Jump to content
The Wifcon Forums and Blogs

KeSer

Members
  • Content count

    6
  • Joined

  • Last visited

Community Reputation

0 Neutral

About KeSer

  • Rank
    Copper Member

Contact Methods

  • ICQ
    0
  1. I asked that question to DASA(P) in my review of the draft Army Source Selection Supplement. We'll see if they respond. If a program is well-established, and superior technical approach can only be accompanied by low risk, methodology 1 makes sense. But if we're seeking any kind of innovation or creativity, it doesn't make sense to force us to combine approach with risk. - And even though the AS3 only "prefers" methodology 1, knowing how things go, we'll be forced to write some type of justification for not using methodology 1, creating more unnecessary work for overburdened contracting officers.
  2. FAR 2.101 defines ?Determination and Findings? as "a special form of written approval by an authorized official that is required by statute or regulation as a prerequisite to taking certain contract actions. The ?determination? is a conclusion or decision supported by the ?findings.? The findings are statements of fact or rationale essential to support the determination and must cover each requirement of the statute or regulation." There are a few places in the FAR that specifically call for a D&F, for instance FAR 12.207( (1)"(ii)The contracting officer?(A) Executes a determination and finding (D&F) for the contract..." There are other places in the regulations that state a determination must be made, for instance 13.106-1( (1), which states "contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available...", but do not specify a D&F. Logically, all determinations made must be supported by facts and rationale of some sort. So why does the FAR specify some instance where a D&F is required, but require other determinations to be made not in the form of a D&F? And is there a difference (other than the title at the top of the document) between a D&F and one of the 'other' determinations?
  3. Inherently Governmental Function

    Given this coverage in the FAR and DFAR, I am curious to know the answers to two questions: 1. How many contracting folks are preparing for every service contract the FAR 7.503(e) determination that the contract does not cover inherently governmental functions? 2. How many DoD contracting folks prepare the determination using the DFARS guidance? The Army uses a worksheet as part of the Approval of Contract Services which documents that the services being procured are not IG. The Approval is required for ALL service contracts. As for DoDI 1100.22, I'm not certain whether the Army form complies or not since I haven't read the DoDI cover to cover.
  4. Boomerman - Not sure if you are DoD, but if you are, read Shay Assad's memo dated 24 Nov 2010 regarding Improving Competition in Defense Procurements. This takes away our ability to use FAR 15.403-1©(1)(ii) or (iii) to determine that the offered price is based on adequate competiton when only one offer is received. Although you did receive more than one offer, was there adequate competition if none of the other offers could meet the Government's requirement?
  5. What are you reading?

    I just finished Lord of the Flies by William Golding. I think I want to re-read it (again). There's just so much going on there.
  6. He does make a good argument that CONTRACTING people should rotate to the PM Shop/COR side. You learn a lot by viewing the same thing from a different angle.
×