woops85

^{I used CPS as a vendor. I was given a chance to respond but the notification went to an email address that someone had put in the system. My company used a group email, along the lines of contracts@abc.com, to avoid missing notifications in case someone was out of the office. If the address entered belonged to someone who had left the company, there's a chance the vendor never saw the negative rating. I'm not sure if anyone on the Govt side (other than a CPS admin) would have seen an undeliverable email notice, let alone acted on it}

What I've seen done is that support contractors serve as advisors - they read the proposals/listen to the orals and the Q&A. When the evaluators are doing their individual evaluations, they are present only to answer questions and they leave before any consensus discussion begins. Sometimes the TEB chair will give the evaluators a few minutes to gather their questions at the beginning and then the tech advisors give their answers and depart before the individual evaluations are done. But the advisors are always briefed beforehand that they are not to give opinions on ratings but to help members understand the benefits or risks to the Govt. And yes, that's a fine line that some have trouble not crossing

Make the program office draft all the paperwork associated with one of the funding swaps so they see what's involved. I'm assuming you are in an organization that includes all the line of accounting information in the contract, which means a lot of doublechecking to make sure all the right numbers got changed.

Agree with Vern. I used to have folks tell me they could not close out their orders for same reason. They'd have $50K of travel on a $10M and want to wait 5 or 6 years for the vendor to get its audited rates. Had a lot of discussions about "unreconciled indirects"

Thanks All. The majority of vendors they use now are on Schedule 874 (old 69).

We've looked at doing a BPA, but the overhead associated with it doesn't make economic sense. We have training locations across the country and a whole variety of subjects. So we could establish (a) multiple single-award BPAs that cover a particular range of classes presented anywhere; ( b ) multiple BPAs with a regional focus (which BPA you use is based on where the class is presented); or © multiple award BPAs that require competition for each order. But the real problem comes in post-award. If we have a BPA, we have a CO involved in each order (I can't use an SF-182 as ordering instrument because of way finance and contracting systems interact - or don't interact). Our acquisition shop wants 10-20 days to complete a commodities delivery order, even sole source, That includes de-obligations and cancellations if a class got cancelled. We run about 20 classes a month and each class could be a separate order (yes, good planning would mean we could order as a group but we need to collect tuition so we can pay the vendor as we don't get a centrally funding training budget).

Thanks for comments on the BOA. Looks like I'll concentrate my efforts on good market research and procurement practices since the majority of the buys are above micro-purchase (about $15-20K)

Thanks. I don't work for the Army and my agency guidance says the training official can use the 182. But I just came from an acquisition shop and it's the lack of market research here that worries me. Vendor comes in and makes a pitch to a training official and next thing you know, the 182 is done. Don't ask for discounts; don't get copies of curriculua/lesson plans that show course objectives, topics and about how much time will be spent; don't audit a class to see if their instructors know their stuff; don't check references - if you like the sales guy, the company gets to teach. They ordered a series of FAC-P/PM courses from one company earlier this year and had to get the instructor replaced mid-class during the first course (was a Level III course and he was teaching them like first graders). Part of the reason I was hired was to get them to start using good procurement practices.

@formerfed - the training I'm referring to is the mandatory and role-based training our agency brings instructors in to present - things like appropriations law, acquisition courses, project management, leadership, supervisory, financial/budget, office applications and communications. Courses qualifying for tuition assistance are not within my purview.

But my original question remains - is it worth the time/effort to establish BOAs with training vendors to have an approved providers list? Or do I skip that and just work on improving and documenting the market research aspects of each buy?

My new agency allows the use of an SF-182 to procure training up to the SAT. The people procuring the training are currently NOT required to be 1102s, CORs, or have any training on Simplified Acquisitions. So that means we have lots of training bought without getting multiple quotes or looking at small business status. But we're working on fixing all of that, especially the training part.

We're trying to establish the new way of doing business. We've thought about doing a multiple award BPA for instructor-led courses but post-award adminstration would be a nightmare. Most vendors want 15 -30 days notice of cancellation and many classes don't fill up until the last minute. It takes 2 weeks to get a requisition through our financial system (mainly due to it being new and the learning curve) to contracts, who then need 10 days to process. That means lots of potential cancellation fees.

Additionally, they still want to use the SF-182 as an ordering instrument. So I wanted to get thoughts on using Basic Ordering Agreements to establish what would be a preferred vendors list. But I don't have any experience with agreements - I'm the Program person, not an 1102. I'm thinking we could have a panel review vendor responses and the outcome would be a list of vendors whose curricula for various courses has been approved to be taught within the agency. Could have some sort of process to add new offerings/vendors as well as take people off the list if there's a quality problem (shown by course evaluations). Then training coordinators could get quotes from the folks on the list who offer the class they need and still use the SF-182 to place the order.

So thoughts?? What obstacles am I not seeing? What ways have you seen training procured that have worked well? Our agency has folks nationwide and runs about 20 classes a month in classrooms across the country. Trying to find a way to ensure quality of the training as well as the procurement process. Oh and we are very decentralized but could get an agency mandate to use a BOA or other process if one existed.

Thanks

LM - In your accounting system, you should be able to establish SubCLINs that allow you to track the fee and non-fee bearing parts separately for your internal purposes and still allow you to bill at the single CLIN level as specified in your contract. Get the person in accounting who is smartest on the ins and outs of your system - they should be able to come up with a solution.

@contractgeek - doesn't matter who CAO was. In GSA that's a pure policy role - it's a lower level that is responsible for making sure the rules are followed on a daily basis. Each service (FAS/PBS) at the Regional level has someone designated as HCA and Comp Adv. And since most of the individual actions wre valued at less than $650K, approval for sole-source would have been one level above the CO, not even the Comp Adv.

You agreed to the labor rates at time of award, having seen what went into them. You want to adjust the rates if the contractor's overhead or G&A decreases. So you are also going to adjust the rate every time the average direct labor rate of employees in a labor category change (due to raises, turnover, etc)? What if the the overhead or G&A increases? Are you going to adjust them upwards?

Speaking from my vendor days - negotiating the initial labor rates for the contract years is where the contractor takes his risk. He's basing his proposed escalation rate on what he thinks will happen in the economy (raising direct labor costs), what will happen with his OH and G&A rates and trying to make a little profit. It's up to him to control his OH and G&A rates or he is effectively reducing his profit percentage.

When I had turnover on a T&M contract, the directive was to hire a repalcement who fit the labor category qualifications as cheaply as I could. Not everyone in the labor cat had to make the same annual salary, but the goal was to make sure the average rate of people in the same labor cat on the same contract stayed below a target number. That way, the OH, G&A and profit were all covered. Sometimes by the end of a contract we were making a larger profit on one labor cat than another - but that was OUR problem, not the Government's.

I missed the first part with the opening statements and Rep Issa's questions - did Neely take the Fifth in response to what's your job title? I thought Robertson came off looking the worst with the teeth pulling to get the name of who he spoke to at the White House

"What we plan on doing is asking each offeror to essentially answer 5 questions pertaining to their technical and staffing approaches. The evaluators are going to review the responses, document the strengths and weaknesses of the responses, and determine which offeror is the most highly qualified from a technical proposal. There will be no proposal scoring, and we're not even developing an evaluation plan"

GSA Region 3 Assisted Acquisition Services has done something similar for their Oral Presentation portion of the proposal. Can get you a POC over there who can hook you up with a CO who was involved. If interested, message me

Vern - That picture isn't from the conference. It's from something dealing the Capital BikeShare program here in DC - I can't tell from the background if they are over by One Constitution (GSA swing space) or somewhere else.

Martha resigned because it happened on her watch (not even sure if she attended the thing at all, let alone for the whole time). Bob Peck was forced out for the same reason. Leeds - probably because he's Martha's advisor and no where for him to land if she's not there. Would bet that the Reg 9 PBS RC is on admin leave since he's a career and not a political. In the end, this will prove to be a few employees trying to please a boss who said let's make this over the top and the ones who will wind up on the street are the politicals - who may have been gone by Jan 21st anyway depending on the November results.

May be too late if you've got the proposal already, but use a Statement of Objectives instead of a Statement of Work and then the offeror's proposed PWS (which hopefully documents the innovative processes) becomes part of the contract. If you've already gotten the proposal, then the CO could incorporate all or parts or the proposal into the contract by reference. I say "or parts" because there may be something you all don't want to incorporate. But I'm not a CO, so will let those that are comment on the possibility of only incorpoating sections of an offerors proposal into a contract by reference. It may be an all or nothing thing.

One of the best things about contracting is there are generally a bunch of possible ways to fulfill a requirement. Then you add in the circumstances, local rules/guidance and the list narrows. And then someone (maybe you down the road) makes the decision on the remaining options and the procurement takes off down the selected path. .So as a new guy, master the art of asking Why in a way that doesn't tick a person off. It's an art because the technique will vary based on who you are dealing with. You need to ensure they understand that you aren't necessarily questioning their decision but are simply trying to understand all the factors that caused them to make it - and many times one of them is the CO's past experiences.

Welcome to the ride!

Convince your CO that since it's a "fixed fee" pool, it should be fully funded on the first increment of funding applied to the option year.

I hadn't heard that there's a requirement for anyone but the VA to use VetBiz, unless an agency has adopted it as the authoritative source in its own guidance. If someone has a directive that applies to all agencies, can you point me to it? Thanks

Agree with all Vern said. Been in your shoes and there's no good solution. Of course, since T&M is out of favor these days, you can always hope that the next contract will be CPFF and then the Govt will directly feel the impact each time they push for a raise to the staff.

ji20874 brings up a good point. Assuming the labor portion was not funded to ceiling and therefore you aren't talking about a ceiling increase, your system may consider the movement of funds from one CLIN to another as a de-ob from laboe and obligation to ODCs. Since funds are expired, they would be ineligible for obligation at this point in time and system may prevent it. However, if your system does not tie the lines of accounting to the CLINs, then you may be able to do so systemwise because the system doesn't count it as a de-ob/re-ob. In my part of GSA the system would allow us to do it - but the finance folks who certify the funds would raise questions.

If protest was filed within 10 days of award, then you are at mandatory stay of execution unless you go for an override. If it's the base IDIQ that was protested, then you shouldn't award any task/delivery orders underneath it unless you get the override approved. If it's an order that was protested, then you issue a stop work and figure out how to extend the incumbent's POP through the protest period (if it ends before then)

RCS - Say your IDIQ base POP was 1 April 2011 - 31 March 2012, with 4 options. Your CO just exercised the first option so your IDIQ POP is now 1 April 2011 - 31 March 2013. Therefore your issue date of the task/delivery order is within the POP of the IDIQ and you're good to go

Who says your period of performance must begin on the date of award? If you issue a services order at 10PM with a POP that starts that same day, you have a lost a day's service.

Our tech eval boards don't assign a ranking, just a rating to the tech proposal. Our pricing team only assigns an Acceptable/Not Acceptable rating to the cost proposals and documents there reasonableness/realism (depending on what RFP said). Then the SSA (usually our KO) will make the determination of apparent winner, second, etc. The KO does a trade-off analysis among all proposals that were rated acceptable or higher and that have a lower price than the apparent winner based on tech ratings. If we get less than 4 proposals, the KO often doesn't establish a competitive range. If a competitive range is established, the trade-off analysis is done on everyone in the competitive range. This process has worked well for us - our post-award protest rate is just under 4% and we've only had one sustain (and that dealt with OCI analysis).

Disadvantages - it takes time to educate the TEB on how to describe the value of a proposal's strengths without talking dollars.

Kelly Clarkson - "Don't Be a Girl ABout It". Simply because the lyrics make me laugh and that's needed on a Monday