes (which defy reasonable expectations and common sense)...it stifles so much initiative and often makes it very difficult to get a business on board and PAID timely for services or supplies rendered without the need for silver bullets or heroic measures. If a small business cannot get paid timely then THEY are financing government's ponderous machinations...it's wrong but in the current big picture almost inevitable that some will fall prey and their aspirations fade away accordingly. People's expectations are so low,, we should be able to meet them in making meaningful real improvements in doing the government's business and help many... if only we can manage to work with with an even, steady, and competent hand. There was a famous Federal Jurist with my all time favorite name: "Learned Hand"...a name for all time to live up to...metaphorically, we need more of those.. .Thank you for your part Vern. You pull much more than your own weight. Sorry, I think I have mixed a few metaphors, too.
  13. I don't think a longitudinal study isolating for the right things is in the cards...there are too many exit ramps, scenic vistas and pretty snapshots to take along the way, so we won't know much about the real impact of small business however long we ask such question of ourselves. Take for example the authors' observation about small business failure. Anybody can reckon small business failures, in the same way that anyone can count the number of seeds in an apple...but that's a snapshot at an instant...even when the same statistic is gathered in serial fashion every year...it is a series of snapshots and does not tell us what becomes of any given failure or set of failures. Instead, what will we imagine if we ask ourselves how many apples in a seed? Similarly, does anyone know the real impact of small business failure and even the prospect of small business failure over time for even one business or in the aggregate, all businesses? We might as well try to discern the Invisible Hand taught by Adam Smith in all the goods and services that surround us. Attempt to banish the twin horribles of failure and the prospect of failure and society will find out quickly that is does not have the wherewithal to underwrite all success. What does that tell us about failure? What phoenix rises from these ashes we call failure, time and again? What is in the economic DNA of almost every success you and I know?...We will find a lot owing to failure, if for no other reason than that failure tends to be such a generous teacher.
  14. Jenkins83, Thank you for your service and I really do wish you well. You might ask yourself some questions: 1) Am I looking for a solution or am I dug in? and 2) Have I noticed others offering ways to fill in the hole and help me (and the customer) move on?...and why would they do that? Its not personal...and It’s a bigger issue to DoD...one of the biggest; Look, we are not immune from the effect of dysfunctional relationships; why should we think we are? We see examples where scarcity problems (turf wars among them) and administrative inertia are liable to chase away many a good solution and leave us in the weeds. I no of no lasting solution to this problem that would avoid focusing on the individual; Each one of us would do well to ask as often as need be, questions fitting two themes: “What is my part in this chase for solutions?” and “How am I doing?” The exact questions and insightful answers to these questions will probably change some each and every day, but the self assessment need never stop.
  15. Mark Zuckerberg made hoped for further developments in AI the centerpiece of his deflections while appearing before Congress last month. When pressed on FB’s own enforcement of community standards...his invocation of AI as a prospective cure seemed to me at best a transparent attempt at political alchemy and at worst an inversion of rational standards of trust. I hope that such superficial blandishments are not a harbinger of things to come. Issues over commonplace AI technology do not strike me as a trivial...these issues call for great care in what we cede knowingly or not, to AI. We may not get a redo in our lifetime. The feedback loop is necessarily the most important part of any iterative system...Just what will happen should AI become “self-interested” and already have a role in many feedback processes? We hold to a chain abounding in weak links...will we catch them all before any one of them breaks...and who is doing the watching?