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policyguy

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  1. To me, grants have the connotation of just giving away free money without the guarantee or requirement to complete certain deliverables.

    You really need to confer with someone who is more informed on grants since I don't believe the above statement is accurate. Recently, OMB has issued new guidance at 2 C.F.R. 200 titled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Here's a link for additional information:

    https://cfo.gov/cofar/

  2. I would caution on using a grant instead of a contract or subcontract and recommend talking to folks who are knowledgeable in the grants field. Additionally, I recently had to do some research on the question if GAO will hear a protest on the award of a grant. I found that according to GAO an interested party can protest to GAO. In GAO Protest Decision B-406738 et al., August 15, 2012, GAO states:

    "...we will review a timely protest asserting that an agency is improperly using a cooperative agreement or other non-procurement instrument, where a procurement contract is required, to ensure that an agency is not attempting to avoid the requirements of procurement statutes and regulations..."

    Here's a link to the GAO Decision that contains additional information for review:

    http://www.gao.gov/assets/600/593742.pdf

  3. Several years ago I found a GAO protest decision that discussed how to refer to time: B-405754, SBBI, Inc. November 23, 2011, and they reference a law to which I was not familiar - Uniform Time Act of 1996, 15 U.S.C. § 262 (2006). In the protest decision GAO states:

    "..We have previously held, that under the Uniform Time Act of 1996, 15 U.S.C. § 262 (2006), there is one standard time for most governmental purposes, including the time designated for receipt of proposals or opening bids, and that time is the local time, regardless of whether it is referred to as standard time or as daylight savings time in the solicitation. 49 Comp. Gen. 164 (1969) (standard time and daylight savings time are one and the same for purposes of designating a bid opening time); Environmental Control Division, Inc., B-255181, Feb. 16, 1994, 94-1 CPD ¶ 115 at 4...."

    Based on this information I would suggest using local time.

  4. Thanks Vern.

    So, to revise my question, what are some good oversight measures that Program Managers can implement to ensure adequate oversight on complex T&M efforts? Where should these measures be described in a contract file? Should oversight measures be described in a solicitation?

    I would suggest you review the "DOD COR Handbook March 22, 2012" that might give you a good starting point:
  5. I don't recall the full funding principle applying to the appropriation year, only the appropriation amount. Having said that I would suggest that you write a memorandum to both your activity General Counsel/JAG and Comptroller and request a formal written opinion. Also, I seem to recall a number of years ago DOD General Counsel directed DOD Contracting Officers to request answers to fiscal questions to their office vice going to GAO. At one time a CO could go to GAO and request an opinion but DOD General Counsel put a stop to that.

  6. You need to review your department/agency guidance. I have seen guidance where if there is a question whether or not a trip is a "conference" the guidance designates a POC to assist in making the determination. Additionally, if there is a determination that the trip is a "conference", along with obtaining approvals, there are reporting requirements including posting the information at the department/agency public website. It would be best to refer to your internal guidance. I hope this helps.

  7. I have not seen anything on an extension. Hopefully it will be in the FY 15 NDAA and perhaps that will pass after the elections. I think Congress is very reluctant to make the program permanent because when agencies are periodically asked for data to support its use and effectiveness it's my understanding that the data is not forthcoming. I would suggest monitoring the FY 15 NDAA bill in the House and Senate and see if it is in the final bill that goes to POTUS.

    On a related note GAO did a review of the program in February 2014 and here is a link to the report: http://www.gao.gov/products/GAO-14-178

  8. Does your Agency HQ review your procurement office? If so are there findings that you could use as areas for the training? Have you reviewed your Agency OIG audits for findings related to procurement? These are sources that may give you specific areas for your Agency that you need to provide procurement related training in your office.

  9. I would agree with you that with the COFD/CDA route - we are leaving the administration world and jumping head-first into the litigation realm. Unfortunately, I have both the head of contracts and general counsel involved in discussions on this matter and - although the cash flow is material - they all want to wait it out, but somehow expect me to pull a rabbit out of my hat to be able to collect the variances before de-obligations occur.

    I would not recommend waiting it out. Vern Edwards had a very informative blog entry on a contractor waiting things out to their detriment as well as some helpful tips to all contractors that I would suggest you review:

    http://www.wifcon.com/discussion/index.php?/blog/2/entry-1346-tips-for-the-clueless-would-be-contractor/

  10. policyguy...a quick follow up to your question #3. I don't deny that this is what the CO rhetoric claims, but I am wondering if "business managers" are different than "business advisors." Business managers assume control over the business line, whereas business advisors provide feedback and information without necassarily intruding on the decision making capacity of the project manager. Do you think this perception leads to a certain level of contention that often exists between COs and PMs? In other words, who is really in charge? Who should be?

    This is a never ending debate. Just wondering what your thoughts are on it.

    JJ

    Nothing that in depth. This was a manager/supervisory position that these questions were used and hence the term business manager.

  11. Below are questions that I used for GS-13 Contracting Officer panel - - it is more than three but still may be of help to you. Edit as you need to fit your office/position

    1. Why are you applying for this position and what are your expectations? Also, what do you look for in an Contracting Office?
    2. Looking back over your career, which procurement stands out in your mind and why?
    3. For the past few years, contracting professionals have been encouraged to think more like “business managers.” Please discuss how you have incorporated this into your contracting responsibilities/practices.
    4. What organizational and personal skills do you possess that you believe would set you apart from the other candidates being considered for this position?
    5. What do you perceive as your greatest weaknesses?
    6. Many times customer demands/expectations/desires conflict with regulatory requirements by which contracting professionals must abide. What steps would you take to resolve the conflict and ensure customer satisfaction?
    7. What motivates you?
    8. You are assigned a FAR Part 15 competitive negotiated acquisition. What do you see as the essential elements to successful contract award?
    9. Customer service is a major value proposition of this Contracting Office. What does customer service mean to you? Provide examples of how you have displayed a customer service driven attitude.
    10. Would you like to add anything for us to consider?
    11. Do you have any questions for us?
  12. I would first recommend you check DoD 7000.14-R Financial Management Regulation Volume 2A, Chapter 1, paragraph 010202 that provides exceptions to full funding of procurement programs. The most recent edition I could find was from October 2008 that made changes in this area and may be of help to you. Not sure if there is a more recent edition but again I would check the DOD FMR first.

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