Jump to content
The Wifcon Forums and Blogs


  • Content Count

  • Joined

  • Last visited

Community Reputation

0 Neutral

About jtolli

  • Rank
  • Birthday 06/03/1961

Profile Information

  • Gender
  • Location
    San Antonio
  1. I have seen this behavior a lot in the government. People are afraid to make decisions. My current team lead is that way. If someone asks a question, instead of us answering, she wants to up-channel it to higher HQ. Her thinking is that if we give someone advice (e.g. making a decision), and the advice turns out to be wrong, then they will blame us for giving the wrong advice. It drives me crazy! I have also worked in a contracting office where specialists don't even review documents in a procurement package because they aren't the final reviewer/approver, so "why waste my time reviewing
  2. Here is what the Army's Request for Service Contract Approval (RSCA) form says: "When contracting for services, care must be taken to ensure that no illegal out-sourcing or improper conversion is taking place. Illegal “out-sourcing” and improper conversion involve shifting work from civilian positions to contract personnel (this can happen even if the civilian position is not encumbered). In environments that involve fiscal uncertainty, declining budgets, or hiring freezes, special vigilance is required to ensure these things do not occur. Due to congressional moratorium on A-7
  3. Our supporting contracting office (Army) is now inserting 52.204-14 Service Contract Reporting Requirements into contracts being awarded.
  4. To add to what others have said, the DFARS provides the authority for purchases up to $25,000 with the GPC @ 213-301(2)(II) which says: "(2) An individual appointed in accordance with 201.603-3 (a) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000, if— (ii) The individual making the purchase— (A) Is authorized and trained in accordance with agency procedures; (B) Complies with the requirements of FAR 8.002 in making the purchase; and (C) Seeks maximum practicable comp
  5. From https://www.dmdc.osd.mil/ecmra_splash/ ECMRA is de-commissioned as of COB June 19th, 2020. The data collection functionality will transition to the System for Award Management (https://www.sam.gov) by the end of FY20. For additional details and updates regarding this planned transition, please see the following links: Policy and Data regarding the Inventory of Contracted Services: https://www.acq.osd.mil/dpap/cpic/cp/inventory_of_services_contracts.html. Status of DFARS Rule implementing SAM reporting - Case Number 2018-D063: https://www.a
  6. I am not an expert at this, but have dealt with contracts in many different States before. It is my understanding that if a State has laws that have overtime laws that differ from the FLSA, then the State laws also apply. For example, in California any work over 8 hours a day is considered overtime. See here: https://www.dol.gov/general/topic/workhours/overtime "Some states have overtime laws. In cases where an employee is subject to both the state and federal overtime laws, the employee is entitled to overtime according to the higher standard (i.e., the standard that will provide
  7. ji20874 gave some good general advice. Just to add I typically look for indicators that the PWS (or SOW if you prefer) is not requiring the contractor to perform inherently governmental functions (FAR Subpart 7.5), or personal services (FAR Subpart 37.104). I have many years of experience reviewing these documents. In my experience you need to have some analytical skills, critical reading skills, and common sense. One example that comes to mind is a PWS for IT support services that I reviewed where the contractor was tasked to "monitor the networks for security issues". That was all that spec
  8. As h2h pointed out, this issue goes beyond acquisitions. It appears to be common in any sort of rating program where humans determine the rating. Going back to my active duty Air Force days, we had an enlisted performance rating system that the Air Force eventually replaced because the vast majority of people were getting the top rating. When the new rating system was deployed, it was emphasized that most people would be "average" performers, and therefore should receive average ratings. This only lasted a little while, as I recall less than a year, until people complained that it was hurting
  9. I have a bit of experience with teleworking, both in industry and as a federal employee. My first industry job after military retirement was a full-time telework position. I did that for about 2 1/2 years. I later worked for a DoD 4th estate agency that had a pretty liberal telework policy. For my first 6 months or so with the DoD agency, I teleworked full time as there was just not enough office space for some of us. Once they located office space, we teleworked one day per pay period. In theory telework sounds good. But it requires a lot of self-discipline, even for those who are con
  10. It's kind of hard to answer the question without knowing the specifics of the 1101 position. By specifics I mean the job responsibilities, and not just the job title. "COR" duties vary widely from job to job. Some 1102's are now setting in jobs as 1101's, when they were hired into 1102 positions. This is especially true in the Army who supposedly came down a few years back and said to be an 1102 you have to work in a contracting office. That's the case in my current job. I work with teammates who were 1102's, were hired as 1102's, then converted to 1101's due to the Army policy. Like CO
  11. The rule for paying "checkout fees" with the Government Purchase Card (GPC) changed a while back. It depends on where (State) the vendor is located See: https://www.acq.osd.mil/dpap/pdi/pc/faq.html#q18 "Can I purchase from merchants that charge a surcharge/checkout fee to use the GPC? Answer: It depends on where the merchant is located. If the merchant is located within a U.S. state or U.S. territories permitting merchants to impose a surcharge/checkout fee for charge/credit card purchases, then the CH may either make the purchase with the fee pursuant to the followi
  12. Been there, and done that many times over. At least you have a director who is concerned with having a quality SOW/PWS. My experience has been that I appear to be the only party involved who really cares that the PWS is well written. The attitude of everyone else has usually been why sweat it, it really isn't that important, and would only become an issue if we go to court, which rarely happens so why invest the time trying to perfect the document? So I usually fix what I can, as it easier to fix it yourself than to try to explain what is wrong, and end up having to do it yourself anyway. Of
  13. If the designated office can't receive proposals at the time specified, and time does not permit an amendment to the solicitation, proposals will be due at the same time on the next Government work day.
  14. Reminds me of a response we received to an RFI. The company didn't respond with any relevant information, but instead provided a sales pitch for a software product they were selling; telling us how we could benefit from it. For those of us who had to review the response, it did not leave a positive impression on us, much like receiving spam or junk mail.
  15. You can also find SaaS products on GSA Advantage classified as term software licenses (a product or supply).
  • Create New...