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Limitation on Procurements on Behalf of DoD


cogp2

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Federal Register Feb 11 had a final rule amending DFARS relating to interagency procurements on

behalf of DoD.

Q1: What will be the practical effect on DOD's use of GSA contracts?

Q2: Any change in predicted usage?

Q3: Why was this change necessary? I know the law said so, but what/who drove the law?

Q4: How does this help streamline, simplify, expedite the process?

R,

Bob Thompson

cogp2

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Guest Vern Edwards
Federal Register Feb 11 had a final rule amending DFARS relating to interagency procurements on

behalf of DoD.

Q1: What will be the practical effect on DOD's use of GSA contracts?

Q2: Any change in predicted usage?

Q3: Why was this change necessary? I know the law said so, but what/who drove the law?

Q4: How does this help streamline, simplify, expedite the process?

R,

Bob Thompson

cogp2

I can't answer Q1 and Q2. As for Q3, Congress passed the law in order to prevent DOD from going around the contracting rules that apply to it by going through another agency. As for Q4, it doesn't help do any of those things.

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Ref Q1 - see below from DPAP website under Interagency Contracting at http://www.acq.osd.mil/dpap/cpic/cp/intera...cquisition.html

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In accordance with the requirements of section 801 of the 2008 National Defense Authorization Act, the Director, Defense Procurement and Acquisition Policy (DPAP), Mr. Shay D. Assad, signed a "determination" that it is "necessary and in the interest" of the Department of Defense to utilize the acquisition services of the Department of Energy in FY 2010 for "essential mission related requirements." The determination can be found here. Component single focal points (see DPAP memorandum of September 18, 2009) are encouraged to contact Michael Canales of DPAP/CPIC (Michael.Canales@osd.mil 703-695-8571) with any questions and to discuss reporting requirements.

Section 801 of the Fiscal Year 2008 National Defense Authorization Act (NDAA), "Internal Controls for Procurements on Behalf of the Department of Defense by certain Non-Defense Agencies," required the heads of all non-DoD agencies that provide acquisition support to the Department certify that their respective non-Defense agencies will comply with defense procurement requirements for FY 2010 for assisted acquisitions executed on behalf of DoD in FY 2010.

The Following non-DoD agencies have certified

Department of Veterans Affairs

General Services Administration

U.S. Department of Commerce

National Aeronautics and Space Administration

Office Of Personnel Management (OPM) ? Management Services Division

United States Department of the Interior

U.S. Department of Health and Human Services

Certifications are not expected from the following agencies

U.S. Department of State

Central Intelligence Agency

Federal Bureau of Investigation

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So there should be no effect on Dod's use of GSA contracts since GSA has already met the certification requirement

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