Vern Edwards

Go to: https://www.dau.edu/sites/default/files/Migrated/ToolAttachments/icm_guide.pdf That should take you to DOD's 134-page Indirect Cost Management Guide: Navigating the Sea of Overhead, 3d ed., 2001. It is a free pdf download.

Dear Wifconers, I have spoken with Bob's family. He died yesterday, November 24, of gall bladder cancer. He had been diagnosed as Stage 4 on November 14. The family has made no decision about continuing the site and have said they need time to think things over. I will let you know of any developments. Vern

Dear Wifconers, It is my sad duty to inform you that Bob Antonio has died. I was notified by the Kennett Township police just moments ago. I have no details. The police spoke with his family, who were at his house, and asked them to call me. If I learn anything more I will let you know. I do not know whether Bob made an arrangement for the continuity of Wifcon.com, but I doubt it. So this may be goodbye for now. Vern

In an ambush there are two kinds of people: those who duck and wonder who the shooters are and those who fire at the noise.

Don't need AI. It's not smart enough. We have received some terrific ideas from other sources, people who really know the business, inside and out𑁋people with both deep knowledge and hands-on practical experience at several organizational levels. A team of experienced writers is working hard on preparing them in presentation form. I don't know if anything will come of them. Maybe nothing. We'll see over the course of the next year.

All, I have been trying to reach Bob for two weeks, but have gotten no answer. I have finally located him in a hospital in Pennsylvania, where he is a patient. I have his room number and phone number, but have not yet been able to talk to him. II think he has been there for at least a week, maybe longer. I do not know his condition. If and when I'm able to speak with him or otherwise learn of his condition, I will let you all know, with his permission, of course. Keep him in your thoughts. Vern

@joel hoffman Okay. You have made that assertion several times now. You're making it on principle. I get it, but disagree. I disagree because we spend a fortune every year on lengthy "best value" proposal-based competitions for services that too often take a year or more to conduct because we solicit and assemble teams to evaluate non-promissory proposals that are little more than sales pitches ("Describe your proposed approach..." "Demonstrate your understanding...). We routinely declare price to be the least important evaluation factor, make fantasy findings of strengths and weaknesses that we say we have found in what is too often just bullshit, award contracts to strangers without ever having met or discussed anything with them, and then spend millions each year fighting and suffering delays due to protests about our evaluations and our fantasy findings of illusory "value." It wouldn't be so bad if we dropped the requirement for written proposals and evaluated oral presentations, instead, but we're too poorly trained, hidebound, and stupid to do that. And you think that's less costly and more economical than qualifications-based competition and one-on-one price negotiation with a tentative selectee and with competitors waiting in the wings? Well, I reject your opinion. If we are ever able to make the change from proposal-based to qualifications-based competition for services a la the A-E method, you can complain to your congressional representatives.

I don't think it is essentially a "sole source" price negotiation. It is negotiation with a chosen party, with others in the wings if the chosen party won't be reasonable and tries to drive too hard a bargain. A good contracting officer would have leverage, which they wouldn't have with a true sole source. And I don't know of any rule prohibiting the CO from asking one or more of the other parties for quotes while negotiating with the chosen party.

FAR 36.606, Negotiations, paragraph (f): @joel hoffman Do you know of any studies or reports that say the government is paying unreasonable prices for A-E work because of the lack of price competition in the selection process?

Well, maybe something will happen about CO appointments, which have been far too liberal, and which can be addressed in an executive order. And head-to-head price competition may not be a good idea in the acquisition of custom services when work statements are vague, as they almost always are for such services. With the current system, no competitor really knows at the time of contract formation what service will be required and what it will cost, unless there is an incumbent, and even they may not be sure about the future in a recompete. That's one reason why hourly labor rate pricing has become so popular. In any case, price is almost always the least important evaluation factor.

@joel hoffmanReally? How could qualifications-based selection a la FAR 36.6 possibly be more costly than requiring competitors in service procurements to write "technical" or "management" proposals, or both, describing their "proposed approach" to providing a service described in a 25 or 100 page "performance work statement"𑁋written by someone who has no clue𑁋in order to demonstrate their "understanding" of the requirement and the "soundness" of their "approach" without merely repeating the words of the PWS, then assembling an evaluation team to read those dissertations, perhaps partially written by AI, and write "strength", "weakness", and "deficiency" reports, and then make tradeoffs among fantasies. And price is almost always the least important evaluation factor. And all that is often done without conducting discussions!!!!! Without talking!!!!! Business conducted between strangers, without face-to-face communication until after the contract is signed!!! Based on obscure statements of requirements and obscure "approaches" to fulfilling them. The FAR Part 15 source selection process, developed in the late 1940s and early 1950s for weapon acquisitions, is, as too often conducted, so STUPID, so time-consuming and costly, that it sometimes seems like a subversive Russian, Chinese, North Korean, or Iranian plot. Let's see what costly, time-consuming stupid thing we can get U.S. government contracting officers to do next. We've tried to get COs to dispense with written "technical" and "management" proposals for services acquisitions and to replace them with oral presentations. We even got that into the FAR. And do you know what some of them do now? They ask for both!!!! It's nothing but fodder for the bid protest industry and usually produces no verifiable "best value". Explain to me how A-E selection would be more costly than what's routinely being done "now𑁋being done not because it's required by law or regulation, which say nothing about such "proposals", but because too much of the workforce is clueless and incompetent and just cutting and pasting from what has gone before, a method developed for military aircraft design competitions that has long been known to produce dubious results. Explain it to me, Joel. Better yet, write to Musk and explain it. And safety issues, among others, are just as important in many services procurements as they are in A-E work. Think about aircraft services in support of wildfire fighting or space launch support services. Do you think there are no safety issues in those kinds of procurements? I'm not worried about the "Department of Government Efficiency". If Trump and Musk are opposed to anything they're opposed to stupid, costly, time-consuming methods of contractor selection and contract formation being used by clueless, unimaginative "teams" of civil servants and military personnel and that sometimes take years to complete from conception to award only to be challenged and delayed or derailed (JEDI) by a protest to the GAO followed by a second bite at the apple at the COFC, and even a third to the Federal Circuit. And think of the MATOC competitions in which dozens of firms, even hundreds, get to evaluate themselves and then file protests. The government calls it the "source selection process", and conducts it like a lawyer enrichment process. I can't say what's going to happen. Maybe nothing. There are a lot of fish to fry and only a short time in which to fry them, and acquisition is not at the top of the priority list. But they're heating the oil, and if even part of what is being considered happens some of the clueless fish in our business had better start swimming toward other work. The next two years might be interesting. Shockingly so to some. But it's been interesting before, and stupidity always puts up a fierce fight.

@formerfed I will communicate with you privately tomorrow via Wifcon messages on this page.

And what would be the basis of your protest? What rule would you say they broke?

Some do, some don't. It's what people sent. Thanks. Signing off.

@GovKor You're in business and you cannot figure out how to determine whether a prospective sub's price is reasonable? Really? You can't think that through?