FrankJon

This is a different topic.

Thank you all for the feedback! From what I hear, my agency paid for "all the bells and whistles" for our version of PRISM. So my assumption is the powers that be will be eager to throw good money after bad for quite a while...

I'm curious to know whether anyone has experience using PRISM for workload tracking. My office is in the process of converting from our trusty Excel-based trackers to PRISM, and it's not going well -- big gaps in the data we need, wonky presentation, and extreme latency. Anyone have a similar or different experience with PRISM?

Right. Even if systemic abuse is not found, there's a real possibility that--as occurred with many of DOGE's actions--the administration already knows what it will do and will find the pretext to do it. Apparently, the SBA has a lot of discretion here: https://www.schoonoverlawfirm.com/the-long-term-viability-of-sbas-8a-program-is-uncertain/ For me, it's difficult to imagine a world in which this administration allows the program to continue in anything resembling its current form.

Instead, they decided to drop a 102-page DoDM 5010.12 rewrite the week before Thanksgiving: https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/501012p.pdf?ver=_mt5ZD56t8d7Ft21HK3bPQ%3d%3d. 😅 How officials can talk about "speed," "common sense," and "innovation" in acquisition on the one hand, and then turn around and release a 102-page process document on a single topic on the other hand, I have no idea. I suppose it doesn't matter because few people will actually read it. Policy offices and VAO will distill it down into a few bullets that COs will be expected to follow. DAU/WAU will create an online training that people will race through. The impact will be negligible. Sure hope it was worth the years of development....

Hope your Thanksgiving was nice, @C Culham. I think a lot of what you're observing when you note the disparities in adoption rates is a result of the piecemeal issuance schedule. Those parts that were issued in May tend to have higher adoption rates than those issued later. Those issued on the final date of Sep. 30 (parts 15, 16, 22, 23, 25, 32, 42, and 53) each are adopted by fewer than 10 agencies. Regarding part 2, the Practitioner Guide states the following: Regarding the underlying sentiment of your post, I wholeheartedly agree: How on earth can anyone--from CS to CO to reviewer to contractor--track which regulation applies to which acquisition? I even spoke to one Department-level procurement analyst who told me her Department is allowing each CO to follow whichever regulation (FAR or RFO) they choose!! No doubt that many mistakes are being made regularly due to confusion over which regulation applies. But what is the impact? I suspect there's a greater impact to efficiency than compliance. Those who are in the trenches and trying to get it right have a tall order in trying to fit the pieces together while jumping from regulation to regulation and recalling which apply to which acquisitions. And then there's the questions from industry they'll get in response to solicitations. It's got to be a headache for everyone. The reason I don't think compliance is as big a concern is because the RFO primarily stripped rules from (vice added rules to) the FAR, A CO who erroneously follows the FAR over the RFO might be applying a stricter-than-necessary standard, but conceptually would seem to be at low risk of violating many rules. (Those who are more familiar with the RFO will undoubtedly be able to point out some interesting exceptions to this statement.) My small agency hasn't adopted any of the RFO yet. We plan to do it all at once so there's a clean break. I think this is optimal, as it will enable us to prepare for the biggest changes and mitigate confusion once we flip the switch.

Can you summarize what these organizations do differently or better than others with respect to acquisition training?

That said, they took liberties here and there. For example, by introducing BPAs to subpart 16.5 and completely rewriting part 12, they definitely did some of their own "innovation."

The wildest part is that the drafters apparently recognized the issue and even solicited input on it, yet did nothing. GSA's SPE posted this to LinkedIn in June: https://www.linkedin.com/pulse/thinking-far-33-jeff-koses-1cg7e/?trackingId=yiqlHBhyozlPSEB8c66UaQ%3D%3D While Mr. Koses' post wasn't specifically about the Rewrite, he would have had a voice in the rewrite process. Maybe, as Vern has suggested, the drafters ultimately decided that making this change would have exceeded their mandate.

Just so we're on the same page, while this method has its benefits, the offerors' responses would still come within Matthew's definitions of "approach" and "understanding," would they not?

In my opinion this -- --is an overly optimistic expectation for most agencies in most scenarios.

To be sure, the message and messenger matter. However, status quo bias in this area is stronger than you think. It's important to realize that, until January 2025, most customers at most agencies became accustomed to a carousel of 1102s coming and going. Most of these 1102s were unqualified and unwilling to learn. Each gave different advice and established different rules for the customers to follow, some of which was right and much of which was wrong. Beyond this, it's part of human DNA to continue wanting to do what has "worked" to avoid embarrassing or costly errors. Humans are also fixated on results over processes, easily confusing a strong outcome for a strong process. In this context, it's not hard to understand a customer's insistence on requesting written technical proposals, just as s/he's always done. As a manager and CO, once I encounter resistance, I do my best to find a middle ground. If I can help teach my employees and customers do acquisition a little bit better than they did before, I count that as a win.

I read a passage in Epictetus' Discourses this weekend in which he praises Plato for insisting that his students come to a common understanding of everyday words. Made me think of your recent posts, Vern. You would've been right at home in the agora....

This is correct. What I should have stated instead is that, with respect to my specific acquisition, past results may or may not be strongly correlated to contractor inputs. There may be a high amount of luck involved with past outcomes. For this reason, my customer insists on examining every aspect of an offeror's business before awarding a contract for this particular need. To sum up my position on this topic, I wholeheartedly agree with the argument that requesting a written technical proposal or "approach" to the work is usually unnecessary and wasteful. But if @Matthew Fleharty is arguing that it's never appropriate to request such information unless the government intends to incorporate it into the contract, I disagree with this. I don't know how one could make such a blanket assertion across the myriad Government requirements that ever have been and ever will be. Moreover, even if this were substantively true, I disagree with the notion of "overruling" a customer who insists on requesting such information. I think such a decision rightfully falls within the "advisory" bucket of a CO's responsibilities, even when the CO is also the SSA.

Vern did you intend to post this in the other thread about value?

It may be necessary or beneficial in certain instances in which the agency wants to ascertain that the offeror understands what a technically sound approach is. I have an active example, but the work is very specific and I’m reluctant to discuss publicly. The most I’ll share here is that past results do not guarantee future success. For this reason, my customer wants to do a close inspection under the hood to understand each offeror’s structure and practices. We reserve the right to incorporate any piece of the approach into the contract. (Personally, I think what my customer wants is probably overkill. But their rationale, if true, makes sense. So I defer to the judgment of the experts here despite personal doubts.) Even if you can’t think of a specific example, isn’t it simple to imagine such a situation arising? Can you help me to see why you believe it would never be appropriate to request a technical approach that the government doesn’t intend to incorporate into the contract?

Family: Contract attributes Genus: Contract attributes of significance to the government Species: Contract attributes of significance to the government that address the government’s objectives In any government contract arrangement, the government identifies attributes of significance. For each attribute of significance we have an objective (“more of this” or “less of that”). A contract that addresses our objectives provides some amount of value. The overall contract value is a calculation based on the level to which the contractor fulfills our objectives less the impact of failing to address any objectives.

Value is the attainment of one or more preferred attributes.

No. Even if the approach were contractually stipulated, the contractor might breach the contract.

Eh, maybe not. I would say value is a preference, regardless of how much preference we have for a certain thing. We either do or don't value an attribute. Measurement is what we do to determine which thing possesses more value.

Yes, I think so.

I don't think height and weight are good analogies. These can be measured using objective standards. In my view, value is always subjective. ("I value this heirloom." "I value an office with a view.") The process we use to compare value propositions may be prescriptive, but the value we ascribe to each attribute is always subjective. EDIT: Or maybe that's what makes these things distinct within the category of measurements.

Yes, I've come across this article before. High praise. I just wish the lesson had stuck to any meaningful extent.

This is the article I've shared most with other 1102s. Unfortunately, most remain skeptical that it's usually appropriate to refrain from requesting a technical proposal. For example, this past October, I asked my office to read this. We then got together -- about 15 of us from the SPE and HCA on down -- and discussed it. I asked for a show of hands on how many agreed with your premise that a technical proposal is usually unnecessary. One person raised his hand. My impression is that 1102s are most concerned about taking blame from the customer if performance goes awry and we didn't request a technical proposal prior to making award.

In the context of professional services, which is generally what my branch purchases, I virtually always attempt to dissuade my COs and CSs, and their customers, from requesting written "approaches" as to how the contractor will execute or manage the work. I've read many of the same materials as you and find the arguments against requesting approaches in most instances extremely compelling. There's also the FAR, which in multiple spots (e.g., 12.205(a)) makes clear that a written "approach" often isn't appropriate. However, my success rate in convincing others to change their habits is pretty low. Most COs, CSs, and customer orgs in my agency were taught that this is "the way" to do acquisition, and feel uncomfortable going without it. Breaking that muscle memory is tough. In most cases, we merely agree to reduce the maximum length of these proposals. A step in the right direction, I suppose. All of that stated, I wouldn't go so far as to say that such a request is always without merit, as you seem to suggest. There may be acquisitions for which it's necessary to ensure that an offeror understands or intends to utilize a fundamentally sound approach to the work. In such cases, the details may be too numerous, or the scope too great, for less burdensome means such as demonstrations or oral presentations. Even if the CO disagrees with such a plan, the SSA may insist on it. And even when the CO is the SSA, I would make it happen if my customer insisted on it. My rule of thumb: When it comes to compliance decisions, I insist; when it comes to business decisions, I advise. Finally, if the government reserves the ability in the solicitation to incorporate aspects of the approach into the final contract, I think it's reasonable to assume that the offeror will take greater care than it otherwise might have to ensure the approach is realistic. I'm realizing I didn't directly respond to your request for "best arguments." I'll wait to see what updates you make in response to Vern's reply and give this some additional thought.