ji20874

Here's a great idea (since only great ideas are invited) -- I made the submission on the 809 Panel webpage a few minutes ago...

Detailed Description of the Challenge 

How many GS-1102s does it take to make a contracting decision? 

If a contracting officer's decision or recommendation has to be approved by a higher-level official, such as the HCA, there may be six, eight, ten, or fifteen or more GS-1102 (or military equivalent) persons in between the contracting officer and the HCA.  And we're not even talking about lawyers.  We need to streamline the decision-making process. 

Proposed Solution or Recommendation 

Maybe in DFARS Part 201: 

When acquisition regulations require approval of a contracting officer decision or determination at some level above the contracting officer, the following instructions shall apply: 

When the action requires (a) approval within the local contracting office or center, or (b) review by the chief of the contracting office before submission to the head of the contracting activity, there shall be no intermediate GS-1102 (or military equivalent) persons as reviewers within the local contracting office or center.  The contracting officer may submit the action directly to the approving official or chief of the contracting office for consideration.  However, if the approving official's or chief of the contracting office's position is graded for a member of the Senior Executive Service (or comparable or higher position, including a general or flag officer in the armed forces), the approving official or chief of the contracting office may appoint one GS-1102 (or military equivalent) person to perform a staff review as part of his or her consideration of the action.    

When the action requires (a) approval by the head of the contracting activity (HCA), or (b) review by the HCA before submission to the agency head, the HCA may require an intermediate review by the chief of the contracting office (see the paragraph above).  In addition, the HCA may appoint one GS-1102 (or military equivalent) person on his or her staff to perform a staff review as part of his or her consideration of the action. 

If the approving official, chief of the contracting office, or head of the contracting activity desires the formal input of other GS-1102 (or military equivalent) persons before making a decision on the action, he or she may convene an in-person or virtual meeting for that purpose.  The contracting officer should be invited to participate in the meeting whenever practicable.  The names of all attendees shall be recorded for the record in the contract file. 

The above paragraphs only limit GS-1102 (or military equivalent) reviewers for actions requiring approval above the contracting officer level and up to the head of the contracting activity.  Reviews by attorneys or other specialists or advisors are not limited by these paragraphs.

I'm okay with the GAO's decision.

If Genesis (the protester) disagreed with the requirement for past performance questionnaires completed by previous customers, it should have protested this before the date set for receipt of offers.  That's the rule.  To wait until after it learns that it was not selected, and then to file a protest, is improper.

boricua,

8(a) is different.  An agency cannot award an 8(a) contract without the SBA's permission, and the SBA grants admission to its Business Development program based on NAICS codes.  Thus, a company can be enrolled in the SBA Business Development program (and thus be eligible for an 8(a) contract) for one one NAICS code but not another -- it might be small for both, but 8(a) only for one.

But this only applies to 8(a).  For a general small business set-aside, there is no requirement that a company's SAM listing include a solicitation's NAICS code, as the GAO reminded us -- same for HUBZone and SDVOSB, where eligibility is not driven by NAICS code.

It is a common misperception, and is becoming more common even though there is no basis for it in regulation.  How do these ill-founded misperceptions start and spread so easily?

One other thought -- we cannot improve our professionalism as long as our executives care nothing about it.  When the SPEs and HCAs and people at their level start caring about professionalism in our career field, then they can be responsible for the oversight of the tests -- but we simply cannot leave the matter to DAU.  

Don,

There is tribalism and incompetence and small-world-view within DAU, too.  We would probably need an independent board of some sort to develop and update the test -- but who goes on that board?  Still, I like the idea of a test of professional knowledge.

uva,

I agree that the current crop of DAU web-based training is ineffective -- the in-person training is, too, to a large extent -- we send people to those courses to check boxes for certification rather than with any expectation of meaningful learning.  On this regard, DAU as a whole had been a total failure.*  But still, I believe web-based training can be effective if done right.

Certainly, we don't need one master test -- I much prefer small tests and smaller certifications.

*I mean no disrespect to past or current DAU staff -- just an honest observation in the hope of meaningful discussion.  

Don,

The problem is that shaman might be the one selected to write the module that will grade everyone else's competence in fair opportunity considerations.  Or, to reference an earlier example, the dimwit who thinks the determination to include options has to be in a FAR Subpart 1.7 D&F format might (likely will) be selected for that module.  I fully support the idea, but I would likely be deeply troubled by the implementation details.

I would like to see an honest discussion of the subject -- it could be improperly implemented, too, but I like the idea.

Thanks, Don.

"We have met the enemy, and he is us."  (Pogo)

I still see it as a lot of work, and I am having a hard time seeing the utility of the effort.  But that's just me.  I prefer to rely on original source information rather than homemade desk-guides and so forth, however well-intentioned, because I have learned that it is hard to get these things right and it is almost impossible to keep them up-to-date...

I applaud your effort, but wow!

If a tool was offered to me, I would want it to be an electronic tool, not a Word .docx document.

I would not use it unless I trusted it.  How can anyone trust that the document is up-to-date?

Of course, I don't know why they chose the word -- but I'm okay with it -- there is something about a good GS-1102 that goes beyond "proficiency" as might be measured by a written test -- we also might say a person has skill in producing a solicitation, if skill means putting a document together. But I am supportive if they are trying to say that there is something more -- we have to actually deliver results in our service contracting -- we're not just clerks, after all -- and if tradecraft means the skills and experience and savvy to actually deliver value and results in our contracts, then maybe we need a new word.

My only suggestion would be to mark paragraph ( c ) as reserved rather than re-numbering all the subsequent paragraphs.

The purpose of the report, as I remember it, was that the Army itself had a problem of a culture where success can only be achieved by compromising the truth. I would rather condemn the Army culture as an institution than the Army officers as individuals. I was glad to read the report, because I was actually reading some honesty in an official Army publication.