General.Zhukov

Years ago, I was an Army officer who had some COR duties while deployed. As I was responsible for base security, I was the COR for related contracts (3rd country guards, perimeter maintenance, interpreters, fancy security devices, etc.). Our base security contracts were ... satisfactory. The Contracting Office was AF. I visited their base sometimes. You know who had exceptional base security contract performance - fences maintained, barriers and bunkers trash-free, well-disciplined contract guards, the latest fancy devices scanning and detecting threats? The base home to the COs who ran the base security contracts.

Yes. A topic near to my heart. Your PRISM version may be very different from mine, and PRISM is rapidly changing, so not all of this rant may apply. PRISM (my version and at least some others I know of) uses requisitions (called requisitions in PRISM, but goes by different names, it is the funding document) to track requirements This is PRISM's fatal flaw. Funding Requirement. I suppose If your office typically has a single requirement with a single requisition that arrives at the beginning of the process, and "workload" means "Preaward-Only" then PRISM is technically acceptable for workload. If not, PRISM is bad, don't use it. PRISM - at least my version - has minimal to no workload tracking functionality beyond requisitions. Most likely you will need to continue to track workload outside of PRISM and then reconcile the two sources. Even this most elemental of tracking mechanisms fails if funding (requisitions) is moderately complicated. Disclosure: I work within HHS, where PRISM is called HCAS. I've said all of this (and more, this is the short list) on the record to HCAS PMs, who will probably read this and disagree with me.

Contract data is useful, but what we are doing is people. CORs. We lost hundreds of CORs, most of our best CORs, and had perhaps a thousand active contracts change CORs (compared to ~100 for prior years). Many brand-new CORs. CORs abruptly assigned to complex ongoing contracts, or to contracts that had no COR for months, etc. Critical COR shorts in many domains - IT, research, facilities, cost contracts, etc. One COR Level 2 has >90 contracts. We've got a COR Level 1 with 40 assigned to them. Few of them understand the nuances of the FAC cert process. So, we now are building a lot of COR tracking. Something that is new. Whose got the certificates, much more detail about certification and training status, who can do what, who has capacity, etc. As little of this is or can be automated, it's a far high effort for a pretty basic output compared to anything you can do with financial or acquisition data.

Civilian GVT - Not Classified BLUF - We use Microsoft 365 products (Excel, Power BI), not because they are the best, but because people know how to use them. Basic individual data needs or ad-hoc reporting is typically Excel files. Tracking - and other types of sophisticated information that is used by many people - is centrally administrated and communicated out via dashboards and metrics. We primarily use PowerBI, since it is (relatively) easy to use. Some science/tech groups within agency use Tableau, which they are more familiar with. Agency has some extremely power Oracle reporting tools that I detest and never use. Our data is simple - hosted in private .gov cloud, isn't classified, doesn't need custom permissions, isn't confidential (like, no source selection info, no detailed invoice/cost info). Despite our relative simplicity, data management still manages to be the hardest part. Centrally controlled data is an effort, but better than the alternative of distributing out the raw data and having everyone use Excel to make up their own undocumented, customized, and conflicting metrics.

I am honestly unsure of the correct way of thinking about 'total period of performance' - so I default to the more generous definition. For FAR 6.3 purposes, the time after award, but before the requirement is being met, would not count. I suppose this is similar to the bona fide needs lead time exception. Definitely could be wrong though. Consider a very common thing in my agency - a gas chromatography system. A commercial scientific instrument which (often) needs several weeks of configuration & calibration, and annually renewed software, to be operational. Does the PoP start when the box is delivered on January 1 - or February 2, when it's switched on and starts working - or January 15, at acceptance when the on-site OEM install tech and agency lab guy sign off on it? Genuinely don't know if there is a definitive answer here.

The answers to your questions depend on the governing FAR Parts. Many of your problems go away if this IT is commercial (Part 12), and it is exempt from FAR Part 6 (Part 13). The hardware delivers ~120 days after award and the software license/support term begins at hardware acceptance, even a 12-month license term would extend the contract beyond 12 months from award, exceeding the FAR 6.302-2 limit unless we obtain HCA approval. [Correct me if I am wrong wifcon]: I think a reasonable person would determine that the lead time between delivery of a product, and the start date when the software needed to use the product is turned on, does not count towards the one year "total period of performance". Typically, in my agency, a contract for this would have two Line Items (we don't do sub-CLINs). CLIN 1 for product with a delivery date and $. CLIN 2, not separately priced, for the software. If the overall requirement is for the product, and you have to categorize the entire thing as a single value- like PSC for category management, or NAICS for non-manufacturing rule , or whatever - use the product's value. Often the buyer cannot 'shorten the PoP.' Many software-sellers cannot or will not do this. Typical response: "Sure, government customer, you can limit your PoP to 274 days as you like, just uninstall our software, but the contract will state, and you will pay for, 365 days, just like all our other customers." A reason to know if this is commercial. If you can separate out the software, and buy it separately through normal procedures, without FAR 6.3, you would of course want to do that.

So best value is the answer to the question "How do (or should) buyers, with multiple criteria, decide what to buy?" Answer: By selecting the proposal that represents best value. I propose that 'best value' is simply the federal acquisition application of an enormously rich and influential school of economic thought - decision theory. Many Nobel prizes have been won by economists studying this topic. At its broadest, decision theory is the study of how actors make economic decisions. The pioneers of decision theory, Von Neumann & Morgenstern (1940's), would define best value as the (source selection) decision that maximizes expected utility under constraints. So Best = Maximum Value = Utility Before you object to me kicking the can down the road when it comes to defining 'value' I will quote the great Jeremy Bentham.. By utility is meant that property in any object, whereby it tends to produce benefit, advantage, pleasure, good, or happiness, (all this in the present case comes to the same thing) or (what comes again to the same thing) to prevent the happening of mischief, pain, evil, or unhappiness to the party whose interest is considered: if that party be the community in general, then the happiness of the community: if a particular individual, then the happiness of that individual.

I agree with that. For a large risky IT project - which consolidating >100 separate HR systems into one, for ~2,000,000 employees, in 18 months, after having fired the staff of the agencies upon which the success of this project depends, is indeed - the thing that matters is what the offeror has done. A good 1102 CE exercise is to have student/class pick some very familiar software (like MS Word, Gmail.) and attempt to describe it in a "technical approach" style and notice how woefully that compares to just showing how the software works. Would you, as an evaluator, know more about MS Word's ability to do what you want after 10 minutes of using MS Word, or after having read a 100-page pdf about MS Word?

Good: 119 HR systems is too many. Consolidation seems like a good idea. Bad: It is the intent of government for all agencies to go live by July 4, 2027. Completing the transition for the entire federal government - both civilian and military - in 18 months is impossible. Everyone involved knows this. That this ludicrous goal made it into the solicitation is a very bad sign. Terrible. FFP. Given the complexity, large dollars and ludicrously short designed-to-fail delivery schedule, there are very high risks of many types of bad to catastrophic failure, which the contractor will be nominally absorbing. So this is going to cost...a lot. A FFP contract is going to be galactically expensive (now or later). The GVT cannot actually transfer risk of a mega-project like this onto the contractor, so it's getting the costs of FFP, but not the benefits.

The main use case is when you have a requirement that can be met by some non-MAS IDIQ, but isn't a good fit for an order. An indefinite delivery vehicle (FPDS's term, not mine) would be better. Under the old FAR, you have three options. First, use an MAS to establish a BPA, even if the other IDIQ is otherwise superior. Second is to wield the innovation hammer and beat your indefinite requirement into a definitive order - usually with lots of dubious options, bloated scope, and forgoing future competition (see below). Third is to do an IDIQ. Now, you have a fourth and far superior option - the IDIQ-BPA. Consider the Best-in-Class sources. OASIS, EIS and NASA SEWP (to name but a few) are all big multiple award IDIQs that effectively issue second-tier IDVs which have been beaten into something which I suppose meets the legal definition of an 'order.' So yes, this can be done - and has been done for years. But just allowing a second-tier IDV and doing away with the subterfuge and complexity (aka 'innovation') would be much better. Generally, the self-administrated IDIQ is the last resort, anything else is preferable. There are some agencies that are awarding their own IDIQs which could have been an MAS BPA, but not too many of them. This isn't common, or a big problem. At least according to a cursory look at FPDS data. Also according to common sense - IDIQ's more effort than a BPA, for basically the same result. People aren't doing this for fun, or to spite the FAS.

Having read the relevant USC and GAO case, I agree @FrankJon that a BPA issued against a multiple-award IDIQ is exactly the 'second-tier IDIQ instrument' which will remain inconsistent with statute regardless of what's stated in FAR 16.5. From B-411699; B-411796: The FBI’s contemplated award of a 5-year second-tier IDIQ instrument to a single contractor is inconsistent with the requirements of the applicable statutes and FAR provisions regarding what constitutes a “delivery order.” Those requirements are, at a minimum, that the delivery order be defined as to quantity, place of delivery and schedule. In essence, the two orders contemplated under these RFPs will deprive all the other TacCom contractors of a fair opportunity to compete for each of the delivery orders that will be issued in the future ... How was statement true then, but is not true now, given the applicable statutes haven't changed? Caveats: 1) I am not an attorney, and definitely not a federal contract attorney, nor an expert practitioner. 2) I think second-tier IDIQ instruments are a great idea, and the prohibition against them is red tape.

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1) This meets a fairly widespread need. You have a long-term requirement that with relatively broad but stable scope, although the specifics will change over time and are unpredictable. This is ideal for an IDC/IDIQ/BPA. You can't meet this need with any GSA MAS-holders, but you could with some other multiple-award IDC contractors. Now, with RFO, you can use that other multiple-award IDIQ to establish a BPA. 2) The fact that of all the multiple-award IDIQs out there, only FSS/MAS could be used for a BPA - that feels like an anachronism, which the RFO has finally gotten around to correcting. Like striking out the text about facsimiles. 3) Ex post fasto legalizing SEWP 'Catalogs'. I hope this is the real explanation. SEWP Catalogs are great, my agency loves them. It greatly reduced time and effort of procuring routine IT hardware. A tremendous saving.

Final comment while I wait around to close out the fiscal year. In HHS, somewhere between 60 - 80% of contract actions are never posted to sam.gov. What goes out on sam.gov are some large non-commercial actions for medical-biological-R&D type stuff, and lots of small procurements of products that aren't available from existing sources (like obscure scientific instruments). The vast majority of services and something more than 95% of IT don't go on sam.gov.

My take is that refers to those GWACS that are exclusively for 8(a). For example, GSA has got a few of them (including BMO,). This isn't anything new.