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Moderator

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  1. In a letter to industry and other stakeholders dated February 10, the Department of War asks for ideas about how to reform defense acquisition:

    Now, as we embark on Phase 2 ofthe RFO, we are seeking your input to help shape the substantive content of the proposed rules that will overhaul all parts ofthe DFARS and influence F ,:\R changes. This is a pivotal moment to offer your ideas. Your insights are essential to shaping reforms that are practical, effective, and aligned with the needs ofthose who rely on them. Please submit input to Mr. John Tenaglia and Ms. Kimberly Ziegler at osd.pentagon.ousda-s.mbx.dfars@mail.mil

    See the attached.

    LETTER-TO-DEFENSE-INDUSTRIAL-BASE-AND-ACQUISITION-STAKEHOLDERS-SEEKING-REVOLUTIONARY-FAR-OVERHAUL-PHASE-2-INPUT.pdf

  2. In light of today's emphasis on acquisiiton speed, especially by the Department of War, we think this is an urgent matterr that Wifcon members ought to discuss:

    In CWTSato Travel, Comp. Gen. Dec. B-423181,2, Dec. 19, 2025, the GAO denied a protest GSA's award of an order for commercial travel agent services against a Federal Supply Schedule. The decision is attached.

    In a procurement for the Marine Corps, GSA issued a request for quotations in accordance with FAR 8.405-2 on August 19, 2024. Here is what the quotes were to include, as described by the GAO:

    Vendors were instructed to organize their quotations into four files: administrative, technical, non-technical, and pricing. AR, Tab 10, RFQ amend. 4 at 168. The technical file was to be arranged as eight documents, including, as relevant, a technical quote, a transition plan, a quality control plan, a key personnel plan, and a personnel workforce plan. Id. at 169-171.

    The technical quote document was to provide a description of the firm's experience and knowledge as a TMC and its “industry knowledge, experience, ability, and expertise” for making both contractor-assisted travel arrangements and arrangements made using an online booking tool. Id. at 169. The technical approach document was to explain the vendor's approach to each element of the PWS, including “clear, concise, actionable, and logical strategies and approaches,” timeframes and objectives. Id. The personnel workforce plan was to set out the number of agents that would work in each on-site location, along with the vendor's approach to providing “24/365 (business hours and outside business hours) uninterrupted travel services” that would ensure customer needs are not compromised during business hours and outside of business hours, and an approach to managing surges in call volume while maintaining the required service levels. Id. at 171. The personnel workforce plan was also required to provide the ratio of vendor personnel to the number of transactions and describe in detail the methodology for determining staffing levels. Id.

    The GAO described the evaluation factors as follows:

    Quotations would be evaluated using five evaluation factors: factor A--travel management company passenger name record validation; factor B--technical approach; factor C--past performance; factor D--small business participation; and factor E--price. Id. at 176. Factor A would be evaluated on a pass/fail basis, and factor D would be evaluated on an acceptable/unacceptable basis. Id. Factors B and C would be evaluated qualitatively and were equally weighted. Id. In selecting a vendor, the agency would make a best-value tradeoff where the non-price factors, when combined, were significantly more important than price.

    There were the final evaluation results for the protester, CWTSato, and the awardee:

    CWTSato

    Omega

    Factor A

    Pass

    Pass

    Factor B

    Good

    Good

    Factor C

    Very Relevant / Limited Confidence / High Risk

    Relevant / Substantial Confidence / Low Risk

    Factor D

    Acceptable

    Acceptable

    Factor E - POS Pricing

    $18,366,418

    $24,701,978

    Factor E - MSF Pricing

    $18,366,418

    $24,702,974

    According to the GAO, the contracting officer decided to pay the higher "price" based on the evaluations of past performance.

    It appears to have taken the GSA more than a year to complete its commericial FSS selection/award process, which was clearly based on the FAR Part 15 process model. See https://www.wifcon.com/anal/analcomproc.htm

    Some questions:

    1. Did anything in FAR 8.405-2 require GSA to use such a procedure?

    2. Could they have asked for experience and past performance information and price, without the other stuff, selected Omega on that basis, and then negotiated performance plans and procedures one-on-one with them before making the award, without further communications with CWTSato? If not, why not?

    3. Would that have taken less work and time?

    4. If so, why do you think they conducted the procurement the way they did?

    GAO B-423181.2.pdf

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