Vern Edwards

What do you rely 0n when you evaluate "past performance"? Do you rely on: documented facts about the requirement and the performance or expressed opinions about the performance obtained from "references"? Are you able to obtain documented facts? Or must you rely on opinions? If you must rely on opinions, how much should you rely on the opinions of persons you do not know?

DD Form 1423, Boxes A, E, and F, must be filled in AFTER contractor selection and BEFORE contract award. A contract specialist or any clerk can fill it in.

Does your manager conduct regular in-house training about particular subjects, such a contract line item development? Maybe during "brown bag" lunches? If not, would you welcome it if they did?

I became an 1102 in 1974. I can tell you that the work and status of contracting officers has already changed drastically, and not for the better. The 1102 community really needs to take a long look and redefine their place in the system. But smart people will always find a way to survive and prosper in a new regime. Knowledge and skills are the keys to success. The trick is to be the GO-TO-CAN'T-DO-WITHOUT. Master Of The Game Remover Of Obstacles. Solver Of Problems.

My thought is that you are not stupid. The pending new policy is probably a reaction to the feeling that it takes too long (in their estimation) to award construction contracts under the FAR. We are living through a time of high anxiety about military affairs. In my subscriptions I am reading a lot of concern that we are falling behind militarily. DOD (DOW) wants to cut the bureaucracy and speed things up. But lead times are long due (1) to the outdate competition in contracting statute ("full and open" competition is an absurd, costly and time consuming policy), outdated contractor selection and contract award procedures and (2) workforce knowledge and competence issues. Going to OTAs is going to stress the workforce, especially considering the fact that construction is a complex and highly litigious industry and process. You might be able to get on contract more quickly, but you are going to get lousy contracts and lots of litigation. What we really need is: (1) repeal of CICA's "full and open" standard, which is stupid, (2) sensible rules about competition, and (3) better and more intensive and specialized workforce training. It would help if (1) construction contracting were to be considered an acquisition specialty and construction 1102s were given intensive and high quality training and (2) chiefs of military construction contracting offices and contracting officers were experts in the field. But try convincing clueless high-level policy makers and managers. Innovation by the inexperienced and ignorant will only make things worse. When I was first assigned to procure construction services I received no instruction. I did not know how to read plans and interpret specifications. I bought books about construction practices, cost estimating, and project management, and a dictionary of construction terms, and went to the sites in order to give my reading practical experience. It took me a while to catch on, When I did I found construction contracting to be real fun, but I never became expert. It takes a while.

I agree. He entirely ignores the question/problem of bureaucratic competence. Read contracting opportunity notices at SAM.gov and the accompanying documents. Read solicitations. I respect Fukuyama, but brilliant scholars should be leery of offering off-the-cuff, oversimplified opinions in interviews.

Francis Fukuyama: Is he right?

Why didn't the RFO gang move the duplicative coverage of the Uniform Contract Form in FAR Parts 14 and 15 and move it to FAR Part 4, where it properly belongs, and combine it with coverage of contract line items?

That's as daming an assessment of the contracting workforce as I have ever read.

That is an understatement if ever there was one. The postings at SAM.gov reflect the utter chaos of today's contracting universe. What you see there is shameful.

See RFO FAR 12.204 (c): Mandating use of the Uniform Contract Format is one of the best things in the RFO FAR.

Thanks, Carl.

@ All: Let me rewrite my question, and ask the following two, instead: In a procurement of commercial services by, say, a component of the Department of Defense, is it consistent with commercial items policy for the agemcy to require the contractor to comply with in-house military regulations specifying how agency personnel must perform the same work? If the agency does require such, is the acquisition really commercial? Here is the RFO FAR 2.101 definition of commercial service:

I have read a SAM.gov announcement for a "commercial service." The performance work statement for the service requires the contractor to perform in compliance with several agency procedural regulations, amounting to more than 300 pages. Is that service really commercial?

Thank you, formerfed! I had attached the request for reconsideration. I have now attached the correct one.