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bob7947

S. 2413: Bridge Contract Transparency and Accountability Act of 2018

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S. 2413:  Bridge Contract Transparency and Accountability Act of 2018, was introduced on February 8, 2018.  This one appears to ask for a study (within 180 days of enactment), some interim guidance (within 30 days of the enactment), and then some reporting for a period of years.  There are 4 sections of goodies.  I believe this was initiated based on a hearing from last year.  I couldn't find a press release.

What do you think of this gem?

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Honestly, I think a number of people are fed up with seemingly infinite extensions of incumbency because of reasons (some legit, others not so much). This is what you get when you don't get contracts awarded timely.

And I didn't see anybody here up in arms about measuring PALT. In my view, that's another message from our fiends (sic) in Congress that they believe (rightly or wrongly) that acquisition results can be improved, in terms of timely contract awards.

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You can only do so much with the resources you have.  You have to base speed of award and value of the contract on the average worker in your organization and not the superstars that quickly move up the ladder and we lose their skills.  And of course for each person above average there is one below average. PALT needs to count against the whole acquisition team including the program office.  Every action over $100M should have a formal acquisition team established and their whole job is awarding that contract.  It should not be just 5% of everyone's duties  with a CO who has to administer dozens of other contracts at the same time.  No wonder the requirement takes so long to write that it has to be rewritten twice more due to changes in the mission.  Three years and two urgent and compelling bridge contracts later we are still trying to solicit it.   

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On 2/18/2018 at 8:01 AM, bob7947 said:

I believe this was initiated based on a hearing from last year.  I couldn't find a press release.

See SOLE SOURCE CONTRACTING: Defining and Tracking Bridge Contracts Would Help Agencies Manage Their Use, GAO Report 16-15, dated October 2015, which was requested by Senators R. Johnson and T. Carper and sent to Senator C. McCaskill.

https://www.gao.gov/assets/680/673110.pdf

Sen. Johnson co-sponsored the bill.

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You would think Congress would be the last group to complain about bridge contracts given the number of continuing resolutions they pass.  I read that between 1977 and 2015, Congress only passed all twelve regular appropriations bills on time in four years.  In 2011 alone, there were 7 CRs. 

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On 2/18/2018 at 8:41 AM, here_2_help said:

And I didn't see anybody here up in arms about measuring PALT.

Issues with PALT (Procurement Administrative Lead Time, aka Procurement Action Lead Time) are not new. The following is from the executive summary of a March 1977 report by the US Army Procurement Research Office:

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In recent times procurement managers have complained that Procurement Administrative Lead Time (PALT) policies have taken too much management prerogative out of their hands . Existing PALT management practices must be re-evaluated in terms of the value and usefulness. Procurement Managers need a more appropriate set of PALT management criteria against which to measure the effectiveness of the mission for which they are responsible. Thus, by measuring accomplishments against PALT management criteria , procurement managers will be better able to plan , direct , manage and control the pre-award procurement cycle. This study looks at the traditional PALT practices in order to develop more appropriate PALT management and performance criteria.

http://www.dtic.mil/dtic/tr/fulltext/u2/a038732.pdf

The concern of many about the new focus on PALT (see Opportunity for Public Comment on Proposed Definition of “Procurement Administrative Lead Time” or “PALT” and the Plan for Measuring and Publicly Reporting Data on PALT for Department of Defense Contracts and Task Orders Above the Simplified Acquisition Threshold," A Notice by the Defense Acquisition Regulations System on 02/09/2018) is that it would define PALT as follows:

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“the time between the date on which the initial solicitation for a contract or task order of the Department of Defense is issued and the date of the award of the contract or task order.”

 That would measure source selection lead time---the time between issuance of the RFP and contract award. That is not the traditional definition of PALT as defined in the above cited study based on the 1977 Army Regulation 310-25:

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The first major component of PLT {Procurement Lead Time} is administrative lead time (ALT), which is defined by AR 310-25 (1) as “the time interval between initiation of procurement action and letting of a contract or placing of an order. ”

"Initiation of a procurement action" was defined as:

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Initiation of procurement action is “that point in time when the approved document requesting procurement and citing funds is forwarded to the procuring activity."

The current DAU Glossary of Defense Acquisition Acronyms and Terms, under Procurement Lead Time, says:

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General Information/Narrative

Procurement Lead Time is a term sometimes used interchangeably with the terms Procurement Action Lead Time, Contract Action Lead Time, and Administrative Lead Time. Precise terminology varies among contracting officers and across agencies, but organizations use one or more measures of lead time for internal management and efficiency purposes.

Procurement Action Lead Time (PALT)

This is the amount of time required to complete the actions leading to contract award. It begins when the approved requisitioning document is received in the contracting activity and lasts until a contract or order is awarded. PALT includes the time required to process/assemble the purchase request (including the independent government estimate), statement of work/performance work statement, technical exhibits/attachments, service contract approvals (ref. DFARS 237.170-2), quality assurance surveillance plan for services, and any applicable sole source justification & approval. It also includes the time required to solicit the Government requirement, evaluate the offers received, and obtain necessary approvals before making the final contract award. PALT does not include Production Lead Time (see the section on Production Lead Time below).

PALT is used by management to forecast contract awards and plan workload. It may also be used to evaluate the efficiency of contracting personnel. 

Contracting people don't like the new proposed definition of PALT, because much of what happens between issuance of an RFP and contract award is not within their control, and they don't want their work to be judged on that basis.

Several related concerns are reflected in recent legislation:  (1) concern about how long it takes to get on contract (seemingly forever), (2) concern about sole-source bridge contracts and poor planning, and (3) concern about the impact of the protest system on the acquisition process.

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This bill was amended and reported out of the full Committee but the amended bill is not published yet.  

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On 2/21/2018 at 9:19 AM, Vern Edwards said:

Initiation of procurement action is “that point in time when the approved document requesting procurement and citing funds is forwarded to the procuring activity."

The biggest problem is that PALT is typically designed, implemented, and managed by those with the least procurement knowledge or ability, as evidenced by the above "definition".

Just provide a funds cite and the magic happens.  And to think I wasted years learning this stuff.

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