

formerfed
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Everything posted by formerfed
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@C Culham Excellent thoughts
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@joel hoffman you are correct. This isn’t feasible to complete all acquisitions. From what I gathered, this model just covers off-the-shelf type commercial stuff. 100 pages is not reasonable, but nor should 2300 be. The benefit I see is the model might get people thinking what should the FAR ideally look like. Some promising things are happening, especially to get weapons systems developed faster and cheaper. The proposed Forge Act is an example Forge Act summary here. But for it to optimally work, the FAR process needs revised too. All this should reduce acquisition lifecycle costs and times.
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I honestly don’t know the intent of this. But I can speculate reducing the 2300 pages of FAR, 1300 pages of DFARS, and hundreds more of policies and procedures will greatly simplify and speed up the acquisition process if it’s done properly. There’s a lot of talk right now that the Pentagon is rapidly falling behind other nations because our acquisition process for defense is severely broken. If someone can reduce existing laws, regulations, and policies down even to a few hundred pages of guidance and train and empower the best and brightest to implement, that’s a huge step in the right direction. Even if this exercise just brings attention to how convoluted the present system is, that’s a plus.
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Unfortunately this situation happens. The only successful approach I’ve seen involves (1) bring in experienced staff from other parts of the organization (2) use reemployed annuitants, or (3) use contractors. Regardless on the chosen method, success hinges on quick and relevant training, lots of oversight, and quality reviews with instructional rework when proposed actions aren’t proper. If government staff doesn’t exist, convince management that bringing in contract experts is essential for the short term.
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This person has a goal https://www.linkedin.com/posts/sterlingwhitehead_100-page-far-prototype-v11-feb-16-2025-activity-7296975522381647873-NSBb?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAD7kIsB-HPopONAKvt4lsUP-WTsF4c1_-E
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The language in FAR 49.108-8 makes it clearer that assignment of rights, title, and interests of the contractor and settlement of subcontracts are separate issues. Here’s part of the language So the smart thing for the government to do is stay away unless there are extenuating circumstances. You can assign rights but let the prime handle settlement.
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FAR 49.108-8, Assignment of rights under subcontracts, provides more information. One interesting aspect is “The TCO shall not require the assignment unless it is in the Government’s interest.” So this only comes into play when the governments need that to occur. i did hear this happening twice from a discussion at a conference. DoD terminated contracts for IT development when it appeared the solutions weren’t going to achieve the intended objectives and decided to start over. But they wanted to continue with software packages that the primes subcontractor for. I believe all it took was assigning licenses from the prime to the government directly. The prime just wrote the appropriate language.
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Thank you for the update, Vern. It’s all really good news. Having to re-register is very minor. It allows me tho go back and use my real name the way I started with Wifcon. So many popular websites use outdated technology. Once users and the site owners get comfortable and most of the bugs are gone, it’s not worth switching to something new. Safe travels, Stan
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Good news
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Yes. That is considered market research This can give you perhaps some other ideas https://buy.gsa.gov/spba/steps?step=market-research
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I doubt any of those individuals referred to in the given advice posts have answers right now. I also doubt they would even speculate. Normally contacting those people mentioned is a great choice. But between the suddenness of the orders, court actions pending, and need to provide cohesive approaches between all the affective offices/agencies, it will take awhile to sort out. In short, nobody knows what will happen yet. Any smart person in charge won’t respond to questions until they feel they are on solid ground and their answers are correct and won’t change the next day.
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Message From A Defense Contractor CEO
formerfed replied to Vern Edwards's topic in Contracting Workforce
Yes, maintaining the status quo is important to large segments of the government and industry. On the industry side, the status quo presents a huge maze that newbies can’t begin to navigate. So the “old boy” pool keeps the competition to themselves. On the government side, major change upsets jobs. Some employees can’t handle it, and they know it. The status quo keeps management in power with all their prescribed rules, processes, and procedures they put in place. An enthusiastic employee who wants to try something different runs into a stone wall. -
Actual Contract Value Exceeds SAT
formerfed replied to GovKor's topic in Contract Pricing Including CAS & Allowable Costs
I’m reading the Formation of Government Contracts quoteDon posted as saying simplified acquisition procedures cannot be used for award if the value exceeds the SAP threshold. But if the value exceeds that amount, I see nothing wrong using the results of the simplified acquisition solicitation process to award a contract under FAR 15 procedures. -
Great response Vern. I started to post something similar but this is much better.
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@Minnen you said “subcontracting will not be accepted.” Do you really mean to not allow an offeror to subcontract or are you intending to just exclude requirements for subcontracting?
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Great news. Thanks for the update, Vern. Glad you have that relationship with the family. Making Bob’s name as part of the site title is perfect.
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The problem is it costs money and people resources just to keep it going even short term. Soon there will be a glitch of some kind or a software update needed and no one to fix things.
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Games or other interesting ways to train?
formerfed replied to Supes's topic in Contracting Workforce
I don’t think anything came from the GSA effort from ten yers ago. I believe they awarded a few contracts for companies to develop prototypes. I’m guessing processes were too high for what they wanted. -
DOJ now accepting Qui Tam cases from lawyers revealing client secrets
formerfed replied to David823's topic in What Happened?
Just because DOJ accepted the quI tam case doesn’t mean the attorney isn’t clear. That’s a violation of attorney/client privilege which could set the attorney up for a malpractice suit or disbarment. -
Single Award IDIQ normalization
formerfed replied to FLContracts's topic in Proposed Law & Regulations; Legal Decisions
What you’re doing is not normalization in accordance with Information Ventures, Inc., B-297276.2 unless I’m missing something. You’re not asking for offerors to propose a level of effort. Furthermore you won’t be analyzing or adjusting offerors LOE or mix of categories. -
Single Award IDIQ normalization
formerfed replied to FLContracts's topic in Proposed Law & Regulations; Legal Decisions
@FL_Contracts I think I got the wrong impression of what you’re doing. I assumed from your initial post and the offerors question that your solicitation covered a rather specific and overall defined need. You had an overall LOE that everybody had to propose against but an offeror questioned their technical approach reduced the overall effort required. The overall scope is covered by the resulting contract and work is broken down by acseries of known task orders. But now I believe you are just establishing an IDIQ contract with specific labor categories and the LOC stated will serve as the max. Then you anticipate a variety of tasks orders which will be negotiated on an individual basis with the contract labor rates. I’m also assuming you don’t know the precise nature of future task orders, some of which may not even be known at the present, so the purpose of the contract is to provide speed and efficiency in contracting for requirements as they arise. Is that it? If so, I don’t see any problems. -
Proposed Increases to Micro-Purchase, Simplified Acquisition, and Other Thresholds
formerfed commented on Koprince Law LLC's blog entry in SmallGovCon.com
@sackanator why not call or email Michael Jackson at GSA? He’s easily accessible and very personable