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formerfed

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  1. @LeighHar I don’t think you’ll get much input here. Most agencies don’t consider household moves as something done through a contracting office. Generally they are handled by an office dealing with facilities, logistics, HR, etc. and the transaction is covered with a Government Bill of Lading, at least for domestic moves, and not a purchase order or contract.
  2. Lots of luck with that DoDIG. The majority of the contracting work was done by HHS. I also don’t think any cost data was involved. Even though sources claim production cost is $1.20 per dose, it’s just speculative and there’s no real basis for that. This is one of those instances where suppliers have everyone over a barrel. We don’t want to pay that? Suppliers respond with “We will sell it elsewhere.”
  3. @Vern Edwards My responses: Is there any legal requirement that companies selling to the government take a cost-based pricing approach to product pricing and price negotiation? No Is there any moral imperative that companies take a different approach to pricing when dealing with the government than with other customers? No If no to Questions 1 and 2, is the government's application of policies grounded in cost-based pricing (e.g., TINA) overly broad? Yes If so, when if ever should the government demand a cost-based approach? In limited circumstances, yes. The government is a unique buyer for some things and a cost-based approach can be the only reasonable method. But the exceptions are very few. Is it possible that the government's cost-based pricing apparatus (requiring detailed cost proposals, TINA, proposal "audits," etc.) costs more than it's worth, as perhaps demonstrated by the outcome of the 10-year United Technologies defective pricing litigation? Certainly. In most situations, the government should have a sound understanding of a fair price. Cost-based pricing tools are often used just because policies say they are required but may not add value. I especially liked the defective pricing litigation statement that the government wasn’t injured because it got what it paid for.
  4. Or look at buying a new vehicle today, especially those in demand. A $50,000 MSRP Ford Bronco is selling some places at $30,000 over sticker. Wonder what cost or pricing data from Ford shows as the cost? Just like lots of contracting areas, we don’t need more policy, procedures, regulations or laws. We need better and trained people who are held accountable for results and rewarded accordingly for good performance.
  5. I looked through the IG report. Maybe this recommendation has the most merit to me If an agency is buying something needed, they ought to have knowledgable functional experts that at least can say what’s a reasonable price/cost. COs can leverage that expertise for negotiating. The way most COs are trained combined with limited experience, they can’t really benefit from cost or pricing data or other price/cost information. Sure auditors are available but the process of using them is cumbersome and time consuming. When a CO finally gets the audit findings, contractors can bring up lots of new information during negotiations. Then often the CO is lost for lack of understanding and assistance. It’s either wing it or go back again to the auditor. Here’s a question - how many government negotiators understand accounting and specifically cost accounting?
  6. Since you are quoting me, I think the comment “your proposed fix” is referring to me. If so, I never proposed a fix. I said that’s what many agencies do. It happened very frequently a couple years ago with consolidation of schedules. I haven’t heard any criticism either. It’s a situation where an exact answer isn’t apparent or not worth the effort digging further. The OP can do a limited source justification if he’s uncomfortable. Also my “it’s not that simple” referred to asking the GSA CO - nothing more
  7. It's not that simple. There are 12 different Schedules and each has huge numbers of awards. For example the IT has nearly 5,000 contractors. While there’s a single CO for a solicitation, the thousands of responses get assigned to a large number of contract specialists. A contract specialist also may or may not be the CO for the offer that are evaluating and negotiating. It depends upon the estimated dollar value of the award and the CS/COs warrant. In addition COs concentrate on getting contracts out. Probably many don’t know that much about BPAs and the specific question asked here. Even if you somehow found the CO assigned contract responsibility, do you ask the CO of the expiring contract or the CO of the new contract. You may get two different answers. Some of the typical questions agencies ask about placing orders are beyond COs expertise. Details of how the Price Reduction clause operates is a prime example. GSA does have groups that are set up to answer these type issues but it’s a completely different part of the organization.
  8. The most common way of handling this is simply modify the BPA to show a switch from the old to the new contract number. That’s what most agencies do in similar circumstances. I’m not saying it’s proper or not but I haven’t heard criticism from any source. It’s a relatively frequent occurrence especially with the GSA merger and consolidation of Schedules over the past few years. Another approach is prepare a Limited Sources Justification, do the BPA action, and then post in FedBizOpps for the required time period.
  9. This situation is not that uncommon. Agencies often neglect close-outs for years. Then they tackle the tasks in a mass effort or use a contractor. Lots of companies go out of business during that time contract performance occurred and getting to the close-out. The way it’s generally handled is document the efforts to unsuccessfully locate and communicate with the contractor. All the tasks that don’t require contractor input are done like verifying financial data. Then the files are packed up and sent to the Records Retention Center.
  10. Reminds me of an old comment from a senior Treasury official years ago - before DHS was established. He said Customs could contract for a mainframe computer, have it installed, and fully operational before IRS could finish assembling their planning committee.
  11. A lot of misunderstanding exists across the government of IFF and “best rates.” In reality the IFF is nominal at 0.75% of the order amount. Compare that against the administrative time and expense for doing an open market procurement. GSA negotiates prices generally by comparison of discounts from price lists. They usually seek discounts equal to or better than the offerors most favored customer. Exceptions include situations where the most favored customer buys substantially more over a year such as Amazon or provides some value added services. However the GSA discount price the government pays covers some very small orders as well as larger ones. If an agency has a large and immediate requirement, GSA expects that agency to seek more favorable prices.
  12. @KeithB18 That is a major problem especially when a lot of the acquisitions involve major IT. A couple of agencies partially solved that by creating organizations intermediate between CIO and Contracts. The CIO office funded a few positions. Some of those are IT specialists that take user requirements and convert to documents supporting the acquisition process. Other positions are contract savvy people that have some IT knowledge.
  13. When you get down to it, acquisition is a function that supports mission. If a program office struggles for a year putting together a requisition package and PALT takes 120 days, is contracting successful?
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