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About FrankJon

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  1. Appreciate the robust discussion on this. I work in a defense agency under USD Intelligence and Security. According to my policy people apparently Defense Pricing and Contracting has specified that USD Acquisition and Sustainment is the waiver approval authority, although I’ve seen nothing explicitly stated in writing to this effect. My policy people further interpret the *emergency* waiver authority to be the Director of our agency, based on the fact that that language refers to the “head of the agency” vice “head of an executive agency.” We’ve encountered another ambiguous
  2. Yes, these definitions exist under FAR Part 2 but they don’t provide context into what is meant by “head of an executive agency.” The FAR is written for and applicable to all executive agencies (1.101). Assuming the use of the word “executive” carries meaning here (I’m not convinced it does), what could that be?
  3. Happy FY end, Wifcon! (Almost...) FAR 4.2104, which implements the Sec. 889 waiver process, alternately refers to the “head of the *executive* agency” (for standard waivers) and the “head of an agency” (for emergency waivers). Is this a distinction without a difference or does the word “executive” carry special meaning here?
  4. Former friend of Wifcon PepeTheFrog and I used to discuss the value of an NCMA certification and ideas for improving the experience (we both received our CFCM around the same time). We both thought the exam itself was a poor measurement of knowledge and ability. It’s an exercise in rote memorization and the relevance of the material is questionable. Its value is mostly in getting your name to stand out among large pools of resumes. It shows you have some level of dedication to the contracting field because you’re willing to invest your own time and money into your development. (Altho
  5. I've seen more than one "old school" CO say this. I think it's a silly vestige based on how IDIQs and BPAs were traditionally "supposed" to be used (i.e., supplies, brief tasks). They can't get comfortable with the idea of separate 5-year contracts springing forth. They stopped updating their acquisition knowledge at some point in the 90s, and they're trapped there until they retire. Same ol' story, different day...
  6. For those who are interested in this topic, OUSD(A&S) provides this explanation within its new Adaptive Acquisition Framework site: Source:https://aaf.dau.edu/aaf/services/references/
  7. FWIW Virtual Acquisition Office did an Advisory on comparative evaluations a couple years ago. Those with a subscription may want to take a look to get a fresh perspective on the discussion.
  8. On January 10, DODI 5000.74 was canceled and reissued. Does anyone know of an online explanation of what has changed? In the alternative does anyone know where the prior version may still exist to compare and contrast?
  9. I think you might need an agency policy to do this. I agree, it would be useful if possible. I have a feeling you'd still want a J&A. FAR 13.203(a)(1) contemplates micro-purchases being distributed among vendors. If that's impossible because there is only one vendor, I think that merits justification. (At least as a CYA.)
  10. The intermediary is not a required source. It's a nonprofit organization with a network of partners and affiliates. The sources are not government orgs. They're institutions. I'm not the CO, but I don't think the intermediary is prone to negotiate. The entire ordering process appears to be highly standardized per the intermediary's website.
  11. Let's assume we go the BPA route. We would have an executed J&A for all calls thereunder. Each call (an email) would be under the MPT, so synopsis requirements would not apply. Calls could be grouped together and billed for monthly against an order created in the contracting system. Is there a problem with this approach?
  12. Intermediary is the only contractor. Sources are not subs to my knowledge; they're independent entities that have a separate agreement to provide records through the intermediary. Good point about the individual order limit.
  13. By "open market" I mean not on an established contract. It will be sole source.
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