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21 hours ago, Vern Edwards said:

In short, the analogy between what you do and what the acquisition system must do is very, very weak.

Hmmm maybe not so weak if you consider the attempts to emulate what I do through creating commercial acquisition and the government purchase card.  Yet both got complicated and complex beyond intent.

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4 hours ago, General.Zhukov said:

I wonder if this is true.  My policy analysis training wants me ask 'failed compared to what?'  I want to compare the US fed acq system to other systems.  Are comparable acquisition systems - large states like CA, TX or NY, or overseas with vaguely similar legal structure like UK, EU, AUS, or Canada - 'better than' the US FAR system? By what metrics would the FAR way be better or worse? Someone, somewhere, has done this comparative analysis.  

What you are asking is a different question than the one I have asked. I suggest that you start your own thread.

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Take the case of an employee needing a highly specialized tablet.  Seems like something easy to buy?  First the requirement had to be screened against everything the agency had.  Then it had to be matched against what was available under all the potential other contract vehicles.  The person needing it had to write a four page justification and get six different approval levels.  The CIO had to research how use on the agency’s network might impact network performance.  Next the CIO checked to see how staff could support it along with the specialized software.  The IT security people had to verify security claims and determine if a CAC would work or a token is better.  Finally Labor Relations people got involved because bargaining unit employees were told only certain standard devices were given to employees.  

Seems complicated to me.

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@General.ZhukovI should point out that comparison of our system with those of other countries must take into consideration differences in the structure, content, and processes of government. Great Britain, for instance, has a parliamentary system, which is very different from ours. The doctrine of strict separation of powers does not apply. The two systems are different, operate differently, and must cope with different kinds of emergences. (That's emergences, not emergencies.)

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2 hours ago, C Culham said:

Hmmm maybe not so weak if you consider the attempts to emulate what I do through creating commercial acquisition and the government purchase card.  Yet both got complicated and complex beyond intent.

Government commercial acquisition is nothing like what you do, not even superficially, and the purchase card program is trivial in the overall scheme of things.

I don't want to argue with you about the analogy that you want to make. Even if I agreed with you, it would not contribute to this discussion. You are welcome to your opinion.

My question is whether the Federal acquisition system is a complex adaptive system and, if it is, whether that might explain why acquisition reforms based on rule changes have, by widespread consensus, failed.

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On 8/17/2021 at 10:24 AM, Vern Edwards said:

I am trying to determine whether acquisition reform efforts have failed because the reformers have thought of the acquisition system as merely needlessly complicated, when in fact it is unavoidably complex and adaptive. Thinking that it is merely complicated, they try to simplify it through rule reform. But if it's complex and adaptive, then simplification and rule reform won't work, in part because complex and adaptive systems are subject to emergence, which defeats rules.

I want to see if anyone else here has thought along those lines, and I want to learn what if any conclusions they have reached. Because I think that my thinking about this has been, in the words of Dylan, "limited and underfed."

@General.Zhukov and Vern, the next reformer should think hard on the above concepts too, and @C Culham I agree he/she should stick to his/her guns for the years it takes to follow through.  The acquisition system includes agency implementations as you drill down.  These agency implementations are demonstrative of how hard reform is.  Take DCMA for example.  The DCMA used to have an overly prescriptive manual of procedures.  It was best used for describing the steps a GS-11 should follow to pay an invoice.  It then bloated to instructing a GS-14 how to negotiate all of Boeing's intermediate home offices' costs.  As soon as the practitioner of it encountered emergence - which was pretty much anything, since a manual is designed for simple systems - that practitioner was like Wile E. Coyote running on thin air.  In a dynamic negotiation with industry, covering the entirety of a business unit's indirect costs for 5+ years out meaning tens of billions of dollars in revenue is on the line, it's safe to say industry comes more prepared than a manual can anticipate.  A reformer in the 2010's recognized that, and replaced procedures with DCMA Policies.  Then someone came along a few years later and copy/pasted the old manual into new, fancy Manuals.  It is so frustrating.  The reformer did not stick to his guns.

So, what do you do when you receive a Forward Pricing Rate Proposal audit finding from DCAA with which you have a basis to disagree?  Consult the Manual.  It says to bring the SESs together to let them decide what to do.  Not kidding.  From DCMA-MAN 2201-01:

Quote

(b) Receipt of a DCAA Audit.

1. Upon receipt of a DCAA audit report, the ACO must review the audit findings, determine whether the current FPRR/FPRA requires revision, issue a revised FPRR within 5 business days, and continue to work toward negotiating an FPRA if appropriate. In this case, the ACO can issue the FPRR with a memorandum for record (MFR) and the historical rate data, rather than with a PNOM. The DCAA position on FPRP must be reflected in developing the ACO’s FPRR position. The ACO must address DCAA unsupported costs and unresolved costs in either the PNOM or Price Negotiation Memorandum (PNM).

2. If the ACO deviates from the DCAA audit position, the ACO will discuss these issues with the DCAA auditor to obtain a joint resolution. If a joint resolution cannot be reached on significant issues and DCAA’s management requests DCMA management review of the ACO’s position, DCMA review will be accomplished IAW [Board of Review] BoR General Practice located on the main Resource Page of DCMA-INST 2201, “Indirect Cost Control,” prior to the issuance of the FPRR/FPRA. The ACO’s PNOM must document all discussions with DCAA, mutual resolutions, and/or differences of opinion. If major issues are escalated to DCMA management to assist in their resolution, the MFR or PNOM must document the results and conclusions of this management review process.

I don't know everything, but this is probably why the FPR Agreement is all but extinct.  I was not around when they existed.  Maybe the system was not so complex back then.  I hope this example helps.

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18 minutes ago, Vern Edwards said:

My question is whether the Federal acquisition system is a complex adaptive system and, if it is, whether that might explain why acquisition reforms based on rule changes have, by widespread consensus, failed.

Yes it could be concluded as a CAS.  Processes based on independence of players and not always statutorily required.  Acquisition reforms, in the context of FAR, DFARs and independent agency acquisition policy/regulations such BPA's  have addressed just one element of the system without integrating the policies of others, by example a CFO, and vis a versa.

Dare I be so bold as to wonder if the rule changes should be for everyone?

(created this post as WifWaf's post appeared.)

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1 hour ago, C Culham said:

Processes based on independence of players and not always statutorily required.  Acquisition reforms, in the context of FAR, DFARs and independent agency acquisition policy/regulations such BPA's  have addressed just one element of the system without integrating the policies of others, by example a CFO, and vis a versa.

@C CulhamGood observation!

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  • 2 weeks later...
On 8/17/2021 at 10:24 AM, Vern Edwards said:

I want to see if anyone else here has thought along those lines, and I want to learn what if any conclusions they have reached.

Vern,

General Martin E. Dempsey, USA (Ret.)thought along these lines in an undated white paper he wrote as Chairman, JCS in 2012.  The white paper was called "America's Military - A Profession of Arms".  I kept a copy as it was influential to my thinking at the time as a civilian employed on an ACAT I Program being canceled due largely to the acquisition system's failures.  Much of that failure was, according to to the IG, attributable to acquisition leaders having a plan on how to navigate the acq system, namely through commercial contracting, but then not following through.  Rotations out of leadership led to the backfills doing what they were used to - namely, DOD Instruction 5000.02 requirements and noncommercial contracting practices prescribed by FAR.  A strategy's failure results in perpetuity of the failing strategy.  This is a hallmark of a bureaucracy - see, for an extreme example, Thomas Ricks chapter on the Vietnam War in The Generals: "Rather than shift to what we need to do, we continue to do what we know how to do."

At the time he authored the white paper, Gen. Dempsey held three Masters degrees and had previously been Commander of U.S. Army Training and Doctrine Command.  He is a professor at Duke University now.  He must be an awesome educator, because you can see it shine through in his writing.  My favorite quote is provided below - this one paragraph was, for me, a license to kill bureaucracy the rest of that decade in my career, especially given my Program's cancellation:

Quote

Today, much of the Joint Force is employed in environments involving ill-structured problems and against adaptable, thinking adversaries who exploit opportunities at every tum. These challenges call for leaders at the tactical level to exercise greater personal initiative vice relying on the decision-making of echelons well above the point of action. Leaders must empower individual initiative by providing clear, concise, and complete mission orders in a climate of mutual trust and understanding. The future joint force will be one where junior leaders are empowered to exercise disciplined initiative based on clear guidance and intent. Institutionalizing mission command is imperative to prepare our next generation of leaders.

I have uploaded it here for readers as they may find it empowering in even more ways than I did.  Read from the Mission Command section on, for my quoted paragraph.  For more influential reading like this, see Sinek, S. (2010) Start with Why: How Great Leaders Inspire Everyone to Take Action.  This was a book I found useful at that same time of need, for career guidance.  There's more where that came from too, which I may add to the Recommended Reading Forum sometime.

022312120752_Americas_Military_POA.pdf

Edited by WifWaf
Added “DOD Instruction 5000.02 requirements” to exact blame
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8 minutes ago, Vern Edwards said:

@Don MansfieldGive me an example of a simple rule.

The article gives the example of rules for a flock of birds:

Quote

 

One of the simplest adaptive systems is a flock of birds. We have all watched in amazement the graceful and coordinated movements of a flock of birds. Yet there is no bird-in-chief directing the action. There is no script distributed to each bird prescribing the actions of the flock. However, this collective behavior can be modeled very nicely. In these models, individual birds have a degree of decision-making capacity, but all the flight decisions must follow the simple rules. Each must:

avoid hitting neighbours or obstacles,

align flight to match the neighbours, and

fly an average distance from the neighbours.

From these simple rules, very complex flocking behavior proceeds.

 

 

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@Don MansfieldBirds have behaviors, not rules. The author of your article is confused. If birds were people they would ask for definitions of "hit," "neighbor," and  "obstacle."

The problem in acquisition is that it is a complex adaptive system on which Congress and policymakers have tried to impose hard rules.

"Consider price before when selecting a contractor" is a simple rule. Now look at FAR Subparts 15.4 and 31.2.

Congress and the policymakers have applied complicated thinking to a complex adaptive system, writing generally strict rules that lead the system operators into maladaptive behavior, which is why the system often does not perform satisfactorily. Think JEDI.

The problem is how to manage complex adaptivity without writing complicated rules, which make the system maladaped.

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@Don MansfieldTake a look at It's Not Complicated: The Art and Science of Complexity in Business, by Rick Nason. He describes a complex system as one in which:

  1. Successful outcomes are not easily and objectively definable.
  2. Factors and elements necessary for a successful outcome are not known in advance.
  3. Exactness is not required.

Nason classifies systems as (a) simple, (b) complicated, and (c) complex.

A simple task is making coffee for the office.

A complicated task is preparing annual business financial statements.

A complex task is making a sales presentation to a potentially important client.

 

 

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  • 2 weeks later...
On 8/17/2021 at 8:33 AM, joel hoffman said:

My first “acquisition”as a brand new GS-11 was on my second day of civilian federal employment in 1980. It was to purchase and install a hollow core wood door in the wall behind the GS-15 Area Engineer’s secretary’s desk, at the front of the building, so she didn’t have to go all the way down a hallway and around to reach the office coffee pot and copy machine behind the wall.

They gave me an SF-70(?) purchase order and sent me to the nearest hardware/lumber store to buy it. Hauled it back, cut a hole in the wall and installed it.  Cost about $30 plus some nails. Nothing after that was as simple…

I later found out that it cost about $75 per transaction to process a Form 70, plus mailing it from our Area Office in Mississippi to the District Office in Mobile. Don’t know how many persons were involved in processing and paying for that $30 transaction. 

I presume what happened to you was unusual? As a newbie, my first days involved jumping straight into purchasing expensive tech equipment over the SAT (under guidance from the CO).

I don't get to see or work with what I'm buying, so I wish my first days/weeks/months were as interesting as yours.

 

 

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  • 6 months later...
On 8/17/2021 at 12:42 PM, Vern Edwards said:

Acquisition reformers have focused on changing the rules. The have failed time and again in their attempts to fix the system using that approach. I wonder if it's because they have used an approach that might work for a merely complicated system, but not for a complex adaptive system.

I think you are onto something Vern.  First question begged is what is a complex adaptive system?  

Here is tone source that is grounded in management theory that may be apt (Dooley, Kevin J. "A complex adaptive systems model of organization change." Nonlinear dynamics, psychology, and life sciences 1.1 (1997): 69-97.)

"A theory of complex adaptive systems was borne from the discovery of chaotic dynamics in systems' behaviors. Chaos theory has developed along two dimensions. Experimentalists (as popularized in Gleick, 1987) found ways (primarily grounded in topology) to discover deep and complex patterns in seemingly random or "chaotic" data. Prigogine and Stengers (1984), among others, use chaos to describe how order can arise from complexity through the process of self-organization. Here is a summary of some of the main characteristics of systems described by chaos theory (Dooley et al., 1995): (a) seemingly random behavior may be the result of simple nonlinear systems (or feedback-coupled linear systems), (b) chaotic behavior can be discovered via various topological mappings, (c) nonlinear systems can be subject to sensitive dependence to initial conditions—this sensitivity forces a re-examination of causality—which now must be considered multilevel and multideterminant (Abraham et al., 1990), (d) systems
that are pushed far-from-equilibrium (at the edge of chaos) can spontaneously self-organize into new structures, and (e) changes in the essential nature of a system take place when a control parameter passes a critical threshold—a bifurcation point."

He continues by stating there are two conditions that need to be met in order for something to be considered a complex adaptive system "Whereas chaos theory
relates to a particular behavior of complex systems, complex adaptive systems theory allows one to analyze the organizational system from a more holistic point of view. A CAS is both self-organizing and learning; examples of CAS include social systems, ecologies, economies, cultures, politics, technologies, traffic, weather, etc."

Does our acquisition system fit this description?  If not, then it is not a complex adaptive system.

Would want to think about this more, but maybe self-organizing and learning happens outside of, and in opposition to, the structures of acquisition policy.  Take OTAs as an example.  This could possibly fit into the kind of self-organizing activity in federal procurement that resides outside of the system (inside of one system - 10 U.S.C. 2371 - but outside of the controls of those responsible for acquisition policy)

Looking at acquisition policy I can only help feel that it is blind carpenters seeking nails through the only mechanism that they have any control over.  I often hear folks proposing a FAR rule thinking that it will simply force compliance on the private sector to address a federal need as if a contract are the things that fixes (or incentivizes fixing) problems.  These contract driven incentives towards solutions place greater compliance burdens on BOTH industry and federal contracting officers, as if compliance achieves the result.  As 

Maybe acquisitions is not a system at all but rather a construct that drives integrated systems and activities that are meant to cover the berth of federal acquisitions from satellites to sandwiches?  It seems to be driven by very earnest people who try hard, but there are big differences between a sandwich and a satellites.  Put it in the hands of the internal policy and compliance outfits (as @WifWaf noted in his DCMA example) and things just get progressively less logical and more silly.  No self-organization and no learning.  In fact, self-organizing is in fact frowned upon.

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