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Gonzo

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About Gonzo

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  1. Agree with Joel about cubes being better than open offices and I like the sound of the office he helped build for the Army HQ. That kind of adaptability sounds very useful. My current office actually just completed the transition from old school cubes that had walls about 5 feet high that completely surrounded you to new-fangled cubes that have walls that are so short I make accidental eye contact with the guy that sits on the other side of the wall from me while sitting in my chair all of the time. It is extremely awkward for both of us. We are also organized in "pods" of 4 people, which means that we all face our respective corners with an open space between/behind us. It's just odd. I'm also skeptical of the cost/space savings. In our case, I suspect it was driven by aesthetic considerations that were papered over with talk of "collaboration" and the "need" for more visitor's seats since we have lots of people coming in from our overseas offices. I've only had an office with a door for about 25% of the time that I've been working in contracts. I definitely miss it. Broke down a couple of months ago and bought a nice pair of noise canceling headphones, which do help.
  2. @ji20874 - I think (a)(4) would depend heavily on what "incidental" means in this context, which is part of my problem. I did some additional reading in the FITARA and some OMB memos and it seems to me that the intent of this clause is to allow the CIO of the department (in this case, USAID) the opportunity to review and approve of any "major" IT purchases that are not explicitly included in a solicitation or award. The difference between a "major" IT purchase and an incidental one is not very well defined in anything that I have read. As mentioned above, my organization will sometimes budget for some laptops or a printer to be used during execution, which I would consider incidental. I think it is reasonable to consider ~$1.5M in phones that are procured to be used in data gathering that will be a significant part of the program to be a "major" IT purchase, but I would really prefer that those terms be clearly defined. I'm also just curious how others have interpreted the clause since it is relatively new. I discussed this with a colleague in compliance and his reading was that we should seek pre-approval (compliance in my org is not contracts focused), but he thought that pre-approval should occur at time of award. Not sure I agree with waiting until award, but I'm open to other opinions.
  3. Hello all, My organization is looking at pursuing a contract opportunity with USAID. The solicitation has been released and it includes LIMITATION ON ACQUISITION OF INFORMATION TECHNOLOGY (DEVIATION NOs. M/OAA-DEV-FAR-18-2c and M/OAA-DEV-AIDAR-18-2c) (APRIL 2018) in Section H. Generally speaking, this clause does not cause concern for my org as our IT purchases tend to be incidental to the contract. In this case, we are considering purchasing a significant number of cell phones (~5,000) to use for data collection and program quality monitoring. My read of the clause is that we would be required to submit a request for approval as detailed in the clause, most likely as part of our proposal submission or at least concurrently. I'm curious how others read this clause and/or have responded to the pre-approval requirements. Appreciate any inputs that you all have. Full clause is below. (a) Definitions. As used in this contract -- “Information Technology” means (1) Any services or equipment, or interconnected system(s) or subsystem(s) of equipment, that are used in the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by the agency; where (2) such services or equipment are ' used by an agency' if used by the agency directly or if used by a contractor under a contract with the agency that requires either use of the services or equipment or requires use of the services or equipment to a significant extent in the performance of a service or the furnishing of a product. (3) The term " information technology" includes computers, ancillary equipment (including imaging peripherals, input, output, and storage devices necessary for security and surveillance), peripheral equipment designed to be controlled by the central processing unit of a computer, software, firmware and similar procedures, services (including provisioned services such as cloud computing and support services that support any point of the lifecycle of the equipment or service), and related resources. (4) The term "information technology" does not include any equipment that is acquired by a contractor incidental to a contract that does not require use of the equipment. (b) The Federal Information Technology Acquisition Reform Act (FITARA) requires Agency Chief Information Officer (CIO) review and approval of contracts that include information technology or information technology services. 81 (c) The Contractor must not acquire information technology as defined in this clause without the prior written approval by the contracting officer as specified in this clause. (d) Request for Approval Requirements: Clauses and Special Contract Requirements for Facilities Access, Security, and Information Technology (IT) (Class Deviations M/OAA-DEV-FAR-18-2c, and M/OAA-DEV-AIDAR-18-2c)8 (1) If the Contractor determines that any information technology will be necessary to meet the Government’s requirements or to facilitate activities in the Government’s statement of work, the Contractor must request prior written approval from the Contracting Officer. (2) As part of the request, the Contractor must provide the Contracting Officer a description and an estimate of the total cost of the information technology equipment, software, or services to be procured under this contract. The Contractor must simultaneously notify the Contracting Officer’s Representative (COR) and the Office of the Chief Information Office at ITAuthorization@usaid.gov. (e) The Contracting Officer will provide written approval to the Contractor through modification to the contract expressly specifying the information technology equipment, software, or services approved for purchase by the COR and the Agency CIO. The Contracting Officer will include the applicable clauses and special contract requirements in the modification. (f) Except as specified in the contracting officer’s written approval, the Government is not obligated to reimburse the Contractor for any costs incurred for information technology as defined in this clause. (g) The Contractor must insert the substance of this clause, including this paragraph (g), in all subcontracts.
  4. My personal experience with telework (as a non-Fed) has generally been positive. As previously noted above, I find it much easier to concentrate at home rather than in the shared office/hoteling situation I was in at my last job. I never knew who I was going to be sitting with and it was a real crapshoot. Some folks were fine, others would spend all day on the personal phone calls. My current work situation is a more or less "open" office plan, which I am not a fan of. I am lucky insofar as the folks that sit around me are pretty quiet, but there is no way to have a discussion, in person or on the phone, without disturbing those around you. Needless to say, conference rooms are in high demand around here. Collaboration can also be an issue, but there are plenty of options out there to bridge that gap. Microsoft Teams, Adobe Connect, Skype for Business and many other IT solutions offer you the ability to see and talk to your colleagues no matter where they are sitting. It is mostly about you and your organization making collaboration a priority and then enforcing it. I worked from home full time for about 6 months and then approximately once a week since then (going on 7 years now) and it seems to me that it all comes down to the individual and their management. Work flexibility shouldn't be a given, you should have to prove to your supervisor that you can handle it. My last two jobs had a 6 month no work from home policy followed by managers discretion and in both cases I proved to my supervisors that I could be trusted. When pinged on IM, I answer right away. They never receive complaints from the teams I support, because I do my job when I work from home, along with some laundry . At this point, I work from home when I need/want to. I generally keep it to no more than once a week because I both value and require time in the office in order to do my job well. Several of my colleagues work remote full time and, generally speaking, they are top notch. It certainly won't work for every position or every person, but it's a low cost benefit to provide that most people appreciate and use wisely.
  5. Hi Neil, FAR 52.244-2 is included in USAID prime contracts. One interesting wrinkle between the DOD and civilian worlds that I've heard is that civilian agencies are now being audited by accounting firms rather than DCAA due to the backlog of audits. Curious to see how that is going to work in practice and whether or not it's a "good" thing. Here_2_help: Those are good points and I very much agree with your final point about process and training being keys to success. One of the big issues I am confronting is simply unfamiliarity with proper procurement procedures. People really just don't know the difference between assistance sub-recipient agreements vs. acquisition/procurement subcontracting. There is no "contracts culture" here to speak of, so I am going to have to determine the current state (almost there) and then define the future state, and then I am going to have to really train people up on basic contracts process and compliance knowledge. The good news is that the volume of proposal opportunities is relatively low, but that's a double edged sword because it's "in one ear, out the other" if people aren't consistently applying the knowledge and skills. It's going to be a big challenge. My colleagues are all smart, competent professionals, but this is just a whole new world for them.
  6. Patrick, Appreciate the quick response. We have not been notified of a CPSR yet. We are targeting a couple of large USG contracts opportunities in the next fiscal year, so I am trying to lay the foundation now before it becomes a panic post-award/once a notification is received. The good news is my predecessor did a decent job of getting some policies in place, but lack of use and general disinterest from leadership in the past means that they are pretty bare bones and our institutional "muscle memory" in implementation is very weak. I am curious about the consultant route and will likely look into it to determine if it is a viable option. We have the added challenge of also trying to build out our capacity for contracting with overseas entities as well, so resource limitations may play a part in how we proceed.
  7. Hello all, I have recently moved from a DoD contractor to an NGO without an Approved Purchasing System. This has not been an impediment for them, as they have only performed as a subcontractor under a handful of USAID prime contracts. However, there is interest in expanding their contracts portfolio and a desire to move beyond subcontracting into prime contracting. As that is the case, I have begun the process of determining how prepared we are as an organization for a CPSR audit. So far, it looks pretty grim. Little to no file documentation, no price/cost analysis being performed, policies and procedures exist but are likely insufficient or require revision, etc.. My question for the forum is: what is a *reasonable* estimate of level of effort to get a large (~$900M per year) NGO in a position to not get blown out of the water by a CPSR auditor? My extremely conservative estimate right now is 500 hours spread out across the org, but I think that is probably too low. Does anyone out there have experience in doing this? I know there are a number of consultancies out there that specialize in this, but as a non-profit that is already cost adverse due to some large IT investments in recent years, I suspect that leadership is going to want to keep this process in house as much as possible. Any and all feedback/advice/etc. would be appreciated.
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