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22 hours ago, Vern Edwards said:

The main difficulty is COs who feel they must apply a "beyond a reasonable doubt" standard when making their commerciality determinations in order to avoid criticism.

This is yet another reason why DOD needs its own acquisition regulation, if for no other reason than to free everybody else from the insanity of its processes.

Vern, to be honest I don't see the logical connection between your two statements, quoted above. If the regulations permit a legitimate Commercial Item Determination (CID) then shouldn't the COs feel confident in making it, or in accepting a well-documented contractor CID? In other words, how is this issue anything other than a workforce training issue, or perhaps a workforce "courage" issue (for lack of a better term).

No unique Armed Services Procurement Regulations, even if supplemented with robust Procedures, Guidance, and Information, would solve that fundamental workforce culture and/or training problem, in my view.

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