there are increased requirements for reporting and compliance that are not reimbursed by the Government but require contractors to develop tracking and reporting systems and have dedicated resources to maintaining the system and information for reporting. CDM is an excellent example of this.
Over the last decade, the number of laws, regulations and provisions that apply to commercial item have dramatically increased. For example, in 1996 under 52.212-5(b) there were 17 provisions of law or executive orders identified as applicable to commercial item contracts. In 2012, the number has climbed to 51. The resulting explosion of statutes and regulations applicable to commercial item contracting increases ...more »
2. Procurement Rules and Practices
The dollar cost involved in the production of a proposal has already been broken down in other Ideas. I would like to add the human cost to the mix. It seems to be standard practice for solicitations to be released right before the Acquisition Office leaves for the week or season. It is common for Industry to receive a solicitation on a Friday afternoon, or a couple of days before a major holiday (this seems especially ...more »
2. Procurement Rules and Practices
In business, time is money. In war, time is lives. Companies and the warfighter alike are threatened by the glacial pace of current procurement cycles. Purchases that have always taken months now take years. As prominent authorities on policy have noted (citing examples such as unmanned systems and MRAP), the USG often has the most success when bypassing the system entirely: “When it is necessary to go around the ...more »
2. Procurement Rules and Practices
Contractors are supposed to submit their initial best offer because award might be done without discussion. But we all know that once the contractors are ranked and graded and the competitive range is established, most of the time, the Contracting officer will issue a request for Best and Final Offer. Proposal development is costly. Multiple submissions also cost money. Contracting Officers are "required" to always ask ...more »
3. Small Business Participation
The Federal Strategic Sourcing Initiative (FSSI) should be on every small business federal contractor's list of issues to quickly be educated upon. The FSSI has been identified as a procurement vehicle which it is expected will be applied to over 90% of all Federal Government Spending. In a nutshell, FSSI awards contracts to a select few while leaving the vast majority at-risk of losing government business. For example, ...more »
2. Procurement Rules and Practices
The Federal Government is always interested to implement activities which are "Best Practices" in the Private Sector. I would like to suggest that one of these "Best Practices" is the Cost-Benefit Analysis (CBA). In the Private Sector, whenever a new policy is being considered, a CBA is performed to evaluate whether to proceed with the new policy. Unfortunately, a CBA was never performed for the Federal Strategic Sourcing ...more »
2. Procurement Rules and Practices
The FAR currently contemplates two solutions to resolve the impact of corporate acquisitions and/or reorganization on federal contractors under the Anti-Assignment Act: the Novation process and a Name Change agreement. We propose that a third avenue be established to address situations in which, due to internal restructuring, the legal entity has changed but the parent company remains the same. In these instances, ...more »
2. Procurement Rules and Practices
Despite a growing body of evidence that fixating on costs actually increases them, acquisition personnel insist on making every transaction cost-based. Sections 2379 and 2306a(d) of Title 10, USC, for instance, provide limited authority to obtain cost and pricing information for major weapons systems and their component parts where certified cost data are not required. This authority is over-applied in practice and ...more »
3. Small Business Participation
Acknowledging that the acquisition process is frustrating and cumbersome is a start, but to understand how to fix it starts with a willingness to look at the acquisition processes, technologies, and professionals from the perspective of a small business owner. Follow a small business owner's experience with the acquisition system - from the first sources sought to award of a contract - for a specific procurement and ...more »
2. Procurement Rules and Practices
Attached is a statement by a company that has done business on federal contracts making the point that it is hard to compete against vendors who cut corners on wages and other required standards.
2. Procurement Rules and Practices
Currently there is a Commercial Items test programs that allows use of SAP up to $6.5M for commercial items, or NDIs that have been sold to State and Local Governments. Unfortunately some design activities are wary about providing commercial item determinations because they fear it could cause them to lose control of the item to another design activity or lose Quality Assurance capabilities. There is also a military ...more »