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FAR 12.6 Streamlined Procedures for Commerical Items


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Could someone please help me with this scenario:

We have a procurement for a commercial service that is above $150,000. We are looking at simplifying the process using FAR 12.6, however it is rather vague.

For example 12.602 advocates using simple criteria to be evaluated and the that the "technical evaluation would normally include examination of such things as product literature, product samples (if requested), technical features and warranty provisions"

If we went this route, could someone tell me how the technical evaluations mentioned in FAR 12.602 would be different than formal tech evals using FAR 15? To me, it sounds very informal, and the write-ups would be more simple. Is this correct?

Thanks,

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Guest Vern Edwards

The FAR Subpart 12.6 process is governed by FAR Part 15 if you are not using simplified acquisition procedures. FAR 12.602 should not be read as exempting commercial item buys from Part 15 if the value of the procurement exceeds the simplified acquisition threshold. The main difference is between Subpart 12.6, on the one hand, and sections 15.203, 15.204, and 15.205 on the other, because under 12.6 you combine the synopsis and the solicitation and the solicitation format is simpler. Just about everything else in Part 15 applies to procurements under Subpart 12.6.

FAR 12.602 promotes the use of simple criteria because the presumption is that you don't need a lot of complex criteria when buying a commercial item. That may or may not be true, depending on what you're buying. However, the technical evaluation of proposals is still subject to the rules in FAR Subpart 15.3. I would not say that the evaluation process is "very informal," whatever you meant by that, but it should be as simple as you can make it.

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Vern,

Thanks for your response. I understand why the solicitation process is streamlined. Its pretty clearly explained in 12.603.

However with regards to evaluations, the way 12.602 is written, seems to suggest that you are to evaluate proposals differently that you would in 15.3. If not, then why is it called Streamlined Solictations AND Evaluations? If we still have to follow 15.3 then what is streamlined?

Maybe "very informal" was a poor choice of words, but what I meant was something along the lines of this: Using the simple criteria contained in the solicitation, the technical evaluator writes a brief narrative on how the proposal meets the criteria and assigns a rating for the proposal. There is no technical evaluation plan, no source selection board etc..

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Guest Vern Edwards

Source selections in commercial item acquisitions ought to be simpler because most such acquisitions will be for off-the-shelf type stuff. In many if not most cases you can have fewer evaluation factors and simpler proposals. The result would be a simpler evaluation. Otherwise, FAR Subpart 15.3 fully applies. FAR does not require an evaluation plan, and if you have only a few factors and a simple proposal you may not need one, unless agency or local policy require it. If have only a few factors you may not need voluminous documentation. The length and complexity a a technical evaluation report depends largely on the number and complexity of the evaluation factors.

Look, you should always try to keep source selections as simple as possible, but nothing in FAR 12.602, nothing, frees you from the requirements of FAR Subpart 15.3. You must make a document your evaluation and your decision. You seem to me to be reading things into FAR Subpart 12.6 and 15.3 that simply are not there. What may be happening is that you think FAR Subpart 15.3 requires more than it really does.

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You could use any form other than the 1449 I guess but suggest you are defeating the purpose of combined synopsis/solicitation. The posting to FBO is the solicitation when you folllow the format provided for in the FAR. A further suggestion is that you might want to look at FBO to see how other agencies are doing it, many without a FAR form, to get an idea on how you might format your solicitation.

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I admit I am showing my government bureaucrat side in wanting to use a SF. I just like the familiarity of them.

The benefit I see of a combined synopsis/solicitation is in not having to follow the time requirements for synopsizing and soliciting seperately.

Thanks for your response.

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