formerfed
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Proposed Increases to Micro-Purchase, Simplified Acquisition, and Other Thresholds
formerfed commented on Koprince Law LLC's blog entry in SmallGovCon.com
@jamaal valentine, I think this answers most of your questions. The Councils typically receive a large number of comments and it’s easy to submit. Within the government it’s always a challenge for them to separate comments which reflect a specific agency position and individual agency employee comments. I would be surprised if they received much in the way of negative ones on this change. https://www.federalregister.gov/documents/2024/11/29/2024-27851/federal-acquisition-regulation-inflation-adjustment-of-acquisition-related-thresholds -
Funny but there are a few spots where it all looked too familiar Edit: you’ll probably have to click on the watch on YouTube button on the bottom left
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That’s awful news. I guess the cancer really took Bob by surprise. One of the founders of the company I worked for, Bob Welch, was the Procurement Executive at both Commerce and Treasury. He told me about Bob when we all worked in the government. He said Bob was the one of the very few audit types truly interested in improving the government. The rest were the “got you” types. He added Bob never did that and focused on what everything needs to do to make things better without pointing blame on anyone. Bob Welch’s comments were after Bob reviewed major acquisition programs at both agencies he was responsible for and he had nothing but total respect for him. Creating Wifcon was a perfect example of his wanting to make government better.
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A long time is spent on requirements development. So much, program offices are often reluctant to allow more time issuing draft RFPs or RFQs. Once they finish their part, they want to solicitation issues asap. We all know what happens next - lots of industry questions and associated government answers, multiple amendments with proposal submission due date extensions, and occassionally just scraping the solicitation and starting over. Your tool suggestion has merit. I believe it might work even better with getting industry and even other agencies buying similar items involved early. A preliminary or initial draft could be issued along with high level statements of what the acquisition is intended to accomplish. Responses would allow refinements of the documents and alert the government on conflicting or confusing language, requirements that restrict competition or even impossibility of performance, and suggestions for overall improvements. If this is done early on as part of planning, it shouldn’t produce any delay and might even save overall time.
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Requiring Program/Project Management training as part of COR certification is very beneficial for many large scale contracts. It’s also helpful for some acquisitions for 1102s. I heard a funny response from a senior official about requiring a dedicated COR. He said he will do that when he gets a dedicated contracting officer for his program.
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I was at the Patent and Trademarks Office years ago. We received waivers for much of the FAR. One of our proposed changes was use of FAR 36.6 type procedures to acquire professional services. Senior management backed off due to heavy opposition from small business advocates and organizations wanting to reduce waste and spending throughout the government. We never got a chance to talk to those people because once it turned political with Congress involved, it died. I’m not optimistic things would be any different now.
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You won’t find much specific guidance to help you. Here’s a DoD guide which provides an overall view of the process which may provide better insight. Read the section on solicitation and evaluation. https://www.acq.osd.mil/asda/dpc/cp/policy/docs/guidebook/TAB A1 - DoD OT Guide JUL 2023_final.pdf Without knowing details of your particular acquisition, I say use common sense. Remember, the OT process is about giving the government access to the best industry sources. If your changed requirement can potentially be best satisfied by parties not currently under consideration, I would open it back up.
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Yes, a very large share
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Vendor's failure to submit final invoice
formerfed replied to Doug0464's topic in Contract Administration
I’ve read in several sources the new telephone “etiquette” is texting someone first to ask if it’s okay to call them and what’s a good time? I suppose this has carried over to businesses and unexpected phone calls come as a surprise. -
Vendor's failure to submit final invoice
formerfed replied to Doug0464's topic in Contract Administration
If this is being contemplated, I would also check with the Finance/Comptroller office. There are very few circumstances where payment is authorized without a proper invoice. I would be surprised if they made payment without one. -
We have the FAR. We have supplementing agency regulations. Then we have more detailed policies and procedures at a sub level which often adds delay from bureaucratic review and oversight processes. Much of these exist as knee jerk remedies or band-aid fixes to past contracting blunders. Senior management then implements new reviews, approvals, and controls to avoid repeating the same mistakes in the future. Eliminate needless policies and procedures at the agency/local. Empower contracting officers to make decisions without non value-added reviews and approvals. Hold contracting officers accountable. Reward those with demonstrated exceptional performance. Remove warrants from those with performance issues.
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Issue policy requiring discussions be conducted as the general rule, especially when selections are based up technical/price tradeoffs. Too much is being left on the table with both price and non-price issues by not discussing. Exceptions should be documented and approved at levels about the contracting officer.
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For whatever reasons, the 1102 workforce wants to copy ideas instead of tailoring plans and acquisition documents specific to individual needs. So how about a database of best practices, lessons learned, and new ideas? A central point to review, rate, and provide instructive comments like OFPP could ensure consistency and acceptability using pre-established criteria. Even those people that don’t blindly copy will benefit from seeing practices from others.