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Don Mansfield

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Blog Comments posted by Don Mansfield


  1. 2 hours ago, Whynot said:

    I presume that we can make our own assumptions with regards to orders vs units (i.e. 1 order for a 100 units or 100 orders for 1 unit each) and for the number of customers placing orders (i.e. 1 customer with 100 orders or 100 customers with 1 order each) and that on-time probability applies to the entire order and not to an individual unit within an order; and that what is best for the government means what is best for any one individual customer’s cost or budget.

    You may be making things too complicated. I suggest you just work out the problem for 1 unit.


  2. 16 minutes ago, ji20874 said:

    Here's my initial understanding of the problem--

    • Supplier A = $112/ea for on-time delivery, or $71/ea for late delivery, with about a 1-in-3 chance of late delivery;
    • Supplier B = $106/ea for on-time delivery, or $65/ea for late delivery, with about a 1-in-5 chance of late delivery; and
    • Supplier C = $100/ea for on-time delivery, or $59/ea for late delivery, with about a 1-in-25 chance of late delivery.

    Am I understanding correctly?

    Yes.


  3. 15 minutes ago, apsofacto said:

    Life.  Wow, man, Life. 

    It's really strange you know?  We make these plans to receive your proposals and then Life happens and we can't.  We can't even issue an amendment to our solicitation!   Could be plague, could be invasion, could be we just totally flaked out that day. 

    But chill.  We'll take it when we get back.  We won't trip about Life.  Cuz. Life.  Trips. Us. Man.  All of us. 

    Can you pass that stuff over here?

    😂Someone just took the lead in the humor category.


  4. 1 hour ago, ji20874 said:

    I like your paragraph allowing for an extended deadline for emergency or unanticipated events.

    I suppose your working assumption is that the text can be improved?

    I took the paragraph from FAR 52.215-1( c )(3)(iv). My assumption is that the text can be made more readable. The Dale-Chall Readability adjusted score is 11.1. That corresponds to "Grades 16 and Above (College Graduate)", which is the highest level on the scale.


  5. 5 hours ago, Contracting Pirate said:

    Have any of ye land lubbers had experience using this method? Would a contractor actually be willin' to accept eatin' the $73k doubloons in Scenario A and $91k in Scenario B?  I may be cynical due to me sole-source encounters with dodgy contractors.

    The contractor doesn't have to eat the loss. They could buy insurance, right? 


  6. 2 hours ago, here_2_help said:

    could the CO use Part 15 procedures for the others but use Part 12 procedures for the NTDCs?

    help,

    It's a popular misconception that FAR part 12 procedures are for commercial items and FAR part 15 procedures are for noncommercial items. When acquiring commercial items, the CO will typically use one of three contracting methods:

    Quote

     

    12.203 Procedures for solicitation, evaluation, and award.

    Contracting officers shall use the policies unique to the acquisition of commercial items prescribed in this part in conjunction with the policies and procedures for solicitation, evaluation and award prescribed in Part 13, Simplified Acquisition Procedures; Part 14, Sealed Bidding; or Part 15, Contracting by Negotiation, as appropriate for the particular acquisition.

     

     As such, I think what you're asking is if, when acquiring noncommercial items on a competitive basis, the CO should prepare one solicitation for NTDCs (containing commercial provisions & clauses) and one for others (containing noncommercial provisions & clauses). That's a good question. I don't know.


  7. On 3/31/2018 at 9:14 AM, C Culham said:
    1. The DoD does market research.

    2. DoD determines not to set aside and it is a procurement that does not use Commercial Item acquisition procedures.

    3. The DoD also determines that adequate competition will not occur and includes DFARS Clause 252.215-7070.

    4. A small business responds and states it is a non-traditional defense contractor and states that it is not providing certified cost or pricing data.

    5. The CO treats the supplies/services of the non-traditional defense contractor as if they are commercial items and agrees that cost or pricing data is not required. 

    In the first scenario I think I have it right but what about the second one?   It seems that DoD has forgotten or has on purpose failed to give the “may” option to CO’s with regard to DFARS Clause 252.215-7010 as there is no exception available to the CO if the offeror is a non-traditional DoD contractor.

    I think you have it right in the second scenario, too. The solicitation will also include DFARS 252.215-7013. I don't understand your last sentence.


  8. On 4/1/2018 at 12:08 PM, here_2_help said:

    I would correct your statement to read "ALL small businesses are non-traditional defense contractors..."

    That's not necessarily true. Remember that it's possible for a contractor to be small under some NAICS codes, and not small in others. So, it's possible that a contractor that is small under one NAICS code has performed a CAS-covered contract under a different NAICS code. Also, it's possible that a contractor was not small when it was awarded a CAS-covered contract, but is small now. That's why I used "most" in the blog entry.


  9. 6 hours ago, policyguy said:

    Seems to me to be a technical correction that does not require public comment.  On what basis do you assert that this requires public comment?  

    I base it on 41 U.S.C. 1707(a), which clearly states:

     

    Quote

     

    §1707. Publication of proposed regulations

    (a) Covered Policies, Regulations, Procedures, and Forms.-

    (1) https://www.youtube.com/watch?v=U9t-slLl30ERequired comment period.-Except as provided in subsection (d), a procurement policy, regulation, procedure, or form (including an amendment or modification thereto) may not take effect until 60 days after it is published for public comment in the Federal Register pursuant to subsection (b) if it-

    (A) relates to the expenditure of appropriated funds; and

    (B)(i) has a significant effect beyond the internal operating procedures of the agency issuing the policy, regulation, procedure, or form; or

    (ii) has a significant cost or administrative impact on contractors or offerors.

     

     

     


  10. On 5/22/2017 at 8:44 AM, Melissa Rider said:

    All of you are welcome to be part of the solution.  If anyone would like to share your best practices and have them considered for insertion in the Section 809 Panel's submittal to Congress or there is a part of DFARS or FAR that is completely impeding your abilty to get work done, please submit your recoommendations, including what you think the final change needs to look like, to https://section809panel.org/contact/

    Be the change you want to see in the world!

     

    Melissa,

    If the Panel wants to find out the types of things that are impeding people at the working level, setting up the web site is nice, but it's not enough. People at the working level are working. Most have already filed away or deleted the e-mail from the Panel soliciting feedback that had already been forwarded three or four times. If the Panel wants to know how the regulations are impeding people's ability to get their work done, they should read the kinds of questions being asked in the Wifcon forums or in Ask-A-Professor. Many of the questioners are being impeded by the regulations, but they don't know it. The Panel should read the Nash & Cibinic Report, which contains recommendations for improving the regulations in every issue. 

    Also, you'll reach more people if you don't make them write out their problem and justify why it should be changed. Most people at the working level are young, they would respond to something interactive and fun like Ranker.com. 


  11. uva383,

    The use of FAR 52.216-18 or DFARS 252.216-7006 would be discretionary. The policy for the discretionary use of FAR provisions and clauses is stated at FAR 12.301(e):

    Quote

    Discretionary use of FAR provisions and clauses. The contracting officer may include in solicitations and contracts by addendum other FAR provisions and clauses when their use is consistent with the limitations contained in 12.302.

    When you see an "N" in the "CI" column of the matrix, block E5 explains "Entries of "N" indicate that provision or clause may not be used unless its use is consistent with the limitations at FAR 12.302. See FAR 12.301(e)."

    Make sense?


  12. On 10/10/2016 at 6:29 AM, C Culham said:

    I suspect you went to a lot of work to create and it would take same to maintain as the FAR/DFAR and additional 31 Agency Supplements change.

    The only FAR supplement that the matrix includes is the DFARS. I have no plans on adding non-DoD provisions and clauses (unless someone qualifies for my incentive).

     

    On 10/10/2016 at 6:29 AM, C Culham said:

    I wonder if the effort is worth it when many depend on database programs to assemble the solicitation/contracts these days?

    I had been maintaining a Solicitation Preparation Guide, which received ~200,000 hits over the last 12 months and ~550,000 hits total. The guide contained prescriptions for all the provisions and clauses applicable to commercial items, which I kept up to date every time the FAR/DFARS changed, or a class deviation was issued. I found that this is what people mainly used it for. The guide will now direct people to the matrix, so I expect the same amount of traffic for the matrix at least.

    19 hours ago, Jamaal Valentine said:

    NOTE: I take it the Air Force does not qualify for the agency provisions and clauses ...

    No. The provisions & clauses have to be in the CFR. 

     

    47 minutes ago, TBone said:

    isn't the prescription for FAR 52.204-5 Women-Owned Business (Other Than Small Business) found at 4.607(a) instead of 4.607(b) as indicated?

    Yes, it is. My reference to FAR 4.607(b) was taken from the FAR matrix. I'll put DOE's clauses in the next version.


  13. 52 minutes ago, uva383 said:

    Would a student that chose the web based instruction for material like contract law or acquisition planning be able to switch to classroom for a math based class? Or would they be locked into web based instruction for the entire certification? 

    A student would always have a choice of how to prepare for a particular exam.

    55 minutes ago, uva383 said:

    Under this format how would you tie performance and successful or unsuccessful outcomes to the employee and the instructor? Would you recommend termination of an employee that cannot pass the classes?

    A student wouldn't pass or fail a class--they would pass or fail an exam. As far as terminating an employee who couldn't pass the exam, I don't think it should be automatic. However, it could be a possibility. As for instructors, I do think that there should be some accountability for their students' performance on the exams.

    1 hour ago, uva383 said:

    Also, given the current shortage of instruction in the classroom setting as demonstrated by reduced class offerings and long waitlists, how would your new format allow for scheduling issues or having to go outside of the DAU curriculum to obtain equivalency for some limited classes? 

    The whole problem with equivalency goes away with my proposal. Providers other than DAU can structure their training however they want. No need for a DAU seal of approval. All that matters is the results--everybody must pass the same exams.


  14. 11 hours ago, uva383 said:

    Would you agree that the methods of training today's workforce are different than it was 15-20 years ago, and are these methods ineffective and should we attempt to return to older formats? Or has the issue of an largely poorly trained workforce always been there and you just had more knowledgable individuals that could carry the weight and mask the issue(s)?

    I went through DAU training ~20 years ago and the difference was that everything was in the classroom. I guess it was more individualized in the sense that I interacted with an instructor who was physically present instead of interacting with a Web-based training module. The move to distance learning at DAU began about 15 years ago. Some felt that the quality of the training suffered. Shay Assad thought DoD should go back to the classroom for introductory training and that's why we now have CON 090. I think that was an improvement, but to go back to my original analogy, all we did was modify the design specification. So, no, I don't think we should just return to older formats. I think we should let the employee choose the format and hold them accountable for the results.

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