Posted November 19, 200915 yr comment_3287 Philosophical Question - Do the various interpretations of Agency policies on interagency acquisition cause waste? For example - DoD policy states that you must prepare a written justification that doing an interagency acquisition (either a direct acquisition using another agency's vehicle or getting assisted acquisition support) is in the best interest of the program. Various local levels interpretations of this policy exist, ranging from the original "this means we can't use GSA Schedules anymore" to the recently heard "your assisted acquisition procurement can only have a Period of Performance of one year while a DoD contracting shop does a longer procurement for you". Let the opinions fly!
November 19, 200915 yr comment_3288 Please cite the location of the policy statement. Is it a DPAP memo, the DFARS, someplace else?
November 20, 200915 yr Author comment_3293 Original policy memo from DPAP is 29 Oct 04 and can be found at http://www.acq.osd.mil/dpap/cpic/cp/intera...cquisition.html. It's the various ways that the policy has been interpreted at the local level that introduce, IMHO, the prospect of wasting scarce acquisition workforce resources
November 20, 200915 yr comment_3296 There is no prohibition, or even discouragement, from using direct acquisition (i.e. placing orders under GSA FSS or GWACS) to meet DOD needs. See the below FAQ from http://www.acq.osd.mil/dpap/cpic/cp/faq.html. What are the circumstances in which it is appropriate to use direct acquisitions? DoD contracting officers are encouraged to utilize existing contracts of non-DoD agencies when supplies or services under contract meet or exceed DoD schedule and performance requirements. DoD contracting officers must ensure that the prices obtained for such goods and services are fair and reasonable and that all statutory, regulatory, and policy requirements of the Department are met. As is the case with any procurement this business decision must be sufficiently documented in the contract file. Examples of a direct acquisition include the placement of an order against a General Services Administration Schedule contract or the National Aeronautics and Space Administration?s (NASA) Scientific and Engineering Workstation Procurement (SEWP) contract by a DoD contracting officer. What are the circumstances in which it is appropriate to use assisted acquisitions? DoD requirements may be met utilizing the assisted services of non-DoD agencies. Utilizing an assisted acquisition may be appropriate when requirements are well defined, the bona fide need standard is met, when the fees paid are considered fair and reasonable, when there is a complete understanding between the parties of roles and responsibilities, especially with regard to contract oversight and administration, and when it is determined to be in the best interest of the Department. Sufficient and appropriate funds must be utilized for the tasks to be accomplished for the time period of performance. All Interagency Acquisitions should have an Interagency Agreement (IA) regardless of dollar value. See the Director of Defense Procurements memo of October 31, 2008. However, the memo notes that an abbreviated IA may be appropriate for acquisitions less than $500,000.
November 20, 200915 yr Author comment_3309 Philosophical Question - Do the various interpretations of Agency policies on interagency acquisition cause waste? For example - DoD policy states that you must prepare a written justification that doing an interagency acquisition (either a direct acquisition using another agency's vehicle or getting assisted acquisition support) is in the best interest of the program. Various local levels interpretations of this policy exist, ranging from the original "this means we can't use GSA Schedules anymore" to the recently heard "your assisted acquisition procurement can only have a Period of Performance of one year while a DoD contracting shop does a longer procurement for you". Let the opinions fly! I need to clarify - I should have said "Various local misinterpretations of this policy exist"
November 20, 200915 yr comment_3314 In my DoD office, it requres a J&A approved by the PARC or his deputy in order to place a interagency (GSA task order) acquisition. That seems to be at odds with "DoD contracting officers are encouraged...", as most KO's would rather go open purchase than deal with the J&A process, which entails legal reviews and at least three levels of supervisory reviews, not to mention a lot more time than many KO's have.
