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General.Zhukov

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About General.Zhukov

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    Strelkovka
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    Deception & surprise, combined arms maneuver to encircle and destroy the enemy, T-34-85 Soviet Medium Tanks.

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  1. I have no idea about pricing other than I agree that it its a tough one, but here is another ossible source for comparison: In HHS, the Indian Health Services (IHS) does contracting for direct provisioning of health care over a very wide area. IHS is tiny, so its contracting is a lot easier to understand than, say, the VA.
  2. To further hijack this thread---- The IBR rule in the FAR Clause Matrix is an anachronism. In practice, only the 52.252 clauses must be in full text. Nothing else. Especially not 52.212-3. I typically maximize IBR for commercial orders, simplified, etc. There is something embarrassing about issuing a 17-page purchase order for a copier. And the contractual requirements in those clauses are very, very rarely relevant post-award. Its unlikely Convict Labor will come up with that copier. More complex or risk contracts, FAR 15 contracts, are different. I could see going crazy with the full text for those.
  3. yes, appropriate. However, conference calls are iffy. I would check with the vendors about it before proceeding. Sometimes they are reluctant to say anything within earshot of their competitors. Even their presence on the call- identifying themselves as an interested party - might be something they want to keep private.
  4. Well, if it were me I wouldn't put out an RFQ like that in the first place. But for vaguely defined requirements, I usually have non-cost/price factors be much more important. If I think the prices used for award do not accurately represent what actual costs are likely to be, I discount them in my decision. So in this case, I would likely select Offeror A regardless of whether the GVT or offerors pick the hours. In my field of IT services I see this very frequently. Its not due to anyone's failure to do their job. Its often the case that neither GVT nor contractor can with much confidence estimate the particular outcomes, schedule or overall cost of an IT project. There is a whole contracting cottage-industry devoted to solving this problem - Agile, Digital Services, 18F, Kessel Run, DIB's very long white paper about DoD software, etc.
  5. When the requirement is poorly defined, offerors are just guessing at the LOE in their approach. If its for poorly-defined labor-hour work, then offerors are both guessing about the LOE and their guess isn't binding in any meaningful way - which is a huge incentive to low-ball. During evaluation, the CO has to deal with these theoretically low-priced offers through trade-offs or price realism. Price realism analysis is a waste of time - we don't really know if any offeror's LOE is, in fact, realistic. Trade-offs then ends up ironically comparing these prices as if they mean something. Example RFQ: Paint my house. I don't know how many square feet it is. No, you can't do a site survey. No, I don't have any pictures of it. No, you can't ask me any questions. I'll pay by the hour. I think it will take 20 hours. You have to write me a 10 page description of how you will paint my house, including how many hours it will take you and your hourly rate. By the way, It doesn't matter how many hours you propose, since I'll just pay you until its done. Offeror A: I am a professional house-painter with 10 years experience. I propose 20 hours, at $20/hr. "$400." Offeror B: I painted a few houses last summer. I propose 15 hours at $20/hr. "$300" Contracting Officer trying to write a source selection decision that justifies why Offeror A is worth the entirely-notional 33% premium in price: I need to update my usajobs profile. There are many methods to avoid this situation, but probably the lowest-effort method is fixed labor categories and hours.
  6. Yes I suppose, but its not a big deal. The objective of analysis is to ensure the final price is fair and reasonable. There are seven types of analysis listed in FAR 15, cost and price being just two of them. This analysis is required but most of the times its actually much more simple and common-sense than it appears in FAR 15. Price Analysis. Say you want to buy some software. The company sells their software on their website for $10. You ask your friend who bought the same thing last week. She says she also paid $10. You have just determined the firm-fixed price to be fair and reasonable through price analysis per FAR 15.404 (b) (2) (ii) and (iv). Cost Analysis. You want your house painted. A painter says he'll do it for $8,000. $5,000 labor and $3,000 paint. That seems like way to much $ for paint for your 2,000 sf house . You estimated you'd need maybe 10 - 20 gallons and the very best paint costs $80 a gallon. You were expecting at most $1,600 for paint. Too expensive. You have just determined the firm-fixed price to not be fair nor reasonable thorough cost analysis per FAR 15.404(c)(2)(i).
  7. I know. Its incremental improvement in the face of constraints. There is a whole team of folks who need to approve of evaluation methodology. Evaluators who have to understand what they are doing. I am no expert in the subject, nor is the program office particularly knowledgeable about contracting. Institutional risk-aversion (not necessarily a bad thing). Etc. I would actually really be interested if there is any research about the connection between source selection methodology and contract performance. Such as - what information can we get pre-award that predicts good performance. I only know of folksy wisdom about past performance and competition. I am joking, but not really - is there is any actual high-quality research on the subject?
  8. Caveat: I do IT services, and my informal method may not work for different types of contracting - like supplies with incidental services like delivery or maintenance, services covered by SCLS, construction, etc. The informal method I use If the contractor shall be physically present at a gvt-facility, at any time to do work (even briefly, like for meetings) , to be compliant with the contract, then the work is at least partially on-site. For my contracts, this is very important since requiring any type of on-site will probably limit competition to the local area, or we will need to consider travel costs (ugh). If the contractor being on-site at any time is recommended, or encouraged, or a good business practice, but not a matter of compliance - then I do not consider it on-site. Edge cases I'm not sure about - If our solicitation or contract is silent on the matter, but the contractor's proposal states they will be sometimes on-site. the requirement cannot be met without the contractor being on-site at some point.
  9. Fun fact for those of you who like to get down into the FAR weeds. GSA's Schedules are by definition commercial, at least Schedule 70. GSA recently added 'Order Level Materials' (OLM) as a feature. Order Level Materials procedures may be used to purchase OLM products or services to support delivery orders (products) or task orders (services) under authorized GSA Schedules. OLM must be a separate Time & Material line item on the order. I take this to mean GSA approves of me issuing a commercial Schedule 70 order for commercial supplies, with a T&M line for OLM which are commercial supplies. Implying GSA is cool with use of T&M for commercial supplies.
  10. No, the plain language of the FAR excludes commercial supplies from T&M contracts. In my personal opinion is that T&M is of little use (or maybe entirely useless) for conventional supply procurements, but I don't see the harm. However, my intuition is that the original poster's contracting office probably doesn't know or doesn't care about this. High volume contracting shops aren't concerned with the nuances of the FAR, particularly if it makes the customer happy, isn't obviously unethical or illegal, and isn't audited. I think this type of thing is the norm. My Department (HHS) has a departmental clause that, I am convinced, is universally ignored.
  11. This has been done. The Army had a pretty slick clause picker called Clause Logic Service, but sadly its gone now, or behind a firewall.
  12. I am using DHS's concept of Prior Experience instead of the usual Relevant Experience or Past Performance. https://hallways.cap.gsa.gov/app/#/doclib?document=17951 For a agile software development RFQ my instructions are for offerors to answer our questions, rather than have them write a so-called technical/management approach. Questions (slightly modified here) are: 1. What is your management process for this order, including working with the Product Manager, COR, and End Users to capture and size user stories, prioritize, and work-off the product backlog? 3. What is your definition of done? 5. What is your anticipated velocity? 6. What is your quality management plan for [something] 8. How do you plan on allocating work between the teams, particularly between [X] & [Y]? Page Limit: 5 Pages.
  13. PM - Jack of all trades. CM - technical expert. Example of Why Contracting Technical Expertise Matters: The contract says work is performed on-site and it has been, but due to a long-planned facility repair the COR didn't know about, the building won't have enough space starting next month. The COR is saying most of the team will have to work either at a contractor-facility, or a different GVT building 15 miles away. What are your rights here? The PM won't know, but a good CM will. Contracting Officers have the power to make life miserable for the contractor, so know your CO and be on good terms with them. That is, or should be, the job of the CM. Example of the difference: CM: Why are my invoices being rejected? Friendly CO: Let's find out why, and what to do about it. A not-friendly CO: Invoices are non-compliant with the Section G. Invoicing Instructions, and/or FAR Clause 52. 212-4. Submit a trouble ticket to the Payment Office.
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