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About cogp2

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    Fairfax, Va

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  1. I appreciate all comments. Discussion helps frame a strategy. Additional info: Non-mfgr rule does not apply. A couple years ago, DLA asked SBA to invoke it, but we demonstrated to SBA that would limit Sm Bus awards. SBA declined to issue the ruling. Marketplace is characterized by 2 large mfgrs, 2-3 small mfgrs and many dealers, mostly Sm Bus. 1 large mfgr is the 800 lb gorilla and has name recognition like Coca Cola, Kleenex or Xerox... RFQs are almost always for a Qty of 1. Item is relatively high unit cost, long economic life, and is bought infrequently by same contracting office. (Xc for DLA who has commodity responsibility; many agencies do not use DLA.) We seldom see a justification for Brand Name Only. Looks to me like our courses of action is to: 1. Challenge each RFQ that cites Brand Name only; I guess it is up to us to police the system 2. Advise office Sm Bus specialist and/or agency Sm Bus director. This is a costly process, esp for a sm bus. I really do appreciate the comments. R, Bob Thompson COGP2@aol.com
  2. Vern - We have reviewed a few justifications, but usually they are not published. Problem is general, not limited to a specific office. These RFQs are all Simplified Acquisitions or GSA solicitations. Thx for info. It helps. R, Bob Thompson
  3. What are some courses of action for a SDVOSB manufacturer that typically sees RFQs with a Brand Name purchase description for a Large Business product? Buyer often calls RFQ a Small Business Set-aside. Thx! C. R. (Bob) Thompson, CPCM
  4. Is there a list or summary of the Annual Reporting Burden hours for FAR/DFARS changes subject to Reg Flex Act? If so, where? Thanks! R, Bob Thompson cogp2
  5. cogp2


    Thank you, Formerfed R, Bob Thompson
  6. cogp2


    Thanks to both Carl Culham and DW Gerard. Comments helpful. R, Bob Thompson
  7. Is there any current measurement of Procurement Administrative Lead Time (PALT)? This is the time, in days, between receipt by the contracting office of a valid Purchase Request and award of contract/order. If so, is it reported anywhere? Publicly available? R, Bob Thompson
  8. Vern, Jacques - Thank you both. I appreciate the comments. R, Bob Thompson
  9. Does a subcontractor have any recourse to federal government to obtain payment on supplies furnished to a prime under an ordinary purchase order, non-construction? Are there any lien procedures? If so, is there a period, such as 30 days after delivery, when a lien could be filed against the federal government? Thanks! Bob Thompson
  10. Thanks for the update. R, Bob Thompson COGP2
  11. Federal Register Feb 11 had a final rule amending DFARS relating to interagency procurements on behalf of DoD. Q1: What will be the practical effect on DOD's use of GSA contracts? Q2: Any change in predicted usage? Q3: Why was this change necessary? I know the law said so, but what/who drove the law? Q4: How does this help streamline, simplify, expedite the process? R, Bob Thompson cogp2
  12. Senior DoD Officials Seeking Employment With Defense Contractors (DFARS Case 2008-D007) DoD has adopted as final, without change, an interim rule to implement section 847 of the National Defense Authorization Act for Fiscal Year 2008, that addresses requirements for senior DoD officials to obtain a post-employment ethics opinion before accepting compensation from a DoD contractor within two years after leaving DoD service. One source submitted comments on the interim rule. That source supported the rule and its objectives, but recommended that the central database/repository for retention of written ethics opinions, required by section 847( , be made publicly available. DoD has not adopted this recommendation, as section 847 does not authorize access to the database by the general public. So much for openness and transparency in govt! DOD Officials might have decided in the spirit of 'openness'that the database would be made public. But, No, another public-be-damned pronouncement. R, Bob Thompson
  13. napolik, Thanks for confirming view. I appreciate it! R, Bob Thompson
  14. What is the effect of cancellation of an RFP, and then a month later the agency asks a set of clarifying questions about the offeror's proposal under that RFP? Agency says it will re-issue the RFP 'soon'. RFP was issued as commercial item HUBzone set-aside and likely multiple offers were received. How should offeror interpret the agency's cancellation? What is offeror's best response? Thanks! R, Bob Thompson
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