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HHS at at least four deviations for 52.212-5, maybe more, who knows? Not me. And this is farcical.

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Part of a pitch I'm putting together for management.  Essentially, I am arguing that we need some technology solutions to simplify some work processes that are frequent, time-consuming, and 'brainless' (ie, can be straight-forwardly handed-off to software).  As an example of this type of process , I drilled down into exactly what should be done to correctly use the extremely common FAR Clause 52.212-5, within my department, HHS.  It appears to be worse than I thought when I started out.

HHS has three separate deviations for clause 52.212-5.  In addition,  the -5 clause refers to multiple clauses which themselves have different HHS deviations.  By my count, the 52.212-5 clause, in order to be compliant, has to refer to at least four different HHS deviations.  These deviations have mandatory language that cites clauses which are obsolete, or have been removed from the FAR.

My conjectures:

1) Not a single -5 clause in any HHS contract in existence is compliant, in that they correctly identify the (at least) four deviations, and have updated deviation language.

2) Very few people, possibly just me, are aware of this fact (if it is true).

3) Very few people who know or who learn this fact, possibly nobody (myself included), actually care enough to get it right. 


I am venting.  I have no questions.  I would like to be wrong though, so please let me know if I am.

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