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About FrankJon

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  1. H2H - You're missing my point. I do not suggest that the duties are distinguished anywhere. My point is that there is an opportunity for agencies to change the prevalent - and I say ineffective - "cradle to grave" practice through policy change. An obvious way to implement this is via the CO's warrant. The duties can be whatever OFPP/DPAP/HA/SPE/HCA (or whoever is delegated ultimate authority to decide) decides. COs would be able to change between ACO and PCO as agencies permit, but they would not be able to serve as both simultaneously.
  2. Promote specialization by narrowing the CO scope of authority. Begin by eliminating the "cradle to grave" approach. Warrants would specify whether the individual is a PCO or ACO, and enumerate the high-level duties associated with that role.
  3. What is a procedure?

    In my view, a procedure in Federal contracting is a set of rules under which you solicit and award a contract. Usually this means either FAR 8.4, 13, 14, 15, or 16.5 procedures, and FAR 12 procedures may be used in combination with 13-15 (for some reason, the correct application of FAR 12 remains an enigma to so many 1102s). In your case, your colleague was using FAR 13 procedures, and therefore must abide by all applicable rules under that part. The fact that a technique was borrowed from a different FAR part does not change the equation; in fact, borrowing evaluation techniques from FAR 15 and other FAR parts is expressly allowable pursuant to FAR 13. The risk here is taking things too far - borrowing to the extent that you give contractors the impression that you're effectively utilizing a different set of procedures than what you state. In that case, GAO has found that you could unintentionally convert your procedures to a different set of procedures.
  4. I strongly recommend editing your post for brevity and clarity if you're looking for serious responses. I think you're misunderstanding SCLS, but it's really hard to tell from your post.
  5. Has strategic sourcing gone too far?

    jonmjohnson - Thank you for your thoughts on the topic. Actually, we do at least attempt to do this in the cases I've seen. And this is almost guaranteed to occur when consolidation is involved. Granted, the estimates are often crude and agenda-laden. Would a vehicle that encourages bureaus to coalesce through tiered, quantity-based unit price ceilings obviate this concern from your perspective? I don't agree with this conclusion. I agree that BPAs don't necessarily achieve the purpose of public sector strategic sourcing, but I think they can. Take a single-award BPA with price ceilings. The BPA awardee is confident that it will have all or most of any agency's business in a certain sector over a certain period of time, and might therefore be incentivized to offer lower prices to guarantee that business. How is this concept different from any other public sector strategic sourcing initiative, such as GWACs and the MAS Program? Yes. Thank you.
  6. Real Contracting Pros

    Vern - Junius was referring to public perception. Although certainly there's an argument to be made that within Government, top performers are not sufficiently recognized and incentivized. Simple appreciation is not sufficient unless it is relayed to the employee in a consistent and meaningful manner.
  7. Even if there were a way to submit "through" FBO, which would be news to me, you always want to follow the solicitation instructions precisely. If the solicitation states to submit by email, and provides an email address, then you would send to that address, not to an intermediary. This is usually what the Government means by "electronic response," but that's besides the point. Just follow the instructions to be safe.
  8. FAR 52.222-50 , Form X37101?

    It looks like that form number is specific to Boeing. Ignore that part of the question. Respond to whether you have filed the annual certification.
  9. Has strategic sourcing gone too far?

    apsofacto - DPAP defines strategic sourcing as follows: In this regard, what I am seeing is strategic sourcing because the vehicles are premised upon department-wide spend analyses. Does that answer your question? My concern that you highlighted above refers to the manner that the vehicles are established. The acquisition office takes the lead, performs the spend analysis, and queries the requirements community in piecemeal fashion. It then puts together a patchwork of ideas (usually based on incomplete data) that it believes are technically sound and best fulfill existing needs. The requirements community then gets a final review before the solicitation goes out, but at that point, things are mostly baked into place. It would take chutzpah and clout to stop and uproot everything at that point. A more sound approach would be for the requirements community to drive the requirement through a POC that works in tandem with the acquisition office. In this way, the experts would be the ones to gather the relevant information, project their needs, and craft the requirement, resulting in a stronger, better planned, more efficient vehicle.
  10. Has strategic sourcing gone too far?

    Oh, since I'm on my proverbial soapbox, here's the other thing I get at my agency : A CO creating enterprise-wide solutions who refuses to allow BPA orders to extend beyond the life of the BPA. All that time and effort....
  11. Has strategic sourcing gone too far?

    Boof - I'm really talking about agency-level BPAs and IDIQs here, not governmentwide BIC vehicles. Actually, I think BIC, particularly for commercial items, makes a lot of sense on some level. We are one Government, after all, and acting as such would clearly be the more efficient option than what we do now. With respect, I also get a little tired of listening to COs who jealously guard their discretion like it's a sacred right. By and large, I'm much more likely to trust a vehicle premised on a governmentwide spend analysis than I am on a CO's intuition that she knows what's best based on comparatively limited market research. Now, what I'm getting at my agency is COs who insist on layering multiple-award BPAs over those BIC solutions. And we're talking COTS here - items that can be purchased rather efficiently using LPTA. Because these BPAs are worth hundreds of millions of dollars, and because the CO insists that trade-offs will be used to establish the BPA pool, we are spending potentially thousands of man hours putting these in place. It's like agencies and COs can't leave well enough alone. They insist on having control over something that they can call their own because their thing will somehow be "better." Maybe it's human nature. I can't help but thinking we're just guinea pigs on a wheel - we pat ourselves on the back at the end of a long year, feeling like we accomplished something, when really it was wasted effort for the purpose of justifying our existence. (And the guinea pigs are in better shape than us at the end of the year, to boot.) Bob - I'm glad to hear that you came to your senses, went to the Honda dealership, and purchased the 2018 Fit. I love mine, too!
  12. Has anybody else noticed the proliferation of agency-level strategic sourcing initiatives that seem to be of dubious value? Examples include vehicles that overlap significantly or completely with existing vehicles; vehicles under which the first order will use up the vast majority of the ceiling or estimated value; and vehicles championed primarily by the contracting community, that receive relatively little input from the requirements community. My cynical side believes that some COs do this to put feathers in their caps and zeroes on their resumes, but I'm interested in hearing others' experiences and views.
  13. Walk of Atonement?
  14. Reinforce the responsibilities and authorities inherent to each Acquisition Team role. By each role-holder staying in his or her lane, the idea is to increase specialization and reduce dependency on other roles that may not be best-suited to perform certain duties (e.g., requirements community on the CO, the CO on OGC). Increased specialization would bring increased efficiency. Ancillary idea: Dispel the significance of "customer service" in Federal acquisition, which has gotten to the point of performing the duties of others without second thought. Individual acts of "customer service," though they may create short-term efficiencies and inter-office harmony, can result in enduring dependencies that cause long-term damage.