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Everything posted by formerfed

  1. formerfed

    Reserving MACs for SBs

    I don't know if this is GSAs position but I would argue this. I'm doing a multiple award IDIQ contract vehicle for IT needs. It has extremely high order limitations so I know small business can't meet all the order requirements. But I anticipate small firms can perform on some orders. This meets the FAR 19.502-3 criteria for a partial set-aside. So I award Alliant on a full and open basis and Alliant SB as a set-aside to cover all the potential order needs. It complies with the rule of two and everything else.
  2. formerfed

    Reserving MACs for SBs

    Agreed. I would assume that by going to Alliant, the Rule of Two was applied and small firms couldn't meet my need.
  3. formerfed

    Reserving MACs for SBs

    My thought is since both Alliant and Alliant SB are very large IDIQ contracts, the scope is relatively open. Individual needs are met at the task order basis. So ordering agencies decide which vehicle to use based on the specifics of their work. The work is the same for both (same section c and labor categories); it's the magnitude of the jobs that differentiate.
  4. formerfed

    Reserving MACs for SBs

    Napolik, Back to your original question, it seems to me GSA did exactly that with Alliant. They determined that a total set-aside is not feasible so they did a partial. The partial is Alliant SB.
  5. If you have confidence in the government estimate, why not? I would tell each company that the government desires paying no more than $98,000 and what's their best price.
  6. The first question I would ask the technical office is the reason for the "how" to prescriptive elements. If something needs accomplished in a set way, make that part of the "constraints" section of the SOO. In other words you say "these are the objectives of the acquisition, however certain items listed as constraints need complied with." For example security reasons or interfacing with another project may require work to be performed a certain way.
  7. It doesn't make sense. I'm guessing the original intent got lost someplace along the way
  8. formerfed

    RFP states a proposed solution

    I worked at an Army location where all awards had to result from contracts prepared from scratch. Contracts couldn't be a simple unilateral acceptance of offers and everything was done via SF26 signed by both parties. If a solution resulted in a contractor selection, the pertinent parts of the proposal along with the essential parts of the SOW were put into the contract. Then the contractor was called in and the CO went over all the language as well as all the clauses with the contractor. The contractor and the CO essentially agreed to everything the contractor is required to do in clear terms. A lot of work but well worth it in most instances.
  9. formerfed

    Acquisition Support Personnel

    Excellent advice! OP, you are a contractor and an employee of that company. If things aren't going right, you raise the issue within your company. Your boss tells you what to do. It really shouldn't matter to you what the BPA says. That's something your employer deals with.
  10. formerfed

    Category Management?

    Competing objectives pretty much sums up a lot about government buying. Its confusing when you try and sort through it all. Pick just one like socio-economic and it's puzzling on its own. If I have a requirement that can be met by women owned, veteran owned, minority owned business, etc., which do I pick? From a high level, category management makes sense. Have the agency with the most expertise and knowledge do the consolidated buying. But if I truly consolidate and leverage the buying power to get the most favorable pricing, I likely will exclude small businesses. I also likely will award to a very few number of sources at the expense of spreading buisness to many companies. So a handful of companies reap rewards which many other companies are injured. At the same time this concept probably hurts individual agencies and their programs because it takes away preferences and unique but needed features of products and services. There's a cost associated with "one size fits all." What would be nice is for the government to eliminate these conflicts.
  11. Since this is a $500,000 action using simplified acquisition procedures, I wouldn't necessarily consider the quote technically unacceptable. I could go back and ask why parts weren't included. The vendor could simply revise the quote and we've home free.
  12. formerfed

    Category Management?

    He could but just imagine all the pushback - intelligence agencies saying national security is dependent upon their contractors, defense saying only certain large businesses are capable and their requirements are so unique it will drive up costs for other agencies, Homeland Security saying they need flexibility only companies familiar with them can provide. It goes on and on. Every agency says they are unique. Cabinet Secretaries can't even make their components share the same data centers.
  13. Don, They certainly could be used together. But I'm think if past performance was done in the manner described, agencies could get to award quicker and less effort for both industry and the government. From what I gather this process involves multiple awards initially. Each contractor performs for a certain period of time, delivers their products, the government evaluates and makes a selection decision. That involves a lot of time and expense for everyone. My thinking is could the government through the past performance process gain enough information and insight about the offerors to make a selection without the prototypes? I believe they could assuming the work is the typical IT development.
  14. I've noticed several new attempts to speed up awards and reduce time and effort required by both government and industry. Here's one example. I highlighted this one because of the attention Anne Rung gave. http://fedscoop.com/hhs-buyers-club-an-innovative-acquisition-case-study Essentially HHS used a streamlined process to select a contractor for IT development work. The contracts office initially faced a 26 page SOW and looked for something quicker because "they were clearly headed down the path of a traditional six-month procurement likely resulting in the selection of a contractor with the best written proposal." What they came up with is a process fairly typical for Agile where a limited number of sources get selected for prototype development. Then a selection for long term development is made based on the prototype results. Since there are multiple ways to quickly reduce the number of potential sources, it looks like the real problem needing solved is how do you know which source is really the most capable? Seeing actual prototype results rather than just reading a proposal is an easy answer but is that conclusive? I'm wondering if more effective use of past performance is a better solution. I don't mean the more typical means of sending out email questionnaires or canned phone call questions to references and checking PPIRS. I'm thinking doing comprehensive research and finding the most relevant customers. Once located, go through a fact finding process which may include site visits and seeing how well the offerors delivered on their promises. In the case of IT, the questions are do the products do everything intended, are the users satisfied, was the work performed within budget, were user long term needs truly accommodated (this is a very important consideration with Agile), etc. What do you think?
  15. formerfed

    Category Management?

    Category management is just another name for something that's practiced a lot, particularly in the private sector with large corporations. Its just a twist on strategic sourcing. Regardless, the big question is why should the government be duplicating contracting efforts for the same things many times over. Of course there are lots of good reasons. Then there are lots of reasons why they shouldn't. If you look at buying practices across the government for the same commodity, there are good results from very experienced buyers and there are horrible results from others. So why not have the best buyers contract on behalf of the entire government and really leverage the buying power? A lot of duplication and waste exist right now and without good reason. I heard one agency say they won't use GSA Schedules because their management evaluates the contracting office and their need for staffing resources on the volume and complexity of work they do. A GSA Schedule order gets a fraction of weight compared to them doing their own contract. Many other agencies say GSA Schedules won't allow them to negotiate their own special terms and conditions on task orders, which isn't true. So many existing ways to save money and time are in place now but aren't used such as GWACS, GSA Schedules, other agency contracts using interagency agreements, etc. In order for this concept to work, agencies need to be forced to use the sources. More importantly agencies will have to relinquish some of their existing flexibilities to buy items unique to them or those that simply reflect personal preferences. I remember a firearms manufacturer at a conference saying that the non-military section of the government uses 22 makes/models of handguns. Probably most important, agencies need to give up control over the management of their needs and spending. That's an uphill battle and I don't see the Administration willing to do battle to win.
  16. This also isn't a whole lot different than negotiating varying profit/fee percentages with contract types. A contract may contain multiple CLIN with varying contract types. Based on associated risks by CLIN, you would expect different profit rates.
  17. By the time a contracting office or contracting officer is involved, hopefully the agency's acquisition process has worked through a strategy where the need is met by a contract. Suddenly deciding a requirement gets done through a grant or cooperative agreement sounds strange like the agency doesn't know what they are doing. In order words the program need is X. The acquisition process should decide upfront what method is best to satisfy X - is it a grant, a cooperative agreement, another agency, in-house, a contract, etc.? I think Don is bringing up the right points.
  18. There's a lot of generalization about Contract Specialists positions in the government that's just not true. Actually a lot of variation exists. Some contract specialists work in a narrow and specialized field in their agency. DoD has many. It takes a long time and lots of training and experience to become proficient. Other contract specialists are more like gloried clerks and spent a lot of their days doing administrative tasks. Still others get caught up in lots of other duties like doing IT support, liaison with finance and budgeting, interfacing with industry and particularly small businesses, and the like. In some places, contracting is viewed by program offices as barrier to getting what they want. In other places some, but not all, of the contracting staff are viewed as valuable assets. Those people know the agency programs and can provide advice and assistance in making acquisition work for them. To get there individuals have to work hard and demonstrate their value by showing professionalism, good communication skills, exhibiting critical thinking and providing solutions to program needs. The key to finding the right job is getting started. You need to get your foot in the door through some means like an entry level position or an intern program. Just having status will open up lots of doors. The one unique thing about the government is you can switch jobs and it doesn't look bad on your resume. In fact many people at the senior management level like to see employees in contracting with a board range of experience. I think a JD degree is great. The only issue you might face is reluctance by the selecting official - most of us in contracting are way too familiar with the legal response that "you can't do that" rather than "here's the way to get that done." So in an interview, my suggestion is stress how you like to find the optimal solutions. Good luck!
  19. I think there are at least a couple reasons to disclose amounts. One is the solicitation doesn't provide enough information for offerors to understand the full effort. Another is you don't have enough money for what is apparently needed for everything. So you tell everyone what you do have and try to get the most for your budget.
  20. formerfed

    (1) More and (2) Better Training?

    This is a broad generalization I'm making but too much training doesn't have practical implementation. Source selection is a perfect example. Many students can't walk away from that and craft a strategy for an individual action. What usually happens is they "cut and paste" an example from training that may not be even close to a good one for the immediate action. They also have no idea whether technical evaluations/TEP reports are good or bad and fall short in answering questions or assisting evaluators. Price/cost evaluations is another good example. Students often have the concepts down afterwards but are at a loss to apply it in real world situations. There are several good points already made about - need to teach critical thinking; better content, better course materials, and better instruction; and training with practical exercises so students know how to apply.
  21. Keith, Unfortunately I have to agree with you. It's not just for GSA Schedules but contracting and procurement in general.
  22. Joel, Just for information, this has been a long time requirement for all agencies. Agencies have to accurately account for all costs and revenues from a number of means including statues, regulations, OMB policy, etc.
  23. If you're looking for a yes/no answer because I think the actual answer is "it depends," I say no. The BPA was established against the Schedule in effect in 2011. If the Schedule was revised later, the contractor has to agree to including changes to the BPA. But that's just one answer. The correct one is what was the parties intensions as Vern points out?
  24. formerfed

    Defining PII

    Look at NIST Pub 800-122. Phone numbers and email addresses fall in that category.
  25. The rules started out as simple. Then ordering was abused and some fixes are overly complicated - including items that aren't part of the contract, getting competition for orders (especially when the order value exceeds the simplified acquisition threshold), and the process when you limit sources. It started out as being very simple but with the additions like I mentioned above, it is simple with elements of complexity thrown in. Its now to the point where too much confusion and misunderstandings exist - the dialogue in prior posts on discussions and debriefings are prime examples.