formerfed

Yeah, something is missing. GSA needs to clarify. The regulation either needs to specify approval levels above the contracting officer for justifications exceeding the SAT or clarify the approval level is still the CO but only after considering responses received from the publication requirement under 538.7104-3. Since MAS ordering procedures are now in GSAM, it’s GSA’s call.

This reminds me of something I read from a senior manager. He stressed how important empowerment, training, and trust is. The gauge he uses for his personal management performance on these areas is his golf score. When he has sufficiently trained and empowered his subordinates, he can take off a lot of time for golfing. He doesn’t need to worry about the job not being done and his golf improves.

Great article, Vern. Thanks for posting it. I hope a few read it, get motivated, and change their outlook on their jobs a little differently. This excerpt is a compelling message for those seeking employment and for managers seeking the best hires:

There’s no better advice for those interested in advancing their career. Right now there’s a mass of confusion out there. The workforce is largely risk adverse. It looks for regulations to be broken down into detailed instructions and precise steps to be take. The majority want to physically see what works so they can copy for their assigned tasks. So not much has happened thus far with the RFO. A few hopefully will see the light. They will do as Vern states - study, learn, and explain to others. I’ll add they will seize the opportunity to apply the revised process to newly selected contracting assignments. They do this before all the policy, analysts, and writers of procurement instructions spend months producing something. They then become the “experts” others turn to including the policy writers. The bulk of the workforce needs led with examples and told the steps to follow. I think that’s largely due to the risk adverse environment created. 25 years ago, Performance Based Acquisition was in vogue. Despite the push to adopt it, not much initially happened because people waited for someone else to take the lead. The company I worked for had knowledge and experience in helping craft the Seven Steps process. Once the word got out we could assist, we had to turn away work due to the demand. The 1102 community wanted someone to tell and show them how to proceed. Another example concerns when the government tried Zero Based Budgeting. Few at the operational level knew what it was about. A newly hired young employee became interested and read, studied, and asked questions. Despite her age, she quickly became recognized as the expert. She saw what’s needed to be done to succeed from that experience and advanced applying that same inquisitive nature to everything she did. She rose to an SES position within record time. To address Carls point, it’s more than just being nimble and flexible. It’s grasping beneficial concepts, studying and inquiring, developing insights and understandings on what needs done to apply, and taking the lead in doing the work as well as continual application throughout your career.

This site contains many of the historical documents affecting our profession. It starts with the 1955 Hoover Commission Report and goes up to the present. https://procurementroundtable.org/#history

@Vern Edwards I would work closely with the program official official who needed help in preparing the SOW. I always liked collaborating with program officials in preparing the SOW and other documents.

AI is most useful in its current stage of development for instructing preparation of items like SOW. It doesn’t produce a complete document by any means but it provides examples, instructions, and means to complete through iterative prompts. I just played around with a SOW for help desk services. ChatGPT provided a simple template which is good to convey what’s needed. Gemini, which is what Google uses, is more informative and referred to examples from HHS and others. Claude gave the closest to a finished product. If I were a CO and had a program office official who looked for help in drafting a SOW, AI can help. Of course, I would need to work closely as the document went through to final. The nice aspect is it avoids copying from other documents which may not be relevant.

You are not alone. The complexity results from a host of varying solutions to changing legal, regulatory, technological, and marketplace conditions. It’s a matter of considering what’s currently happening, “how can we make the Schedules attractive for continual and even greater use?“ So the result is a maze resulting from band-aid revisions. There are lots of complaints from buying agencies - too complicated to follow the rules, prices aren’t good, don’t want to pay the hidden 0.75% GSA fees, and want to utilize their own teams and conditions. Still I find them very beneficial in the right situations. For example, instead of establishing a pool multiple award contracts for supplies or services which might take several months maybe running into a year, award BPAs under the Schedules. One simply does market research, identifies three of four capable sources, and you’re done.

I may not fully understand. But are you asking if it’s okay to develop non-commercial applications using commercial software licenses/tools? Is the office developing the applications government? Or is the office a commercial entity where the application is integrated with the commercial license?

There are many odd appearing actions. But this one is really surprising to me. VA just released a new solicitation for Community Managed Healthcare. The resulting contracts are for 10 years in duration valued at $1 trillion. The solicitation is for commercial items using a combined solicitation/synopsis. There are approximately 40 attachments. https://sam.gov/workspace/contract/opp/7b2734002e4048bfa2ac4cc5b0479930/view The synopsis says “The Government will award a Firm-Fixed Price plus Incentives, Multiyear, Multiple Award, Indefinite Delivery Indefinite Quantity contract resulting from this solicitation to the Offerors whose proposal conforms to the solicitation and represents the best value to the government.” The proposal response time seems very compressed. The synopsis was posted four days ago. Offeror questions are due Jan 6 with a pre proposal conference on Jan 22. Proposals are due March 15. A trillion dollar procurement using a combined solicitation/synopsis with a 90 day proposal due date! Then there’s the contract type of firm-fixed-price plus incentives multiple award IDIQ!

Going back in this thread, here’s an interesting comment about tools to track I copied from another forum: Flywheel of Failure: Stop Managing Programs. Start Managi...Mark says it best - government CULTURE "... rewards the perfect management of a failure, rather than the messy iteration of a success." We need to embrace OUTCOMES over process. Battlefield success“And I can tell you, with absolute certainty, that there is almost zero correlation between a program marked "Green" on a PowerPoint slide and a piece of software that actually works for the mission. This is the enduring flywheel of failure facing the Department of Defense (DoD) today. We are culturally addicted to Program Management—the administration of contracts, schedules, and compliance artifacts. But we are starving for Product Management—the relentless pursuit of value, quality, and user satisfaction. We have built a system that rewards the perfect management of a failure, rather than the messy iteration of a success”

So true. The RFO provides a means for someone to shine. While others sit back and wait for additional guidance, detailed policy memorandums, examples to copy, and see that’s it fine to proceed, a few will see the opportunity to be a pioneer. They will just jump in and use RFO now. Those will be looked at as taking bold actions and not timid. They will be in demand. Others will be eager to listen to or read what they have to say. I know already what the typical reactions to this will be - “wish I could but I can’t do that where I work.” If you are motivated, you’ll just be able to do it. I saw this in another site on a completely different topic. But it’s relevant here. “While your organization debates strategies, policies, governance, and pilot plans….you could be operating in expert mode.”

Excellent thoughts! This seems like a great theme for an article or class. Very motivational.

Some of this stuff is really beneficial and saves time and frustration. For example a contract specialist needs a funding requisition. They can quickly check to see status and where it’s at in the approval process. If it’s urgent they can speed it up. Or a contractor wants to know status of an invoice. The contract specialist can quickly track the invoice down and spot reasons for possible delay. Another example one can see how much money remains on a contract in real time. A manager can look at how many expiring contracts come up for renewals. What actions are exceeding PALT. I know 1102s spend too much time with automation and blindly follow what contract writing systems produce without detailed verification. This also leads them to not knowing over time what clauses say and mean. They just go with what the system produces. Unfortunately it will get worse, especially with AI capabilities getting better and better. Edit: Vern, I was writing this response and didn’t see your latest post. I agree.

Good question, dave2025. As a point of clarification for the entire discussion for everyone, PRISM is a very robust system and contract writing is just one component. Some other pieces including requisitions, workflow processing, contract management/administration support, vendor management, FPDS input, and financial integration. The financial portion is very important to some agencies because it allows seamless interface with accounting and financial systems. All this means is someone with all these components can initiate and track requisitions, apply funds certification (only authorized users while others can view), create solicitation and award documents, track invoices and payments including line-by-line account reconciliation, and initiate closeout. The interface also allows easier creation of dashboards if that’s of importance to offices.

DHS and GSA apparently have success with PRISM. DoD is starting to use it as well. You might have your technical experts contact DHS for advice.

This comment reminded me of a great thing we did a long time ago. This was when no dollar ceiling limit existed for 8(a) sole source. This was also when agencies needed to require a delegation of procurement authority from GSA to purchase IT hardware. My agency, CBP, needed to buy a mainframe computer system, acquire space for a data center, and recruit a large number of employees to operate everything. We were faced with at least a three year timeframe to do it all. We got the idea to have an 8(a) accomplish it all through a contract for facility management operations. The contractor would conduct a competitive procurement for the mainframe, acquire space, and operate everything for us using their own employees. We simply paid for it all as a service contract. It turned out everything was up and running in one year and below budget.

I think if you are using something like Jira and applying it to contracts, you are a pioneer. If you can do it so it’s useful to a contracting office and just the contracting function, that would be amazing. This could be so useful to contract management and let them know early on of potential problems.

An article detailing how intense this is. It also lists all the information SBA is requesting from the 8(a) firms which is much more comprehensive than I assumed. I think FrankJon is absolutely correct in that he can’t imagine the program remaining unchanged. Federal News Network - Helping feds meet their mission.SBA audit, lawsuit puts 8(a) program deeper in cross-hairsFrom Capitol Hill to the courts to now the executive branch, the 47-year old contracting program is facing new questions about its legitimacy.

I meant to say compete all actions and not ones just above the SAT

Here’s a bill Sen John Ernest introduced today to put a hold on sole source 8(a) contracts until SBA completes their study. https://www.congress.gov/bill/119th-congress/senate-bill/3173/text He also sent a letter to 22 agency heads asking for their voluntary compliance. Edit: Wouldn’t a requirement to compete all 8(a) actions above the SAT eliminate much of the price criticism?

From a link Vern posted above: “There is mounting evidence that the 8(a) Program designed for ‘socially and economically disadvantaged’ businesses went from being a targeted program to a pass-through vehicle for rampant abuse and fraud – especially during the Biden Administration, which aggressively prioritized DEI over merit in federal contracting,” said SBA Administrator Kelly Loeffler. “ Everyone knew some problems existed in the past. The issues now are how extensive the abuses are and how much is this is politically motivated. A very important part of fact finding will be in the responses SBA is seeking on ownership and financial data. Plus it will be interesting to see how many companies balk at submitting the information.

I’ve thought about this and I can’t don’t come up with a simple answer. There are so many variables - contract type, nature of what’s being brought, criticality of successful performance to mission, COR/PM respective roles to the CO, availability of existing data in other systems like financial payments and invoice acceptance, and even management desire to monitor certain items. Take the example of “burn rate.” Does a contracting officer want details to track? Or do they want the COR to be totally responsible for that? Or are the contractors periodic status reports sufficient? At the highest level, there should be data letting the contracting officer know the likelihood that performance will be on time and within price/cost limits.

Deltek’s ERP system and Cobblestone’s product are probably the two most frequently used. Both are complex yet robust and take effort to set up, train staff, and operate. But they are fine for large projects. I personally think they are overkill for the majority of government contracts and those products are often barely used for their full capacity. What seems to work best and provide meaningful results are tools specifically set up for individual contract specific needs. First, define what data is needed to effectively manage and oversee performance. Then build the means to obtain and track using tools like Microsoft Project or Excel. Don’t overthink this - just brainstorm what’s needed and set up the process to provide results.

I read this book but this one piece always makes me feel good https://www.thesr71blackbird.com/Aircraft/Stories/sr-71-blackbird-speed-check-story