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competition in contracting statute ("full and open" competition is an absurd, costly and time consuming policy), outdated contractor selection and contract award procedures and (2) workforce knowledge and competence issues.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.

Another tale of the state of the system. Only about two pages. A commercial service procurement. Pay close attention to the award process. Count the number of "contracting officers". How could they screw this up so badly? PUBLISH Protective Order 64442, 64443 Wild Hare Haulers, LLC 6.23.26 Decision2.pdf

I find it interesting that, according to a Adobe Reader search, Kelman mentions "workforce" only six times and only in terms of its size. He makes no mention of workforce in terms of education, training, quality, and mangement. In my opinion, workforce quality and management have been the biggest problems in procurement. A bigger problem than rules. The rules are a problem, yes, but a much bigger problem is the manner in which they are implemented. If source selection takes too long, it's primarily because of the way it's being done, not the rules that govern its conduct. But Kelman did not have authority over workforce quality and management, and I don't recall that he made education, training, and CO appointment issues to be addressed.

I hate SAM.gov, but I've not been sure that my judgement is fair, so I asked Google AI. My prompt: What is your own assessment of the quality of SAM.gov based on your own research? 😃 I was right! I also prompted as follows: What is your own assessment of the quality of wifcon.com based on your own research? Here is the response: Wifcon will pursue immediate updating of the interface and a special feature for those without high baseline knowledge. May take a while and $$$.

I think it's a lazy and thoughtless cut and paste.

The following contracting opportunity was posted to SAM.gov recently, exactly as it appears below, by someone working for the Navy . I have seen other such postings by other agencies. What's up with this? What is your opinion of this kind of thing?

I am pessimistic, because changes in laws and regulations are not enough. Much of what hampers in procurement is attributable to workforce behavior rather than rules. Smart people can work around dumb rules. What we need is to (1) restructure the system and then (2) properly educate and train the workforce, and I don't think either of those things is going to happen. Even they did, it would take years to have an effect. The problems are inherent in the natures of our politics and government, and those natures are not going to change any time soon if ever. Incompetence is obvious and widespread. To see it, spend a few hours at SAM.gov looking at contracting opportunities with a critical eye. But what could happen is that individuals in the system would work devotedly to pursue and achieve mastery in their field. Then they could lead the way by example through small incremental achievements and improvements. That's the best that we can realistically hope for.

The U.S. Congress and Executive Branch, such as they are today, are not capable of producing a substantial and effective overhaul of the acquisition/ procurement/ contracting system and process. The statutory and regulatory history of procurement since enactment of the Armed Services Procurement Act of 1947 proves that. I asked AI "Are the U.S. Congress and Executive branch, such as they are today, capable of producing substantial and effective reform of the Federal procurement system and process?" Here is the answer I got: In short: No. Heck, they cannot even produce an annual appropriation without causing a system-wide breakdown.

Go to Google Scholar and search for: <federal procurement reform AND failure>

Congress launched the modern era of government procurement with the Armed Services Procurement Act of 1947 (actually enacted in 1948). Since then Congress has been perennially dissatisfied with the conduct of procurement. We've had commissions, panels, studies, reports, statutory reform, regulatory reform, and regulatory revision, all of which bring have brought uncertainty, doubt, confusion, hesitation, scandal, and litigation. TINA, CICA, FASA, FARA... just to name the ones with a big impact. According to Federal News Network, more procurement legislation is pending before Congress, including: FIT Procurement Act (H.R. 4123) Value Over Cost Act (H.R. 1118 / S. 2118) Stop Secret Spending Act of 2025 (H.R. 2069) FY27 National Defense Authorization Act Ensuring Federal Purchasing Efficiency Act (H.R. 7283) Contract Our Veterans Act of 2026 (H.R. 7534) The general consensus among critics is that acquisition/procurement/contracting reform consistently failed. Want to understand the state of procurement today? Just spend a couple of hours perusing SAM.gov contracting opportunities. Chaos. What's wrong?

I like that. But is it possible?