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Everything posted by Boof

  1. They are not "obligated" unless that is what was negotiated. You usually you give time but not money, however if circumstances warrant you can give both.
  2. That sure sounds like what the exception at FAR 6.302-3, Industrial Mobilization was meant for. You sole source to the new firm and need the J&A to avoid having to offer it to the regular contractor. Are you trying to say they want to buy the product or service but have no "legitimate" need for the item being bought?
  3. Bob, The best in class list is located here: https://hallways.cap.gsa.gov/app/#/gateway/best-class-bic/6243/best-in-class-bic-consolidated-list . GSAs definition of "Best in Class" is here: https://www.gsa.gov/acquisition/category-management/bestinclass . It is on the public access to the Gateway so no password is needed. Some of these are almost mandatory such as FSSI or the Small Package Delivery. While others are just highly encouraged with lots of justification such as buying desktops and monitors.
  4. Now OMB and GSA are shoving the vehicles they believe are best down our throats. They declare a vehicle or set of vehicles as "best in class" and mandate their use through making us justify why we are not using them. GSA OASIS for professional services, the new DoD Transcom contract for small package delivery, FSSI for office supplies, etc.
  5. Boof

    Paper or Digital?

    Number 2 but not as you portrayed it. Our main contracting office is digital except for signing the award document. The award is scanned and added to the eFile. eFiling became mandatory in May 2017 but compliance (change management) is taking longer than originally thought. Documents are not printed and put in a hard file. The COR files that go with the contract file lag far behind because funds were cut for deploying the system to them. Some personnel have electronic files outside of our mandated central repository and have not found time to move them.
  6. Why are they concerned with fixed price? My guess is OIG or some other audit agency thinks we need to make deductions because they don't understand contracting. Our agency has hundreds of professional services contractors who are from many companies and scattered through the offices all on labor hour task orders or contracts. There is usually a COR for the contract but all the contractors are on task orders, one or two per order. The Government FTE who they support is responsible for tracking if they were on the job and makes sure the COR responsible for invoicing knows. The easiest way to accomplish this is to "concur" on timesheets. The time sheets all get submitted with the invoice so the COR knows how many hours were not worked. If invoices get paid without a Government FTE concurring with the timesheet, our OIG and internal financial auditors say we don't have a legitimate receiving document. We could create a receiving document, reenter the hours and waste more hours sending them forward but concurring on invoices works and is the easiest way for the COR approving the invoices to know if a contractor cut out an hour early or took the day off on leave. Might not be ideal but has worked for years.
  7. Doesn't fixed fee mean fixed fee? The fee should have been 6% of the original approved cost ( a real $$ value not a percentage) for each option period. They do not get more fee or less no matter where the costs go. The subs fee is part of the primes cost. So if the cost goes down with fee dollars remaining the same, he gets a fee % increase but not more money. I don't know your situation but my OIG does not like it if you increase fee or the price of a fixed price contract without a stellar justification for doing it.
  8. With minimal contracting experience from being in Air Force supply, I started as a GS7 and got my 14 in 6 years and my 15 in 12. I had one 4 year stint as a Foreign Service Officer between 14 and 15. I can not think of any field that you can move that fast but you need to keep taking training and putting that training to use. I got my MBA with emphasis in contracting during my early years while I was still taking my mandatory FAC-C courses. I also worked many hours of overtime whenever we were getting close to a big award. So promotions were fast but far from easy. But now I have 37 days left before I say goodbye to the Federal Government and hello to my travel trailer.
  9. You can only do so much with the resources you have. You have to base speed of award and value of the contract on the average worker in your organization and not the superstars that quickly move up the ladder and we lose their skills. And of course for each person above average there is one below average. PALT needs to count against the whole acquisition team including the program office. Every action over $100M should have a formal acquisition team established and their whole job is awarding that contract. It should not be just 5% of everyone's duties with a CO who has to administer dozens of other contracts at the same time. No wonder the requirement takes so long to write that it has to be rewritten twice more due to changes in the mission. Three years and two urgent and compelling bridge contracts later we are still trying to solicit it.
  10. This might seem a strange question but should our purchase orders, delivery orders and contracts for services contain a Freight on Board (FOB) designation on the documents? The issue came up because of our contract writing system defaulting to "destination" on services. They were trying to match up the contract system and the finance systems and wanted to know all the correct standard delivery terms. I gave them FAR 47.303 to list all the possible combinations. Someone suggested creating a new one - "Service Contract Only - No FOB terms" . This is not a FAR definition. Would we have to have a FAR deviation to add it to our writing system? Should we have a FOB for services? What does other agency contract writing systems put in the FOB block when it is services? By the way, we use Momentum Acquisitions as the writing system.
  11. For Department of State we have CORs and GTMs. They both have the same training requirements for the same level of COR duties (FAC COR I, II, or III). The GTM is intended to designate that they work for the COR and not directly for the KO. The KO delegates some of the COR duties to the GTM which could hold a lower COR level depending on duties assigned. Many times the COR will be in the program office in Washington while having GTMs at sites around thee world. The Bureaus sometimes insist we appoint an "Alternate COR" which is not in our DOSAR. This person is usually someone who works in the office of the COR who fills all the same duties when the COR is TDY or on leave. We have a lot of long overseas TDYS. Since the training and experience is met, we usually don't argue and just appoint the Alternate. Our big problem with CORs is not their meeting training requirements but experience requirements. The Government is becoming a revolving door and Bureaus can't find personnel with contracts experience and many do not have technical experience either. With contractors filling our technical positions, the FTEs are sometimes managers from Foreign Service or other career fields and do not know what to look for in performance. We just appoint the best available Government Employee offered by the program office and they can get the experience on the job.
  12. I would say that depends on the security requirements of your Agency or building.
  13. If the Government is serious about streamlining and saving the man hours they are taking away from us in downsizing then they need to scrap the whole past performance system. The CO would only report performance that is substandard after proving the contractor was given a chance to improve. I say this because your large contractors have both greatly sucessful contracts and some failures. Sometimes the failure is only due to picking a poor project manager without good intercommunication skills. When you are on a source selection board you read both good and bad reports on that contractor and it does you little good. It is unrealistic to expect a contractor who is graded on profitability to increase their costs to give the Government something above what they contracted for (satisfactory). All the bad reports would flow to a Government Wide Debarrment Official who would debar any contractor receiving a high percentage of poor performance reports compared to their total contract awards. All companies would be equal if they have no poor reports. My suggestion would save thousands of man hours in writing and processing CPAR reports, simplify source selections, and eliminate one of the largest protest issues.
  14. In my acquisitions office it is office policy that the reviewing official be the CO's Division Director.
  15. The CPAR system is set up to keep COs from being pressured into changing performance reports. Once the report goes to the contractor it cannot be withdrawn and changed. The Contractor makes thier comments and either requests review or not. I have seen the comments section of an outstanding report read like a multi page advertisment for the company. All the comments stay with the report. In the case of judicial action, the Department Point of Contact (DPOC) for CPARS can request the report be placed back in draft for rewrite but this is only done in extreme cases. If you go to the CPAR website you can find the CPAR guidebook that lays out the whole reporting system. I believe the guide is before a sign in so anyone can access it.
  16. Off the top of my head without any research, I always thought that oursourcing was what "privatizaiton" was all about. Contracting out which leaves the Government with some control over the work and outcome or just turning over a Government function to private industry by selling it or giving it away. Can't think of what we may have given away or sold though.
  17. As my office assigns the 50 reqs that we just received this morning, I must chuckle. We have accepted over 500 orders since our cut off of Sept 15th. How can you stop the requests when the funds are not released until September. We just got Congressional Notice on about a billion $ Thursday night. Of course they were ready for award already and awaiting the funds but still there is a lot of work to finalize the award in the system. We plan to be here till midnight like every year.
  18. The FAR Finance Team sent us this response concerning a revision being made to FAR 11.002. FAR Finance Team’s Response: The FAR should not instruct requiring activities (requiring activities must prepare...) but rather the contracting officer. Therefore, the text was changed to instruct the contracting officer rather than the requiring activity (the contracting officer shall obtain from the requiring activity...). I thought the FAR applied to all members of the Federal Government but at least to the members of the Acquisition team. FAR 1.102-4(e) states: (e) The FAR outlines procurement policies and procedures that are used by members of the Acquisition Team........... So how can they say the FAR should not instruct the requirments office on thier responsibility to prepare the requirements document. I just thought I would see what the WIFCON community thought about this. Maybe I am off base in my thinking.
  19. OK so I post my requirement to Alliant SB and if I do not get two acceptable proposals, I repost it to Alliant LB.
  20. You better start running harder or you may get traded. You were my favorite player but you been slacking lately. Anyway, to your question. I cannot opine on all the reasons there might be something wrong with the contract but it probably has to do with the funds. I assume it is a labor hour contract since you mention annual labor rates. Funds are usually annual and cannot fund more than 365 days from obligation on severable T&M labor hour contracts. So they would not have been available for 5 years as you thought.
  21. Eliminate everything having to do with the service contract inventory reporting by contractors. Seems to just be a back door way of getting head counts that the Government can never give accurately. And guess what? They have never gotten accurate data from it either. FAR 4.17.
  22. And get away with it. And be chosen as Best in Class. They might as well not trained me.
  23. If everyone is doing their jobs correctly the past performance information will be in PPIRS. The contractor cannot claim he has none. However, not everyone is getting all their reports into the system. My Agency is about 22%. Everryone says they have no time. Then on the evaluation side, only "relevent" past performance can be considered and their is plenty of protest cases over that. What if it for work in a different NAICS but there is 5 reports in PPIRS (each lower value) that are sat and below. Why should that not be "relevent". Between the CPAR system being too segregated in who can submit reports, password difficulties with the system, and too many protests over the PP evals, the whole system needs to be revamped.
  24. NASA SEWP is where the majority of the COs in my agency go for anything IT related. We are just not that familiar with NITAAC.
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