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IGE for supplies


CS1102

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AFARS 5107.9002(b)(1) states The KO shall ensure prior to accepting an IGE that The IGE contains enough detail to verify the validity of the offerors’ proposals; When it comes to the maintenance and overhauling of parts I continually get IGE's with zero details, and they state since it's a supply part they don't need to provide detailed. I've never heard of this does anyone know of a regulation that supports their statement that supplies do not require detailed IGE's? 

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50 minutes ago, CS1102 said:

AFARS 5107.9002(b)(1) states The KO shall ensure prior to accepting an IGE that The IGE contains enough detail to verify the validity of the offerors’ proposals; When it comes to the maintenance and overhauling of parts I continually get IGE's with zero details, and they state since it's a supply part they don't need to provide detailed. I've never heard of this does anyone know of a regulation that supports their statement that supplies do not require detailed IGE's? 

Specific to the Army, no.   I think that the Army states the imperative for an IGE for all procurements over the SAT.  Reference 5107.9002(a).

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Carl is right, that the AFARS only requires IGE for procurement actions over the SAT.

But even then, the AFARS text provides some appropriate flexibility -- for example, the text speaks of "...enough detail to verify..." and "...sufficient narrative and analytical detail..." -- perhaps the people you are dealing with have an understanding of "enough" and "sufficient" that differs from yours?  I hope with professionalism and appropriate discretion you can solve your problem.

You might note that the AFARS does not require "detailed" IGEs -- you are introducing the word "detailed" as an adjective for IGE.  The AFARS merely requires an IGE with "enough detail" and "sufficient narrative" -- do you see the difference?  For a very routine buy, there could easily be a dig difference between "enough detail" and "detailed IGE."

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3 hours ago, CS1102 said:

with zero details

If true I would conclude as you have that a IGE does not meet the intent of the AFARS.   In support I would offer this document (link below) which I think is still current.  While the docment deals with services to a large part it does provide an example of an IGE for goods and services which could help in determining what is enough detail and sufficent narrative again suggesting that "zero" does not quite cut it.

https://www.acq.osd.mil/asda/dpc/cp/policy/docs/sa/DoD_IGCE_for_SA_Handbook.pdf

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On 7/25/2024 at 6:14 AM, CS1102 said:

When it comes to the maintenance and overhauling of parts I continually get IGE's with zero details

Is this categorized as an acquisition of services or supplies? What is the Product and Service Code (PSC) assigned to the acquisition planning documents, DD2579, and solicitation?

On 7/25/2024 at 6:14 AM, CS1102 said:

they state since it's a supply part they don't need to provide detailed

Who is categorizing it as a supply? Does the contracting officer agree?

On 7/25/2024 at 6:14 AM, CS1102 said:

does anyone know of a regulation that supports their statement that supplies do not require detailed IGE's?

Ask them to cite a rule to support their assertion. They should have the burden of proof.

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On 7/25/2024 at 7:14 AM, CS1102 said:

[D]oes anyone know of a regulation that supports their statement that supplies do not require detailed IGE's? 

Asked like a true bureaucrat instead of a buyer of goods and services. Forget the regulations and think like a buyer!

I don't know of anything that supports the your requisitioners statement. They came to you with a purchase request that presumably includes a dollar amount. Well, where did they get that number? Probably from the last order or contract. They don't have any detail because they didn't make any estimate, probably because they didn't know how. How do they know the amount on the PR isn't too low or too high?

The most extended discussion of government estimates that I know of off hand is the Contract Pricing Reference Guides (CPRG), Vol. 1, Price Analysis, which discusses them in 47 places. READ IT!

In one place it says:

Quote

When determining how much reliance you can place on the Independent Government Estimate in making contracting decisions, you must evaluate the depth and quality of the analysis involved in developing the estimate. As a minimum, you should consider the following five areas: 1.1.1 - How Was the Estimate Made? 1.1.2 - What Assumptions Were Made? 1.1.3 - What Information and Analysis Were Used? 1.1.4 - Where Was the Information Obtained? 1.1.5 - How Did Previous Estimates Compare With Prices Paid?

Don't look for a regulation to tell you how much detail should accompany a government estimate so you show it to the requisitioner. The amount of detail accompanying an estimate usually depends on the nature of the thing you're buying. If you're buying something unique or custom, then the estimate should include some amount of analysis. If you're buying commercial items it may be based on internet searches, informal quotes, prior buying history.

What are you buying? Nuclear warheads? Cruise missiles? F-35s? Pencils? You didn't say.

From the CPRG, Vol. 1:

Quote

When determining how much reliance you can place on the Independent Government Estimate in making contracting decisions, you must evaluate the depth and quality of the analysis involved in developing the estimate. As a minimum, you should consider the following five areas: 1.1.1 - How Was the Estimate Made? 1.1.2 - What Assumptions Were Made? 1.1.3 - What Information and Analysis Were Used? 1.1.4 - Where Was the Information Obtained? 1.1.5 - How Did Previous Estimates Compare With Prices Paid?

***

Independent Government Estimate (FAR 15.404-1(b)(2)(v)). As the name implies, the Independent Government Estimate must be developed independently by the Government. Independent development is vital because this estimate normally provides your first indication of a reasonable contract price and it is also one of the bases that you should consider in contract price analysis. The estimate development process may be automated or manual, but the best estimates reflect the requester's market research. Reviewing Requester Market Research. FAR Part 10 requires market research before developing new requirements documents for an acquisition. Logically, this responsibility falls on the requester. The quality of the requester's Independent Government Estimate usually depends on the quality of the requester's market research. Because of the importance of the Independent Government Estimate to your selection of appropriate acquisition techniques and eventually your decision on price reasonableness, you should review the estimates carefully, before initiating further procurement action.

***

Market Research Information. The most successful estimators know their item. Before they make an estimate, they collect information on the product and the market for that product. Their market research may be a one-time effort or part of an on-going process that is an integral part of their normal job.

***

If the rationale used to develop the estimate is not clear or does not seem reasonable, ask questions! IN PRICING, THERE ARE NO DUMB QUESTIONS! If you do not know, ask! By asking questions about the Independent Government Estimate and accompanying documentation, you can identify assumptions that are not consistent with market realities and work with the requester to improve the estimate before the contracting process begins.

 

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