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Vern Edwards

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Everything posted by Vern Edwards

  1. Or maybe he's not communicating what he wants. What does "how" mean? What does he want to know? Process? Procedure? Method? Technique? Means? Something else? Everything? "How" is a vague word. Without some specifics, offerors can't be sure what he wants.
  2. 😆 How dare I? How could I not? You didn't give a coherent peer review. It was close to nonsense. And to think I devoted precious time trying to clear things up for you! Hmph!
  3. @C CulhamI'm sorry about that. I thought it was a simple illustration. I'm not sure I can dumb it down any further. But try this: Bucephalus was a magnificent warhorse, large, strong, brave, and fierce. Alexander was a daring tactician, fearless warrior, great horseman, and the only man able to break and ride Bucephalus. The objective was victory. Each was valuable in their own way in that pursuit. The value of the whole was equal to the sum of the values of the components. Together, they were an unequaled victory machine. Never defeated. Alexander on another horse, or Bucephalus under another rider, would not have been as great. If that doesn't add up for you, don't bother to tell me, because I can't do better.
  4. @REA'n MakerIt's not a sin of any kind, mortal or venial. But it's not sound practice. As in all decisions involving multiple objectives, the task is to (1) identify the attributes of the alternatives you are evaluating that will be useful to the pursuit of acquisition objectives (have "value"), (2) assess each alternative's performance on each attribute, (3) integrate the findings on diverse attribute scales to a common value (utility) scale, (4) compare and rank the alternatives. Decision scientists have worked on that task for decades and developed sound, widely-practiced methods. They go by various names, such as SMART (Simple Multiple Attribute Rating Technique), SAW (Simple Additive Weighting), and Analytical Hierarchy Process (AHP). You can read about them in books like Decisions with Multiple Objectives: Preferences and Value Tradeoffs (a classic); Advances in Decision Analysis: From Foundations to Applications; Decision Analysis: Introductory Lectures on Choices Under Uncertainty; Foundations of Decision Analysis; Decision Analysis and Behavioral Research (based on Navy-funded research in decision making; another classic, but technical); Value-Focused Thinking: A Path to Creative Decisionmaking (good discussion of attributes); A Science of Decision Making; Smart Choices: A Practical Guide to Making Better Decisions; Decision Analysis for Management Judgment (very clear and practical); and Multiple Criteria Decision Making: From Early History to the 21st Century; all of which are on the bookshelf behind me as I sit typing, and many more, not to mention countless and widely-available research and practical-application papers, such as SMARTS and SMARTER: Improved Simple Methods for Multiattribute Utility Measurement. The government funded much of the research that went into those books, but it didn't tell their contracting people about it or provide them with decent education and practical training. Ignorant contracting officers—who haven't, don't, or won't read such books, because they don't know about them or because they're hard reads—speculate and pontificate based on half-baked OJT (training by rumor and innuendo), and then spread their ignorance to trainees entrusted to them. And so it goes.
  5. I don't understand that question. What do you mean by "compartmentalizing"? Do you mean focusing on approach when you evaluate approach?
  6. Source selection should be considered a medical specialty. Don't go to podiatrist for brain surgery.
  7. The FAR does not address that issue. It doesn't even come close to addressing that issue. Not a whisper of a hint.
  8. On a ranch, they are components of something else—a working team, which has its own attributes. You can evaluate the horse, or the rider, or the team. Which is it? In an RFP you must state what it is that you are evaluating. The answer to Sam101's question is that if you state that you are evaluating an "approach", then evaluate it based on its own attributes—the characteristics, features, properties, and qualities that make it what it is.
  9. @Sam101I have a different take on this than the others who have responded to you. If you think there is value in requiring each offeror to describe its proposed "approach" to doing the work (whatever that is—process, procedure, method, technique) then the attributes of the approach itself are what matter and what you should measure or assess, based on appropriate standards. "Blurbs" about experience are just part of a sales pitch and should have no bearing on the determination of the strengths and weaknesses of the approach. It's the inherent soundness of the approach that should matter. The experience of the user is a separate consideration. The merits of a horse are determined by the horse's attributes. The merits of the rider are something else.
  10. Cancel the procurement, start over, and find someone who knows what they're doing to conduct it.
  11. @Freyr One thing is to decide whether to solicit offers or quotes in simplified acquisitions. Note what Prof. Nash had to say about that.
  12. The RFP for the concept development acquisition, W56HZV-20-R-0142, is one of the worst I have ever seen.
  13. @FreyrYou should be careful about communicating with the offerors (quoters?). I have attached an article by Prof. Nash from this month's issue of The Nash & Cibinic Report, in which he discusses the GAO's handling of protests of simplified acquisitions. He discusses issues that have arisen about government communications with quoters. I think the article is on point with your situation. If you decide to talk to Offeror B, you should think about how to be fair to Offeror A. SIMPLIFIED ACQUISITION Keep It Simple.pdf
  14. Have YOU searched beta.sam.gov? What will you pay for the service?
  15. "Remember"? Remember from when? Where? On what is that proposition based? Where does it say that in FAR? If not in FAR, where else?
  16. Go here https://obamawhitehouse.archives.gov/sites/default/files/omb/memoranda/2013/m-13-10.pdf Read. Then go here https://www.govinfo.gov/content/pkg/FR-2013-06-21/pdf/2013-14614.pdf Read. Then go here https://www.lexology.com/library/detail.aspx?g=9c86071c-4432-4b84-b6a6-7b1954e2e08c "New procurement rule is intended to limit the Government’s acceptance of standard commercial terms of service for social media applications" Read. @Witty_Username Keep in mind that the people who write the FAR are neither thoughtful implementers of policy nor procedural practitioners. They just scribble and move on, leaving it up to you to figure it out. So put it all together and figure it out.
  17. Very ambitious technical requirements. Not promising. The 171-page concept design phase RFP is now available at beta.SAM.gov. Just search for OMFV. DOD still lacks the simplicity gene—there are 74 attachments. They plan to award up to five firm-fixed-price contracts, incrementally funded. Typical bureaucratic source selection. They want "narrative" "approach" proposals, of course. DOD can't be taught and never learns. "Speed of relevance" my ***. Given our country's dependence on contracts and contractors, competitive proposals "best value" contracting as practiced today is going to be the death of us. No, I would not accept the job as program manager on the OMFV. They'll get someone to do it. There will probably be three or four of them over the course of the next six years.
  18. From the GAO Red Book, Ch. 5, E. Effect of Litigation on Period of Availability: The actual statute, 31 USC 1558, reads as follows:
  19. The FAR doesn't "work" in that regard. It does not address that issue. Funds are not "awarded." They are obligated. If de-obligated, they might not be available for new obligations. Go to the GAO Red Book and read Ch. 5, Availability of Appropriations: Time; D. Disposition of Appropriation Balances; 3. Expired Appropriation Accounts.
  20. Well, it makes sense to have the IG do it, and it will give the CBCA more to do. And if the IG decided to contract for the services, I'm pretty sure they'd use the tradeoff process and pay for the "best, most expensive people." 😏
  21. Anyone who asserts that there is no such thing as an acceptable level of risk doesn't understand risk. As a member of the Society for Risk Analysis in good standing, I can assure you that if there weren't such a thing as an acceptable level of risk no one would ever leave their house. I know Steve's paper and have quoted it. I don't recall him saying that there is no such thing as an acceptable level of risk. But it's been a while since I have read it, and I'm not going to read it again. So if he did say that, please cite the page, and I'll pull his chain the next time I see him. I read the DOE IG report as complaining about the independence of auditors. I don't recall the IG saying that the government should hire the "best, most expensive people." That sounds like an argument against contracting for audit services. I admit that I have only scanned the IG report, but it read to me like a recommendation to expand the IG office, not to contract for audit services. Is that how you read it?
  22. @here_2_helpActually, I'm not going to tell you that a good solicitation would address that risk. Instead, I'm going to challenge your premise that the government needs "the best, most expensive people" to staff routine incurred cost and CAS compliance audits of government contracts. I don't think so. I think we need only reasonably competent people. I would be fine with "junior folks plus a couple of managers." Who does DCAA use? What level of quality does the government get from DCAA? I don't think incurred cost audits of government contractors require the same level of expertise as audits of publicly-traded international business firms. Do you? I don't think DODIG or DCAA audits are at that level. I used to negotiate IR&D and B&P ceilings for DOD and NASA, and worked closely with DCAA auditors of companies like Rockwell International and General Electric. I know what kinds of audits we got. I don't think anything has changed much. So why must audits performed by contractors be at that level? What risk? That the government might inadvertently pay some amount of unallowable cost? That happens under DCAA audits. I'm not saying, "Good enough for government work." I'm saying that an incurred cost or CAS compliance audit of Boeing or Lockheed is not as demanding as the internal and external corporate audits of those firms and firms like Amazon, Facebook, or Microsoft under, say, Sarbanes-Oxley. So, why am I wrong?
  23. Why not? I don't have much practical knowledge of auditing, but it seems like the SOW would not be hard to write. There are well-defined and long-established commercial standards for auditing, aren't there? There's your performance work statement. Firm-fixed-price contract? Cost-reimbursement?Time-and-materials? The key would be to identify qualified CPA firms that are experienced in the application of government cost principles and cost accounting standards. If we could price each individual audit FFP, I think I could hire a competent auditor through sealed bidding in a very short time. Certainly through LPTA. I think that we could establish special responsibility standards IAW FAR 9.104-2. Am I wrong? Why should we pay premium? We're not talking about rocket science. Are we? No lives at stake. Are there? The biggest problem would be: Who would perform contract quality assurance?
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