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PBSA - Can you point me in the right direction? I feel lost.


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Good day to everyone,

I am hoping you all could help correct me and point me to additional material to read/review.  First, I have MCI, so my memory and my ability to recall information is lacking compared to most.  But I try my best, and it surely takes me many more hours than the average bear.  Mostly on the weekends and evenings. 

Anyway, I’ve been in the 1102 career field for almost 20 years (I wasn't always this bad, but over time my recall ability has decreased significantly), and I have never been on this side of the fence.  I directly support a 3-Star and he has not been pleased with the results they’re receiving from some of their contracts.   I’ve been tasked to basically lead/develop and create the entire contracting requirements package.  I have no other support…such as a technical requirement owner I could bounce ideas off of. 

What I’ve been struggling with is the idea of what type of effort this should be.  What I mean by that is, the old effort has a lot of fixed price LOE on it.  The boss thinks he wants a performance-based services acquisition.  I have no earthly idea how in the world I will develop this requirement, focusing on “outcomes” for auditing services.   Because we’re basically paying companies to conduct audits.  FFP, LOE; paying for hours.  How can I successfully and clearly measure a service to audit something? How does the USG verify the work? Based on the number of issues they discover?  The number of issues they don’t discover?  The old effort FFP LOE, paying for hours, is flawed in the sense that there really aren’t any measurable deliverables.  If the contractor shows up for 40 hours a week, they’re getting paid.  That is the root cause, we have nothing to hold the contractor too.  I suggested some kind of report that the COR could review to verify the audit progress has occurred.  The "COR" is an 0-6 and has no desire to do any of that, so he said, no.

I know I am missing the ball here.  I’ve read a few things on this website, and one example for PBSA was cleaning the floor.   Even then, isn’t the end result somewhat debatable?  Couldn’t a person debate what a “clean floor” looks like?  I know that is silly, and I am not being a wise butt here, but normally everything has to be so clearly defined when you issue a solicitation.  For many reasons, contractors propose based on the solicitation, and they don't want to lose money in an FFP environment. 

I am really struggling with this tasker.  I’ve never had to write the PWS before, I was never a requirement owner.  I've always had an IPT where different sections were drafted by SMEs related to each specific section. 

How can I successfully measure a “performance objective” for an auditing service? If there were incentives tied to this, I could relate it to perhaps time, so the quicker the audit is completed the higher the incentive.  The problem with that is speed could increase the chance or mistakes, which we don’t want.

Because of the power this individual has, the contracting shop will basically award anything, and I mean anything that comes their way.  It’s not really their fault, it’s just a matter of the 1-Star SCO (Term changed now but Senior Contracting Officer) “losing” to the 3-Star every time.  It’s a very uphill and very political battle, that the SCO will lose every time.  This has created an environment where the contract requirements package has basically been a bag of crap that Contracts then has to award.  Which then causes the 3 Star to be upset when the contractor isn't performing to his liking.  And the circle continues.  I hope I can help change this evil circle.

The dollar amounts aren’t significantly high, so these normally go under the radar of other type of contractual oversight.

I just want to do the best job I can within my abilities.  I am just really struggling with the idea of PBSA for my type of service, auditing.  I’ve read the DOD PBSA December 2000 countless times, and I still can’t get it to click.   I don’t know what a measurable “outcome” could even possibly be… the contractor completes the audit?  Okay, but how can we even truly verify they completed the audit? 

Can anyone suggest a decent contract as an example?  Perhaps I can pull it from EDA? 

I appreciate your time, knowledge, and support. 

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Doinmybest,  I have a lot of experience with PBA and while there are often very good reasons to utilize it, this isn’t one.

What I recommend for situations similar to this where existing contracting approaches don’t seem to be as effective as people like is conducting market research.  Carefully lay out the problem in succinct terms.  Invite a handful of the best performing companies in the auditing business in for a meeting or virtual conference.  Ask them for ideas, lessons learned, and best practices of others.  Also ask other government ideas to share their experiences.  A favorite question of mine for companies when concluding the sessions is “if you were in our place, what would you do?  This should give you good thoughts on how to structure a better approach.

If your management still insists on PBA, about the only thought I have is based on experiences of a few agencies using consulting type A&A services.  They use a report card type evaluation of contractors performance much like an award fee process.  The results tie into past performance which affects selection of the next competitive for new work.  As far as I know they haven’t had any protests or challenges of the process.  Somewhat related is multiple awarded debt collection contracts where future business is mostly dependent upon success in collections.  But that uses more quantitative assessments than what audit services involve.

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31 minutes ago, DoinMyBest1102 said:

I appreciate your time, knowledge, and support. 

Quite a challenge.  My thoughts in no particular order.

Have you asked why the boss thinks performance based will work best for the situation?

No technical requirement owner?  Presume that means no program area for the assist?   Leaves a big hole as to what mission accomplishment looks like.   This may require you to do more extenisvie market research.   SAM.gov for examples of audit services procured by other agencies.   An RFI, possibly with a sample work statement, to engage input from entities that provide audit services to gauge if you are on the right track.  Even entertain a pre-solicitation get together with industry for their input on the RFI and invite the boss to observe to understand better the challenges of putting the perfect contract together.

While you might find a decent example avoid using it exactly for your need.  I know crazy thought but maybe ask the boss to provide input on whatever best sample you find for buy in. 

Here are some links that might help help you zero in.

Good luck......

https://www.gsa.gov/system/files/CCAS Ordering Guide May 2023.pdf

https://oig.hhs.gov/oei/reports/oei-07-99-00430.pdf

PS - I just finished this when formerfed posted.   Some of my content relates to his content. 

 

 

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I don't know what is being audited, or if an audit is what is really being procured.  However, DoD is awarding contracts for audit services to augment DCAA's capabilities.  I don't know what office is awarding the contracts, but I suggest you contact DCAA and see if they can help you.

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2 hours ago, DoinMyBest1102 said:

Thank you all for the tips and helping me to develop a better path forward.  It always goes back to market research.  :)

Thanks again!  The A&A sounds interesting and more aligned with the scope.  Something for me to consider.  Also thank you for the links C Culham, very helpful reads. 

If you do decide to proceed this way, be sure to describe your task order ordering procedures carefully and in detail in your solicitation.  You don’t want post award protests.


 

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