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We're having a discussion in my office about who is supposed to prepare the acquisition plan required by FAR. I work in a system program office. Is it the contracting officer or the program manager?

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Both, and others. See FAR 7.102(B). In my experience, it doesn't happen that way. I've worked in offices where the 1102's have to try to define the technical requirements of the acquisition plan, and then more recently worked in a systems office where the Program Managers Office did the plan, including the acquisition specific items (contract type, POAM, evaluation criteria). Neither was an optimal or efficient method. I've never seen a true, collaborative effort where people sat around the table and discussed each of the elements in the early stages of the acquisition; hopefully it exists somewhere.

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We're having a discussion in my office about who is supposed to prepare the acquisition plan required by FAR. I work in a system program office. Is it the contracting officer or the program manager?

In DoD, it's the program manager's responsibility. DFARS 207.103(g):

The program manager, or other official responsible for the program, has overall responsibility for acquisition planning.

If you're not in DoD, then check your agency supplement.

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In DOD, if the program manager writes the plan, does he select the contract type?

Response: The program manager has overall responsibility for the acquisition plan but uses the responsible professionals to develop it and must coordinate with Contracting and Small Business advocates.

From FAR 7.104(a):

"...In developing the plan, the planner shall form a team consisting of all those who will be responsible for significant aspects of the acquisition, such as contracting, fiscal, legal, and technical personnel. If contract performance is to be in a designated operational area or supporting a diplomatic or consular mission, the planner shall also consider inclusion of the combatant commander or chief of mission, as appropriate. The planner should review previous plans for similar acquisitions and discuss them with the key personnel involved in those acquisitions. At key dates specified in the plan or whenever significant changes occur, and no less often than annually, the planner shall review the plan and, if appropriate, revise it."

See FAR 7.104 ©:

"© The planner shall coordinate with and secure the concurrence of the contracting officer in all acquisition planning. If the plan proposes using other than full and open competition when awarding a contract, the plan shall also be coordinated with the cognizant competition advocate.

(d)

(1) The planner shall coordinate the acquisition plan or strategy with the cognizant small business specialist when the strategy contemplates an acquisition meeting the dollar amounts in paragraph (d)(2) of this section unless the contract or order is entirely reserved or set-aside for small business under Part 19. The small business specialist shall notify the agency Office of Small and Disadvantaged Business Utilization if the strategy involves contract bundling that is unnecessary, unjustified, or not identified as bundled by the agency. If the strategy involves substantial bundling, the small business specialist shall assist in identifying alternative strategies that would reduce or minimize the scope of the bundling.

(2)

(i) The strategy shall be coordinated with the cognizant small business specialist in accordance with paragraph (d)(1) of this section if the estimated contract or order value is?

(A) $7.5 million or more for the Department of Defense;

(B) $5.5 million or more for the National Aeronautics and Space Administration, the General Services Administration, and the Department of Energy; and

© $2 million or more for all other agencies.

(ii) If the strategy contemplates the award of multiple contracts or orders, the thresholds in paragraph (d)(2)(i) of this section apply to the cumulative maximum potential value, including options, of the contracts and orders."

"

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As an aside to this thread, I am posting a favorite "Vern-ism" of mine:

As the chief of a contracting office, I would insist that contracting always write the acquisition plan. He or she who writes the acquisition plan gets the first shot at steering the destiny of the acquisition. As a leader, I would want that power and influence. I wouldn't want to be just an implementer. Anybody can do that. I would want to be at the helm. I would want the power to say: This is that way that it ought to go. I'd be damned if I would cede that power and influence to anyone else.

When I was an intern, the interns in my program jumped at the chance to write the acquisition plan. It was considered to be a singular opportunity, especially on big procurements. You got to go to the meetings, to meet the bigwigs, to give presentations and be seen, to impress, and to lay the foundation for your professional future. Hell, I knew interns who wanted to write everything: the statement of work, the acquisition plan, the source selection plan, and the source selection decision document. I was one of them. We would put a block on the signature page: Prepared by: __________________________.

But don't listen to me. I only went from GS-05 to GM-15 in the minimum time allowed by law. Writing acquisition plans was one of the ways I did it.

To all you interns: Seize every opportunity to excel. That's how you get ahead. Turn that grungy acquisition plan into a masterpiece of acquisition planning. Show the bosses what you can do. BE the plan! Let everybody else cut and paste your work.

http://www.wifcon.com/discussion/index.php?showtopic=18

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.

from GS-05 to GM-15 in the minimum time allowed by law.

As I understand the law, that would be, what, 366 days ?

I believe that the fastest way to rise in civil service is to get out, wait a year, then come back in without the time-in-grade restrictions holding you back.

.

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  • 5 years later...

My apologies, in advance, for the following rant. I'm just extremely frustrated by the lack of quality leadership and knowledge out of my senior leadership:

I was just told, by my Branch Chief (essentially the Head of the Contracting Activity, in my agency) that he doesn't see the value in preparing an Acquisition Plan for simplified acquisitions. Our internal policy allows for the use of an acquisition summary sheet (which is prepared POST-award) or small business form (think DD-2579, but a civilian version) all the way up until the acquisition hits $6.5M.

I prepare an acquisition plan for every requirement that hits my desk, and in accordance with FAR 7.105. Am I really the exception in this day and age? I was taught, very much in line with Mr. Edwards reasoning, that preparing the Acquisition Plan was a way to perform "above and beyond" and show managers your enthusiasm and professional expertise.

When the bosses stop caring about the process and the product.....well, now what?

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Hi, NoDegree,

If you are purchasing 20 staplers, I hope that acquisition plan is very short. That may have been the type of simplified acquisition your HCA was thinking of.

If you are purchasing a 250K study, then you are defninitely on to something.

But to reference another Vernism, if you are an 1102, you should never purchase staplers. The clerk should. You should be writing awesome acquisition plans. Precise and complicated plans . . .

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I don't see the need for a written acquisition plan for EVERY acquisition. Whether 1102 or 1105, many simplified acquisitions simply don't need a written acquisition plans, and some agency FAR supplements establish dollar or category thresholds for written plans. For many simplified acquisitions, the time spent on written acquisition plans might be better used on other work.

Note: I'm not opposed to written acquisition plans, but I am always in favor of meaningful planning -- but where the FAR or agency supplements don't require written plans, then there is no need for contracting personnel to write plans -- they could be doing other work. For routine acquisitions, I favor check-the-box and fill-in-the-black acquisition plans rather than starting from a blank piece of paper.

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Guest Vern Edwards

A written acquisition plan is necessary when (1) there are multiple participants in multiple organizations who need to know what the plan is and what is expected of them and (2) when it is necessary to obtain higher level approval before proceeding. If we're talking about a transactional acquisition (purchase order, delivery or performance, inspection and acceptance) and the only fully engaged participants are the buyer and his or her boss, then a written acquisition plan should not be necessary.

It is important to remember though, that simplified acquisitions can be worth several millions, involve multiple participants, and take a couple of months to complete, in which case a written plan is a good idea.

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Our office QA plan requires an informal plan for acquisitions above $150K that are not under FAR 13.5 and below $5M approved by a Division Chief. For acquisitions over $5M our agency supplement to FAR Part 7 requires a formal plan and our QA plan requires it be reviewed by branch, division, legal, Small business office and approved by the HCA. Comp advocate gets it too if it is going to require a J&A.

However, due to our rediculous workload, the informal plans are rarely done and the formal ones are rushed through the process at the last minute, sometimes after the solicitation is already issued (defeating the whole purpose of the document) just so it is on file IAW our agency supplement. Services over $25M have to be approved by an Assistant Secretary.

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Guest Vern Edwards

It is silly to require any kind of written plan for an acquisition of $150,000 or less. It does make sense to have some kind of plan for acquisitions in excess of $5 million, but approval by the HCA seems a bit much. You must work for a small agency.

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