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About FrankJon

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  1. Gns & Gordon - I appreciate you pointing this out. I was not familiar with this case or the broad interpretation of "responsibility" within the applicable USC section.
  2. Vern - Thanks for the reminder on Sevatec....
  3. Gordon - Because the rates have been capped at the BPA level below the GSA level. We don't want to exert any additional price pressure, which might affect quality. Vern - Thanks for the recommendation, and perhaps you're right. I feel that I have "DSFHW" (that one took me a second...) and I generally feel good about the approach. I'm simply anticipating my uphill slog, and seeing whether I can rebut critiques.
  4. Gordon - The problem with trade-offs for an 8.4 procurement is that the method is typically a lot of writing and difficult for the customer to write to (this is the experience within my office). I believe that moving to "direct comparisons" would allow the customers to write in a way that they're more comfortable with, thereby making the process more efficient.
  5. Don - I am referring to "streamlined" or "simplified" evaluations under 8.4, 13, or 16.5. I cannot recall ever discussing an evaluation method other than LPTA or trade-offs within a DAU classroom. In my experience, the vast plurality (and possibly majority) of the curriculum, beginning with CON 090, is focused on FAR 15.
  6. Pepe - That was a transcription error on my behalf. The BPA reference is cited correctly as "8.405-3." Yes, I will have to follow the procedures for BPA calls in excess of the SAT. Is there a particular sentence within that reference that you want to draw my attention to?
  7. C Culham - There is nothing in the BPA terms that stipulates the evaluation process for call orders, apart from "IAW FAR 8.504-3."
  8. Somewhat related tangent: The real shame is that DAU doesn't teach this stuff as part of its core curriculum. The vast majority of their content is focused on non-commercial FAR 15 procedures. I can't tell you how many time I've raised my hand in class to clarify how an issue might change in a commercial environment, and was met with blank stares from the instructors. We are constantly being told by senior DoD leaders and policy directives to "innovate" and to work "smarter not harder," yet our formal education does nothing to reinforce these maxims. Instead, entry- and journeymen-level 1102s are often forced to put themselves out on a limb in order to try something different.
  9. C Culham - Thank you for your reply. The BPAs are already established; this is a competition I am holding among five BPA-holders. While I don't think I agree that terms like "factor, pass/fail and risk" make this "almost like FAR Part 15," I do agree that there is likely room to make this even simpler, yet that may not be feasible at this time. I think it might be helpful if I explain that in my office, it's just me (and perhaps a couple of other quiet warriors) trying to convince about 130 other 1102s and several attorneys to do anything other than LPTA or trade-offs. I am not a supervisor, nor have I ever held a warrant. Few in my office would dare to do something that could be seen by OGC as "cutting corners," thereby increasing protest risk (case-in-point: the award decision for the BPA I am competing this requirement under is 200+ pages). Other than Wifcon, I really don't have many outlets for testing ideas, pushing boundaries, or trying to effect cultural change. I am grateful that I was able to convince my current CO to try something new, but this is uncharted territory for him, too. I am doing my best to persuade others, but without any senior 1102s to guide me or provide cover, incremental improvements may be the best I can hope for.
  10. As a follow-up, my biggest challenge with this has been wrapping my head around the "direct comparison" technique. After years of conducting trade-offs against objective criteria, it's difficult to switch gears and do something that is antithetical to everything I was taught. I would especially be interested in hearing about the experiences and advice of others in this regard.
  11. Wifcon Community - I am seeking critical feedback for my planned evaluation approach. I want to ensure that I have my ducks in a row before approaching Legal with this. This method is based upon a mix of Vern's past posts and the Sevatec holding. Thank you in advance for your assistance. OBJECTIVE: To utilize an evaluation scheme that is more streamlined, intuitive, and flexible than trade-offs, without increasing protest risk. If this works as intended, I would apply it (or some variation) to most of my future service procurements competed under FAR 8.4, 13, or 16.5. CONTEXT: Competitive BPA call pursuant to 8.4. Four FTEs to provide consulting and management support services. Utilizes PWS and exceeds SAT. EVALUATION METHOD: Factor 1: Quote acceptability (compliance w/ T&Cs, in-scope, etc.). (Pass/Fail) Factor 2: Personnel qualifications. (Pass/Fail) Factor 3: Risk - Combination of personnel experience and contractor past performance. (I advised against including PP being that this is a BPA call, but my customer insisted.) Factor three will be evaluated through direct comparisons of quotes. Quotes will be ordered from lowest to highest performance risk. Price will not be a factor, since the Government is willing to pay up to the ceiling rates. Award will be made to the contractor that passes Factors 1 and 2, presents the least amount of performance risk, and quotes a F&R price.
  12. Thank you again, Vern. I think this clarification was needed. I'm going to take some time to digest all of this and see if I can't convince a bold CO to try something new...
  13. Todd - I would say it's a mix of older and younger. My agency is pretty close to the flagpole, as they say. COs are generally leery of running afoul of OGC and PMR guidance, which is generally incongruous with exploiting efficiencies and experimenting.
  14. Vern - Thank you for the thorough response. ji20874 - Thank you for the GAO decisions, which I will review. You are absolutely correct that historically, I have not worked with many COs fully comfortable with using SAP, particularly when over the SAT. When I say that this approach seems like it could be trickier to write to than a traditional trade-off approach, it could just be due to my lack of familiarity with a comparative approach. When I've done trade-offs in the past, I initially compare each proposal to fixed criteria specified in the solicitation. It seems like there would be less risk for error in that situation than when directly comparing proposals to one another, since the proposals may not align and may not be using the same language to discuss the same things. The latter seems like a moving target. But maybe not. Maybe it's just a matter of familiarizing myself and trying it. Thanks again.
  15. Oxford Comma

    As recently as 2008, Villanova Law School was teaching its students to omit the Oxford comma. I do not recall whether that came from our style guide or was the school's preference. In retrospect, it seems like a strange thing to teach law students, who should be more interested in clarity than character counts.