Constricting Officer

Seriously, they are acting like it is Amazon. Guess your are back to FAR 13 single source as your primary option. $0.00 PO referencing a $30K credit. No worries, it is the end of the year. I am sure the requesting office can find something that cost exactly $30K they don't need to tie this up.

ECAT (dla.mil) So basically DLA created a "Amazon" style ordering system for "a wide range of laboratory supplies and equipment, dental supplies and equipment, optical supplies, orthopedic implants, cardiovascular products, medical/surgical supplies, and medical equipment" and forgot to address what happens to the obligation when you order the wrong item and want to return it? I find it hard, though not impossible, to believe that was not something addressed when setting it up. Maybe I am being overly picky, but why/how did the vendor end up with $43K in their bank account for something we did not accept?

Inherently yes - both complicated and complex. Sadly, if something tied to the government it is more so than needed. With no profit incentive why streamline things and make them more efficient? Doing that might limit @joel hoffman's GS-15 position mentioned above to only a 13 or 14 position and then no extra door for a better attack position for the office coffee pot. With that, it is not as complex or complicated as some make it out to be.

They are fine and I have nothing negative to say about them. That being said, I also do not follow them closely. I work more in a contract management role now than in the past so maybe I will follow more closely moving forward. I prefer a forum of this type (WIFCON) more because it produces diverse backgrounds and viewpoints. I agree, but we need the cut and paste people as well. I believe they are referred to as purchasing agents. "Too many Chiefs and not enough Indians" comes to mind. Where the balance is I have no idea and would suggest changes by the mission, administration and time period. Two "Master" COs and a procurement team can put together a $100 Billion IDIQ and then the "cut and paste" brigade can place DO/TOs against it for 20 years. Perhaps instead of the term OJT, "Masters" should seek out the future "Masters" and train them to take their places. Leave the normal required training and the front line managers to take care of the "cut and paste" group. All are not created equal.

@Vern Edwards - You couldn't possibly be implying that such things can be self-serving and have nothing to do with the actual quality of work being provided - 😁... "Certifications are also found in almost every country. Even the defunct Soviet Union had their own cert — the State Quality Mark of the USSR, which was used to certify that goods produced were of “higher quality. Ironically, the Kremlin would lease the certification mark to factories allowing them to charge 10 percent more for their products — so much for equality of the proletariat."

Sometimes there is/isn't reason or logic. Depends what is needed. Examples: 1 - The requirement is to have a doctor on call to do emergency surgeries for an ER at a VA. Might be a good idea to require a M.D. and five years of experience doing the same. Makes sense and is probably a good thing to require. 2 - The requirement is to have a service employee go through an unoccupied office building leased by GSA and make sure all electrical outlets work. You could require a certified electrical engineer do the work, but is probably good enough to have a kid fresh out of high school walk through with small desk lamp and just have him plug it in and see what happens (Quality Control - make sure the light works prior to beginning).

You said it - SOO RFP! Figured out how to do this for services, why not the acquisition process. I like it. Let them come up with the contract, solution and price for it. Could really cut down on the workforce needed to compete and award requirements. Meets all of the CO's responsibilities under FAR 1.602-2. Probably have to add Past Performance as an evaluation factor, unless you are planning on doing it under 2. Only downside is it would increase cost, but that could easily be offset through workforce reduction. Other than that, guessing the main pushback would be from the agency and office level review policy. Going to be hard to talk a lawyer into signing off on releasing a RFP with no clauses in it.

If we are going to ignore the solicitation, eval and award to SpaceX, we still don't know the type of contract intended (guessing cost), the appropriation type available or the estimated value. The $2B offset may not be enough to outweigh the extensive Past Performance cited for SpaceX by the agency. Not exactly a slam dunk here: From article - "In a letter to NASA Administrator Bill Nelson, Bezos said Blue Origin would waive payments in the government's current fiscal year and the next ones after that up to $2 billion, and pay for an orbital mission to vet its technology." All that being said, if you have a interested and capable competitor in the market that is willing to assume that much financial risk then compete it FFP and see what what happens. Other than that, I don't think there is enough information available to work through this. Sounds good, but Congress can't currently agree that water is wet, the sky is blue and gravity still applies in physics.

Depends on what it is as @joel hoffman pointed out. Some additional details would be nice. A few things could be causing it as well. PCO and client don't get along, one of/both of them are lazy or the government is having a hard time figuring out what they actually want. I mean you could have situation where you have a team on the government side that is locked in and ready to roll and leadership keeps moving the ball on it. Who knows! In person meetings is always best. Everyone wants to, but testing, emails and virtual meetings can let so much context slip through the cracks leading to confusion for all involved. Joking aside, you never know what you will get professionally with the government. Our business model has no profit incentive and you almost can't fire anyone.

Does a prime have a contract? If no (I am guessing), they can do as they please. Need more info.

Part 44 - Subcontracting Policies and Procedures | Acquisition.GOV FAR 44.301 Objective. "The objective of a contractor purchasing system review (CPSR) is to evaluate the efficiency and effectiveness with which the contractor spends Government funds and complies with Government policy when subcontracting. The review provides the administrative contracting officer (ACO) a basis for granting, withholding, or withdrawing approval of the contractor’s purchasing system."

Similar conversation along these lines years back - Evaluation Factors - For Beginners Only - The Wifcon Forums and Blogs.

Based on many assumptions I am making I would not put that much into it. With that, it needs to be tailored as needed for the requirement. Yes. The PWS defines the government's need and any restrictions to which the contractor has to operate within. In this case the required classification level of the facility used. Simply by providing a quotation they are stating they will comply with the requirement in the PWS. How far you want to go into confirming that they will comply during evaluation should help you craft your evaluation factors.

You can, but be careful with your planned evaluation process trying to turn a matter of responsibility into one of responsiveness (See B-290158, Great Lakes Dredge & Dock Company (gao.gov)). If you want. Possibly. I believe the terminology GAO has used in the past has to do with what you are doing (FAR 15) compared to what you said you were going to do (FAR 13). My question for you this - Why complicate a FAR 13 acquisition? Is there something highly complicated about this requirement that would require a complex evaluation? If not, then price, PP and technical should be enough (if that much is needed).

Apologies - fat-fingered a 4 in there - 6.303-1(d). The OP is apparently questioning the practices of the government entity of which they are contracted with.

By "blanket SSJ" are you talking about a class justification (FAR 6.303-1(d))? "All future purchases" is a bit much. A "procurement directive" cannot override USC (41 USC 3304).

Select the contract type and duration that will best meet the needs of government. Forget about the price tag and how it relates to additional oversight. If you produce good work, you should welcome more scrutiny.

No - If they provided a submittal and it was approved it is on them, as long as the government did not do something to prevent them from ordering the material. If they persist, advise them that they can submit a REA. Review it and make a fair decision (yay/nay). In the grand scheme of things, it is only a increase of 6% over the course of 2 years. Sounds like normal business to me. Of course if you want to be a smart alec, you could always ask them if they would have told you if it had went down by 6% and you needed to decrease the contract value.

I am a current member and like the new rule, but as always it comes with the question - "how will it be used?" I can see this being a great resource to the operational employees, lower and middle class members of the workforce (GS-9 through 14). With that, what are the limitations on it? Can a SES leave after 32 years of services, make a killing ($) at Boeing for 5 years, come back at a higher salary for 3 years to determine retirement while tap dancing on Capital Hill? The latter seems less useful to the acquisition workforce and our purpose.

I was going to stay away from this one (no experience with "betterments"), but why not learn something. Thank you for the "Parol Evidence Rule" reference. Never have ran across it and will catalog. With that I will move off of them proposing it and it not being evaluated. That being said, they proposed something and it involved a "price." The government awarded a contract at that "price." If the contracting activity wants to add it to the current scope (within/outside), I don't see how there could be an increase in "cost" to the contractor. Question - If the proposal (what the contractor said they'd do at a price) was incorporated into the award and the SOW (what the government wants) was still there, which one takes precedent?

1. I do not take that stance all of the time. 50/50 during administration I would say for equitable adjustments. The little information present in the OP leads me to this determination. 2. I would never assume the ability to defend common sense to a court or board (or many other humans for that matter). With that, I review request and make determinations based on the information I have at the time. Those determinations are what I believe to be fair, reasonable and in the best interest of all parties involved. Also, if I can't back it up under scrutiny, I won't decide that way.

Within my agency, it is standard practice to use the 1442 on Construction/AE Task Orders from what I have seen. Away from the form used and the SOW (sounds more like a PWS to me - I digress), common sense would say, the contractor proposed to do something and a price to do it. They are not doing more then they proposed and I would not provide them with relief without a pretty good reason.

Quoted many times, but this is the one I have in the file for such matters: Great Lakes Dredge & Dock Company (gao.gov) "A bidder need not demonstrate compliance with solicitation requirements pertaining to its responsibility, that is, its ability to perform as promised, in order to have its bid determined responsive. Moreover, the fact that the IFB called for submission of a permit showing that the proposed disposal site was "legal to operate" as of the bid opening date does not convert the permit requirement into a matter of bid responsiveness. The terms of a solicitation cannot convert a matter of responsibility into one of responsiveness."

Sounds about right!

With no profit incentive to drive decisions, why not... “No government ever voluntarily reduces itself in size. Government programs, once launched, never disappear. Actually, a government bureau is the nearest thing to eternal life we'll ever see on this earth!” - Ronald Reagan