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formerfed

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About formerfed

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  1. Two things wrong with this Act. One it’s obviously political. The second is so obscure, no one knows about it, much less workers responsible for furniture procurement. What typically happens with purchasing for a Secretary’s Office is some staffer does a requisition. A budget/controller staffer approves funds quickly knowing who it’s for. Then a diligent purchasing agent or 1102 processes the order. There’s no one that knowledgeable in appropriation law that Evers get close to see it.
  2. That part left out makes a difference. Now I see you’re talking about an agency considering placing an order under your STARS II contract. Ordering agencies can require a contractor to recertify their status prior to placing an order. They don’t have to and most don’t but it’s at the ordering office COs discretion. I just checked the contract and their a provision like that in clause number 26. You need to ask the GSA CO what that means to you exactly. To state if differently, you’re a small business 8(a) for the duration of the STARS II contract unless an ordering office asks you to certify your status and you can’t say you are small any longer for that NAICS.
  3. Retreaded is exactly right. Unless the Stars II CO requires companies to recertify size status prior to exercise of an option, you are good to go.
  4. I know it’s confusing but a FMS solicitation is exempt but the contract award is not. I assume the award notices in the GPE don’t really happen much though through neglect or just forgetting. However there is a requirement for Congressional notification of DoD awards over $7 million. That includes FMS and that’s why you see those published outside of the GPE process http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/dfars/dfars205.htm#P60_1211 and because that’s a Congressional notification, it doesn’t get overlooked
  5. apsofaco, You obviously have done many IT procurements before and know how they work. My concern in the original posts is many 1102s don’t. The field has a big share of people who either aren’t interested in learning, lack confidence, or maybe are just content doing what what they do know. I don’t think the answer is just increasing IT knowledge. It’s more about becoming bolder, willingness to learn and try new things, and experiment. The field is full of risk adverse people.
  6. i’m confused - the budget would come from the IT department so it must originate there? In most agencies, budgets for procurements come from respective programs. Many agency contracting officers work on a fee basis for the programs and have little money of their own, but that’s beside the point. Let me use the example of Agile. It’s been around in the government for ten years. Even though it’s old, many 1102s donut know how to begin with a requirement. IT offices and most program offices look to the contracting office for advise, guidance, and even buy in on approaches and strategies. So what I’m talking about is more than preparing a solicitation. It’s planning, strategy development, source selection, evaluation, discussion, and pst award management. Agile requires something radically different than traditional commodities. When Agile is tried, many of the failures had to do with 1102s not understanding the concept. I’ll give some examples. Agile often works best in a labor hour contract arrangement but many contract offices took the position they can’t do labor hour contracts! So thing s like FFP were used and it was a disaster in many instances. Another is source selection. Often 1102s didn’t understand Agile and insisted on th wold boilerplate factors like technical approach, management plan, key personnel, etc. Proposals looked good on paper but many companies just copied stuff out of articles and textbooks. Many companies, especially small had never done Agile before, so 1102s in some instances insisted neutral past performance ratings applied. That sometimes meant every proposer got a neutral rating especially on small business set-asides. They didn’t understand the significance of experience versus past performance. Then there were some who learned a little and said contract developers working side by side with government developers was personal services and they wouldn’t allow it. Finally there’s evaluation of price. How does one structure a model to use in the solicitation especially when the overall effort may be largely unknown? Structuring a price evaluation approach for Agile is simple compared to Cloud. Pretty much every company prices differently and if the government uses their own model in the solicitation, deciphering each offerors proposal against that model and comparing is challenging. That’s apart from finding out after award, actual costs are entirely different than what was proposed and accepted. Some of these issues might be program offices or at least shared. But 1102s need to be knowledgeable and understand what is being procured to be effective. The lack causes many agencies to go outside for 1102 support. Those are wasted opportunities for personal growth, advancement, and positive experiences.
  7. Retreaded gives excellent advice. We can’t advise you here without lots more information. Plus you need to be clear with what you mean by “additional work” and “in scope”. For example if you need four people than two to do the original work, that might be a cost overrun and not fee bearing. You might get the additional costs but no more fee. On the other hand, a new report the government requests might be fee bearing. A lot of stuff needs examined to decide.
  8. OP, the reason I asked about dollar values is to see if SAP would cover your needs. A few agencies have done remarkable jobs with supply chain management. Without much in the federal sector to go with at the time, they did market research and adopted best practices from commercial firms. These included Toyota, Ford, and Boeing (not a good one to quote right now). But the idea is narrowing down the supplier best to a few proven sources and obtaining price concession from dedicated business. Toyota does an exceptional job with just in time supplying while Ford successfully reduced their supplier base down to a few highest quality sources. Those agencies generally started with identifying all the items as part of the supply chain. They developed strategies and a overall acquisition plan to cover everything. One used a very successful approach where they awarded mostly competitive IDIQ contracts with an evaluation strategy stating achieving supply chain objectives was of prime consideration. Offerors submitted proposals describing their approach and the agency evaluated soundness, risk, and experience in selecting for award along with price. Past performance really played in and they conducted extensive dialogue with customers, which were mostly commercial, in the evaluation. The difficult part was getting commercial sources to provide input, which they usually don't do. One very intriguing concept was used of award term as an incentive for long term successful performance where the base and initial option years were four plus one and potential award term periods were another ten years. Several also used BPAs since their requirements were mostly commercial items of relatively lower dollar value. One used a similar evaluation that is mentioned for the IDIQ contracts. For some needs, sole source was used especially with proprietary situations. The secret is getting quality and proven suppliers on board with long term arrangements. When multiple awards are made, normally no more than three sources are used. This is need to also streamline ordering. As far as the Federal Acquisition Supply Chain Security Act of 2018, I don't believe it ever passed. I think its still on hold in the House. Even if it passes, it would be months, if not a couple years, before anything comes out that would apply to your situation.
  9. What are the annual estimated dollar values?
  10. I’m going to give you my personal advice which has nothing to do with contractual. You need to develop a closer working relationship with your government client. The positions are non-billable so from a financial and contractual stand point, it’s moot. What you should be concerned about is performance at the highest level to make your client satisfied. Talk with the client, explain the options, and get their input. Long term business rests largely on client satisfaction. If I were in your situation, conversations with the customer would started months ago. The reason I’m saying this is you might contractually right with dual positions and your your deliverables and other work products meeting contract requirements. But if the client isn’t happy, you end up losing.
  11. GAO just released a report on agency best practices for Federal Information Technology Acquisition Reform Act (FITARA) implementation. Some of those pertaining to acquisition are centralize software license purchases, transition data centers to virtual or cloud, and consolidate data centers when appropriate. All of these involve contracting in varying degrees. To me, this involves lots of opportunities for 1102s to do new and challenging work, learn, grow, and receive promotions. But what I see way too much of is 1102s doing little, waiting for training and instructions on how to proceed. Few seem willing to educate themselves and volunteer to become involved. What also is happening is agency management including CIOs going to other agencies for that contracting support. Just curious on how many people here see much of the 1102 workforce left behind for lack of knowledge?
  12. Pepe, I agree with your interpretation in the context described. But in a daily, practical world, the master contract can be just a vey small segment of the agreement between the parties. In those cases, the master contract is just a number maybe with some token T&Cs that apply to actual performance. Good discussion though.
  13. Pepe, I generally agree with you but there are a few exceptions where a task order is very close to being a stand alone contract. For example: GSA instructs ordering agencies on some MAS to determine if the Service Contract Act applies and agencies must obtain appropriate Wage Determinations and require compliance by the contractor. DOL in enforcing the Act considers the task order to be the contact. Occasionally ordering offices request contractors to perform work outside scope of the contract such as providing equipment under a service contract or labor categories not covered. When the contractor performs, the parties create a “contract” Some task orders for very complex work such as major IT development don’t easily fit as a simple order. Take an example of a performance based order valued at several hundred million dollars over a ten year period. About the only thing in common with the master contract is the defined labor categories and some boilerplate T&Cs. Commerce awarded a small business IT services GWAC some years ago. The contract had no CLINS and thus no prices. Ordering consisted of offerors providing solutions using whatever labor, equipment, software, networks, subs, etc. they felt appropriate. The orders were much closer to being a contract than the basic contract was. So I generally agree with you but I don’t think we can say your position applies in 100% of instances.
  14. If you are using a working capital fund now, or even if you aren’t, there are (may be) constraints in how other agency funds are used. This is especially true with annual appropriations. Take a look at this: https://www.everycrsreport.com/files/20090917_R40814_3def4b0205331e0843abcd212e2a6fba3f639944.pdf
  15. The CLIN numbering situation misse911 describes likely will be more common with increased automation and Robotic Process Automation. A few agencies already have contract CLIN data, including numbering, carry over to requisitions produced by program offices. The contracts office then just verifies to information and converts to a task/delivery order. A saw a couple demos of agencies using RPA with procurement and carrying over CLIN numbering and description from contracts is exactly how it works. So this often and even usually results in non sequential numbering on orders, especially with things like IDIQ IT hardware and software contracts.
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