

formerfed
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Everything posted by formerfed
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I don’t think you understand the complexity of this change. First of all, it’s very expensive and GSA doesn’t have the funds. Next it’s exceedingly complex not only in terms of development but testing. FPDS has something like 20 million contracts in the database. Someone just can’t lets make a programming change for actions effective right now and going forward and it’s done. Rather the change will affect any contract that is still active. Then it has to be extensively tested through all potential scenarios. If it’s not, the potential for FPDS to malfunction is likely. All in all, it’s going to take a large staff of developers and testers a long, long time. And there’s still a question of paying for it all.
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
@Vern Edwards There are so many rules, it’s too much effort to ensure 100% compliance at the solicitation and contract document preparation. Most contract specialists use contract writing systems and don’t have the time or energy to verify if all the proper clauses are present. Their supervisors, contracting officers, procurement analysts, and any other reviewing personnel don’t put much effort into their tasks either. There’s little if any fallout when mistakes surface. The only repercussions now seem to be for major issues like improper influencing the awardee selection process, taking bribes and kickbacks, or antideficiency act violations. Otherwise discovery of improper rule violations just gets shoulder shrugs. Priorities to make timely awards, acquire what the mission wants above all other issues, and hitting the socioeconomic goal numbers really dilutes the importance of awarding a contract 100% compliant with all the rules. As stated, there are too many rules to enable that to happen. -
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
No other agency has such a strong and enthusiastic constituency base as Labor. Unions fight tooth and nail against anything that reduces their power. They will view increases in contract thresholds as weakening their position as staunch supporters of labor, even if the increases are trivial by today’s dollar equivalency. -
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
I agree Joel. I’m just responding with what I think DoL will come back with. -
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
It probably is more difficult now to increase the thresholds as it was in the 1980s. Wage determinations are online and contracting personnel can access without the delays from the past. DoL will fight and say the administrative effort on contracting is nil. -
mail meter pricing/award structure
formerfed replied to Supes's topic in Contract Pricing Including CAS & Allowable Costs
The NTE amount isn’t really necessary and not part of commercial practices. When someone uses all the available funding, thr machine won’t generate postage. So your approach providing funds periodically makes sense. You could include language that the contractor should notify you when X% of the postage funding is reached. That allows time to replenish the machine if workload increases beyond estimates. -
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
The Service Contract Act, enacted nearly 60 years ago, has a threshold of $2,500. That amount never was increased just to make organized labor happy. -
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formerfed replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
What is the purpose of this? Is it for your own edification, a project you are working on, or a paper you are writing? Responding properly takes some effort so we need to know. -
Exactly. The process varies by agency. P-Ferg, check with your agency procedures. Rather than a contracting officer trying to remove an evaluator on their own, it’s more prudent for the CO to discuss issues first with their management and then with the technical evaluators management. If it’s a legitimate concern, mostly likely it can be resolved through frank conversations.
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I’m not sure I understand. Let me phrase the situation differently and you can tell me if that’s correct. The subject item is a software license from a small business. The vendor doesn’t really do anything other that provide the software through the license agreement. There was a lapse in coverage because the PM was late in sending a renewal requisition which initially also had some incorrect information. So the question is whether submission of a tardy requisition for continued use of software constitutes an unauthorized commitment?
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Subpart 16.4 - Incentive Contracts (T&M)
formerfed replied to GEO-PCO's topic in About The Regulations
Here’s an idea - use an award term contract. You could employ a variety of factors including employee retention where a contractor can earn additional periods of performance for meeting or exceeding goals. Here’s an article Vern Edward’s wrote Award term Theres data showing many companies are motivated more by continual performance than greater profit/fee. -
It looks like the primary objective here is obligating funds rather than using prudent contracting strategies. Just from a program perspective, there are lots of considerations. There are three incumbents. Are one of more considered valuable to the program? If so, what are those merits? Will transitioning be significant and what will be the impact of a brand new contractor? What are plans for minimizing transition risks and how will be play in contractor selection? Is price the primary consideration? If not what other factors are important including past performance? What are the benefits of consolidation of the three contracts? How about extending the three contracts until a new competitive procurement can be conducted in a more reasonable timeframe?
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Can you provide more detail? What is the contract for? Estimated dollar value? You mentioned BPA - is this under the SAP or covered by some contract vehicle? Is this for a commercial item? I know you are on the contractor side but why the time crunch for receipt of offers and evaluation since there’s almost two months left in the FY?
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Yes, and it takes a commitment to research, study, and train besides just doing the expected 1102 job production work. Someone has to view this as their profession with a keen interest to learn and grow. In my opinion, it requires similar motivation as does a hobby where you are interested and excited to discover things.
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What’s more troubling for me is those people in contracting that know rules but not how to appropriately apply them. They are the ones quick to tell program office personnel why they can’t do something but never help or show how they can get a job done. They are the tough guys who feel their job is enforce rules but are afraid to take any action. Years ago, a Cabinet level agency had a contract attorney review proposed awards. He regularly sent actions back because he didn’t want to sign off as “legally sufficient.” He was called the “abominable no man”
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Learning is also a continuous process. With all the revisions, expansions for new and updated topics, and legal decisions impacting interpretations and understandings, one needs stay on top of it all. That’s a big task. I personally know I’m a shadow of my former self when all I did was contract specialist work.
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So true. I know a couple sources that provide this type of service. Their cost to companies is usually prohibitive. The head of one company is frank with companies and often tells them to not bother. For small dollar contract he says their investment to him isn’t worth it For medium and large size contracts, he says the companies won’t stand much of a chance against experienced competition. Fortunately him he’s retired and does the work almost as a hobby. He adds how frustrating it is when they call him for help on short notice, often a few days before responses are due too.
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@Vern EdwardsIt appears the situation will only get worse. The FAR and supplementing regulations, policies, procedures, along with detailed agency instructions steadily increases in coverage. At the same time we continuously more towards automated tools to do work. That takes away the need for contracting personnel to understand what the rules say. Compounding all this for both government and industry is the desire for streamlining with speed - there’s no time for detailed examination. It’s almost blind reliance on the given processes.
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@Vern Edwards In my opinion, absolutely not. The very largest defense contractors have knowledgable and experienced contract staffs. But the majority of contractors don’t. In most cases, they propose on blind faith and don’t fully understand what they fully are committing to. Then if they are successful in receiving a contract award, their vulnerabilities can be exposed. The government has the ability to bankrupt and destroy a naive contractor for noncompliant performance.
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Yes. Plus it involves continuous awareness of changes and interpretations of regulations, policies, legal decisions, and operational practices throughout the government. It’s a never ending process to stay current. It also involves the ability to communicate that knowledge and expertise to others and apply it to practical situations. That often separates a bureaucratic policy person from an exceptional operational contracting officer.
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Reminds me of the government buying and deploying obsolete desktop workstations in the 1980s. The contract lead time was so long, the computers often were two generations old when award occurred and computers deployed to users.