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FAR 2.O (The FAR "Overhaul")
That’s a great idea.
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FAR 2.O (The FAR "Overhaul")
As I see it, there are 3 prongs to meaningful acquisition reform: People -- As described by Vern. This includes CORs. Rules -- Fewer of them, written more clearly. Structure -- In most agencies, the Federal Acquisition System doesn't work as envisioned. True teamwork across acquisition stakeholders is minimal; in fact, these relationships are often adversarial. In addition, team members often lack authority to make decisions within their areas of expertise, or face so much resistance to making them that they voluntarily relinquish this authority. As the system is currently structured, even the greatest practitioners working under the most enlightened rules would lack means to overcome an agency bureaucracy that is uninterested in supporting the acquisition system.
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WIFCON PODCAST #1 THE FAR REFORM PROJECT
Matthew - Have you ever tried sharing relevant N&CR articles with acquisition personnel? Outside of legal personnel, interest is low in the offices I've worked at. Ensuring access to adequate materials is only part of the battle. People aren't going to suddenly choose to work harder if they weren't already inclined to do so. For this to happen, the structure or composition of the workforce must change.
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WIFCON PODCAST #1 THE FAR REFORM PROJECT
Agree, good work, gentlemen, and thanks for setting this up, Don. My only critique is that it was too brief. I would’ve enjoyed hearing these men continue to quibble, although I guess there’s only so much to say at this point.
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WIFCON PODCAST #1 THE FAR REFORM PROJECT
Vern - I skimmed through it on my phone while on the train. Not a deep read. My two biggest critiques are the vague request for a “work plan” and the lack of any measurable performance standards. I also didn’t see stated which FAR procedures are being utilized, and question whether the CO understands that part 12 doesn’t stand alone. Ideally, an agency would choose an HVAC company based on qualifications, experience, past performance, and price alone. And it must include some kind of quality standard. That said, as someone who reviews a lot of procurement work product, I would honestly be happy if I received this as a first draft for review. It’s short, simple, and (to me) clear in purpose. These are attributes that are so often missing from our supposedly “streamlined” and “simplified” procurements. What are your primary concerns with it?
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FAR 2.O (The FAR "Overhaul")
On the other hand this administration hasn’t shown much interest in following precedent or rules.
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FAR 2.O (The FAR "Overhaul")
Looking forward to the discussion! I notice you posted this at 3 am Pacific time, which leads me to think you may have travelled to DC for it…?
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FAR 2.O (The FAR "Overhaul")
Maybe at the outset the conclusion was true, but I suspect not over the ensuing 40 years. I assume that practitioners are far more risk-averse today than in 1980, and that misinformation is far more prevalent due to an increase of rules for practitioners overlook and misinterpret. In the short-term I expect that it will make life easier for your average paint-by-numbers practitioner. Fewer rules to run afoul of. Fewer review findings. For more capable practitioners there may be potential to move the needle for the better by exploiting efficiencies, although this will depend greatly on how much change one’s leadership will tolerate. Over the medium and long term the number of rules will increase via amendment. Without change to how the workforce is incentivized or disincentivized I don’t foresee an enduring impact.
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FAR 2.O (The FAR "Overhaul")
Oh wow. That is super interesting! Wonder if the Soviets got anything actionable out of that process….
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FAR 2.O (The FAR "Overhaul")
Sounds like this has gone from "not enough cooks" as Vern's source initially described it, to "way too many cooks" now. I'd be shocked if we see FAR 2.0 this calendar year, although I'm sure there will be lots of deviations along the way.
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FAR Rewrite Underway
I don't think I agree with this, Vern. It probably depends on what you mean by "thrive" and "struggle." The majority of 1102s today don't "thrive" professionally (i.e., don't have a sound understanding of what they're doing or why), and many are flat-out unqualified for the role. In fact, many either can't or won't open the FAR--ever--outside of the classroom. Despite this, most "get by" (i.e., maintain some level of output and receive passing assessments) through some combination of obedience, work-of-mouth knowledge, intuition, and "common sense" (real or perceived). I suspect even after the re-write the majority of practitioners will continue to operate in this manner. There would need to be some major new incentive or disincentive, or change in how 1102s are selected and trained, for this to change. Fewer rules would only mean that these folks run afoul of the rules less often.
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Another commercial-product RFQ gone terribly wrong.
I don’t see how you can say this, Joel. Considering price as the most important factor doesn’t mean you can arbitrarily decide not to consider prices beyond the lowest two. Imagine if the third-highest price were only marginally higher than the second - say a fraction of a percentile - but the agency arbitrarily decided not to consider the technical attributes of the third-highest quote. Wouldn’t that be an unreasonable decision on its face? Maybe my initial assessment of this scheme as “fatally flawed” was hasty. The solicitation doesn’t state what the agency will do, only what it may do. But I do think they could get into trouble here if they’re not careful.
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Another commercial-product RFQ gone terribly wrong.
Oh I doubt it very much!
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Another commercial-product RFQ gone terribly wrong.
This solicitation was actually brought to my attention through Reddit. An interested contractor asked how best to individually ID thousands of shirts. A number of COs chimed in that the agency probably doesn’t actually want this and that it’s likely an oversight. Some proceeded further to criticize various aspects of the RFQ, including some that I’ve raised here. I posted to help other 1102s understand what not to do and to generate informed discussion about the evaluation methodology. If I’m being honest, yes, there’s also a public flogging element for me. As an 1102 who puts a lot of effort into my work, seeing something as sloppy as this irritates me. For better or worse, much of the work of an 1102 is available for public consumption and critique. That’s especially true since January 20.
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Another commercial-product RFQ gone terribly wrong.
@joel hoffman Even if the RFQ had stated explicitly that price is the most important factor, it doesn’t seem reasonable to me to potentially exclude consideration of some quotes when award will not necessarily be made to the lowest-priced quote. In this case how would the government even *know* which quote provides the best value unless they considered all? The evaluation scheme isn’t logical. (Note that the agency does not state *why* a higher priced quote might be excluded from consideration, like a a price that exceeds what the agency would ever be willing to pay for the items under any circumstance. It simply gives the agency carte blanche to throw out quotes following the two lowest priced quotes.) Contrast this with LPTA, when the government potentially has all the information it needs to make an award decision upon reviewing the lowest-priced quote. It probably doesn’t matter in the end. I assume this language - like the rest of the solicitation - is ripped straight from a template. It’s hard to imagine a scenario in which the end users wouldn’t want to evaluate all available options To answer your last question, no, I saw no indication in the RFQ as to what “the most advantageous” t-shirt looks like. The agency doesn’t need to say so either, although it would certainly make sense! But I agree with @General.Zhukov — if I were the CO, I’d sure want vendors to send me the tees for evaluation instead of a description!