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napolik

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Everything posted by napolik

  1. napolik

    Relevance of the Defense Acquisition Corp

    Have you just compared the old and new workforces?
  2. What does your solicitation say? Score adjustments were possible when GSA evaluated proposals submitted in response to the OASIS GWAC solicitation. See http://www.wifcon.com/analy/highest.pdf
  3. napolik

    Relevance of the Defense Acquisition Corp

    Phew! Do you have any procurement clerks or agents, or any contracting officers whose job is solely to oversee and train subordinate 1102s?
  4. napolik

    Relevance of the Defense Acquisition Corp

    Does this mean you believe the current 1102 workforce is implementing statute and regulation and supporting their clients better than the old workforce (i.e. procurement clerks, procurement agents, contract specialists and contracting officers) that was hired prior to the introduction of the college degree requirement?
  5. I infer that you're using a tradeoff or HI-ter-ferp approach. The greater the number of evaluators, the more likely the report will contain errors or confusion. This is particularly true in this era of "Cut and Paste" vice a bygone era of "Think and Write". If you were using LPTA, one person could do the evaluation. Depending upon the evaluation criterion/a, that person could be the CO.
  6. What is the estimated $ value of the procurement? Under which FAR part/ subpart will you conduct the procurement - 8.4, 13, 14, 15, 16.5? Are you using the tradeoff, LPTA, or HTRFRP process?
  7. Sacre bleu! On ne badine pas avec le CO!!
  8. napolik

    Leadership

    The millennials let their fingers do the talking and the walking on and off the job.
  9. napolik

    Leadership

    Email volume is a key performance standard.
  10. napolik

    Consideration in exchange NCE?

    Consideration is required for all contract types. See here: https://www.dau.mil/aap/pages/qdetails.aspx?cgiSubjectAreaID=28&cgiQuestionID=112375.
  11. napolik

    Use of 52.217-9 to extend IDIQ Ordering Period

    201.301 Policy. (a)(1) DoD implementation and supplementation of the FAR is issued in the Defense Federal Acquisition Regulation Supplement (DFARS) under authorization and subject to the authority, direction, and control of the Secretary of Defense. The DFARS contains— (i) Requirements of law; (ii) DoD-wide policies; (iii) Delegations of FAR authorities; (iv) Deviations from FAR requirements; and (v) Policies/procedures that have a significant effect beyond the internal operating procedures of DoD or a significant cost or administrative impact on contractors or offerors.
  12. The term BPA was created over 50 years ago for a Small Purchase instrument. For whatever reason, GSA chose to name as a BPA the Federal Supply Schedule (FSS) instrument described in FAR 8.405-3. They are different instruments subject to the different rules. The Simplified Acquisition BPA is subject to the rules set out in FAR 13.303; the FSS BPA is subject to the rules set out in FAR 8.405-3.
  13. Please provide the cite(s) supporting your conclusion. Also, please look at FAR 13.003(a).
  14. The term BPA was created over 50 years ago for a Small Purchase instrument. For whatever reason, GSA chose to name as a BPA the Federal Supply Schedule (FSS) instrument described in FAR 8.405-3. They are different instruments subject to the different rules. The Simplified Acquisition BPA is subject to the rules set out in FAR 13.303; the FSS BPA is subject to the rules set out in FAR 8.405-3.
  15. napolik

    A $1,220 Coffee Mug

    RU suggesting the AF is a bunch of caffiends?
  16. napolik

    Eliminate FAR 52.217-9?

    Security clearances and associated procedures.
  17. napolik

    Eliminate FAR 52.217-9?

    I believe the FAR is clear that there must be an option clause and that its substance must mirror 52.217-9.
  18. napolik

    Eliminate FAR 52.217-9?

    The FAR requires the use of an option clause: 52.217-9 is brief, simple and clear. I fear the results if each CO creates his or her own clause. Keep using 52.217-9.
  19. napolik

    Bridge Contracts

    Well, the GAO has just issued a new decision involving an allegation of lack of advance planning: Trailboss Enterprises, Inc., B-415812.2,B-415970,B-415970.2, May 7, 2018. https://www.gao.gov/products/B-415812.2,B-415970,B-415970.2
  20. napolik

    Bridge Contracts

    The decision recognizes the contracting office's obligation to track its contracts and their expiration dates and to take appropriate actions to award a competitive follow on contract: "Defendant’s subtraction skills notwithstanding, in the court’s view, the fact that three officers retired is not enough to excuse the agency’s failure to ensure it was properly staffed. As plaintiff notes in its supplemental brief, the GAO has sustained a protest in which the agency sought to justify a sole-source award on the basis of similar personnel issues. See ECF No. 74 at 13 (citing Service Contractors, B-243236, 91-2 CPD ¶ 49, 1991 WL 135563 (Comp. Gen. July 12, 1991). Service Contractors involved a sole-source contract award for grounds maintenance at properties for which the Department of Housing and Urban Development (HUD) was responsible. In the protest action, in which the protestor alleged that a non-competitive award was improper, the agency alleged that “personnel turnover and inexperience” sufficiently explained the need for a sole-source award. Service Contractors, 1991 WL 135563, at *1. The GAO disagreed, and held that the agency’s defenses related to inadequate personnel “essentially recognize the lack of advance planning and merely provide an excuse based on the limitations of the agency procurement personnel.” Id. at *3. The court agrees with this reasoning, and concludes based on the evidence in the record, that the agency’s inadequate staffing was due to its failure to plan for staffing needs in the relevant department."
  21. napolik

    Bridge Contracts

    Going back a few decades, contracting officer used to keep track of contracts' performance periods, including option periods. This was done via a pencil and a hard copy spreadsheet. Well before contract expiration, COs asked their customers about needs for follow on contracts. As time passed and IT entered the scene, keeping a list of existing contracts was facilitated, but the COs became unwilling or unable to perform these fundamental tasks. And contracting office managers did not hold COs accountable. COs that cannot track their inventory of procurement actions and that cannot correspond with their customers need to be stripped of their warrants and removed from supervisory positions.
  22. While DAU courses are important to reducing the lack of knowledge among contract personnel, I believe OJT is equally, or more, important. One can learn concepts in DAU courses offered in classrooms or on line, but the true meaning of the concepts and their application can be learned only on-the-job. The actual application of concepts, policies and procedures via the conduct of a procurement creates knowledge, not the viewing of Power Point slides in a classroom or on a computer screen. From my experience, very few, if any, contracting offices have an OJT program.
  23. napolik

    Paying for Proposals

    Either absorb the cost, or refuse to submit a quote/ proposal. Or, call the contracting officer, explain your concerns and hope for an amendment to the solicitation that reduces your burdens.
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