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Regulations (FAR and DFARS)Regulations
Services Acquisition Regulations (FAR and DFARS)
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Picture: ADAM STROUP
  • ADAM STROUP
01/11/2021 8:16 AM

​The Government Accountability Office (GAO) recently released an important new report entitled “GAO-21-171 Information Technology: Federal Agencies Need to Take Urgent Action to Manage Supply Chain Risks.”  This is particularly timely given the December 2020 discovery of a breach of SolarWinds Worldwide LLC’s network-management software Orion, which is widely used by U.S. agencies and companies.

This blog by Bill Kobren will connect you to the report and provides additional blogs on Supply Chain Management Risks.  To go directly to the GAO report select GAO-21-171[NOTE:  you may have to click on the title of this article to access the two links.]

1/11/2021 8:16 AMNo
  
Picture: ADAM STROUP
  • ADAM STROUP
110/23/2020 9:42 AM

It's out!  CON 0150 deployed 16 October 2020.  It will take you about an hour to complete, but it is the latest DoD content available for category managers as well as the workforce procuring services and goods for the DoD.​  The number of continuous learning points will be posted in about a month as we use actual student data to determine CLPs.  Visit the Category Management Community for more detailed information devoted to Category Management!

ADAM STROUP12/14/2020 7:39 AMNo
  
Picture: ADAM STROUP
  • ADAM STROUP
010/9/2020 12:11 PM

First, with the Back to Basics (BtB) memo (also available on the Policy Tab here in the community), things are changing.  I think more seats will become available for our non-acquisition personnel performing services acquisition functions.  ​Last year we had 81 Priority 9s graduate from an ACQ265 (38) or ACQ265V (43)--slightly more once ACQ 265 went virtual.  Currently, for FY21 there are 14 ACQ265Vs in ATRRS and 4 are just about full.  NOTE:  the schedule only goes out to 2QFY21, so I expect to see more offerings added after the new year.

If you are a non-acquisition workforce member, you're a priority 9.  What that means is you will be waitlisted for any of these offerings until 1 month out.  At one month out, if there's a seat available, it's filled from those Priority 9s that are on the waitlist.  It's your seat now--you won't be bumped.  The other trick is to contact DAU and attempt to gain a seat from any no-shows on the first day of class.  Ask if you can get access to the ACQ265 pre-classroom work so you are ready for class on day 1.  On average, I fill one seat per class this way.  So if you are proactive and have some flexibility, you have a much better shot at getting into a class.

Here's my Second thought:  With the BtB and the six functional areas streamlining the required training, more seats are likely to be available when ACQ265 is no longer required (currenly ACQ265 is on a pick list for Logistics and Contracting).  This isn't locked yet, but it's my prediction (Stroup, editor, ACE for Services).  Hopefully we still see contractiong and logistics professionals in ACQ265 as they find a need to learn about services acquisitions. 

Third.  Rules for use of credentials are to be written.  The BtB memo tasks Human Capital Initiatives (HCI) with revising DoDI 5000.66 and a lot of thought needs to go into the policy about use, prioritization, expiration of credentials.  My input on the matter is that re-qualifying ought to be something much more engaging then retaking the current exam (that should keep me busy in the future). You'll find the current rules on the DAU Credentials page

I'd be happy to hear your thoughts!  And a reminder that there exists great training for services acquisition that has no waitlist because it's entirely on line.  ACQ 1650, ACQ 256 (that's the tools course), CLM 006 (soon to be ACQ 0060) (Cost Estimating), all OLTs, had over 2500 Priority 9 grads last FY.  Stop by the training tab here on the ACE for Services home page for more info on DAU Learning Assets.  Happy new fiscal year!  Ad

10/9/2020 12:11 PMNo
  
Picture: ADAM STROUP
  • ADAM STROUP
05/28/2020 8:04 AM

​GAO's Watchblog provides a snapshot of Government-Wide Contracting for FY19 with DoD at the top of the list.  Out of the department's $381.2B in contracts, Services account for $189.7B versus $191.5B for products and Aircraft, fixed wing, leads the list of products bought.  What else can we learn from these data?

Since GAO's 2017 High-Risk Report, their assessment of all five criteria remains unchanged for DoD Contract Management. DoD continues to demonstrate top leadership support for addressing challenges in its (1) acquisition workforce, (2) service acquisitions, and (3) operational contract support (OCS), which is defined as planning for and obtaining supplies, services, and construction from commercial sources in support of joint operations.  GAO noted that DOD continues to take action to meet the demonstrated progress criterion—with additional management attention needed for service acquisition.

Watchblog noted an increase of $20B in FY19 over the previous year; spend on DoD services accounted for a ~$15B increase ($175.0B in FY18).  Within services, the top categories were Professional Engineering/Technical, General Health Care, Logistics Support, Professional:  Other, and Maintenance and Repair of Aircraft Equipment.  That's a lot of Knowledge-Based Services as has traditionally been the case.

To promote small business participation in federal contracting, there is a government-wide goal to award about a quarter of contract dollars to small businesses.  DoD in FY19 awarded $75.7B to small business out of $318.2B, or 23.8%, exceeding the department's goal.  The Office of Small Business Programs tracks DoD's goals over the years on their Goals and Performance page.  You can also find goals for FY2020 posted.

To close, while the data do not reflect spending on COVID-19 response, a Coronavirus page provides blogs on this topic including one on the Military's pandemic response.

5/28/2020 8:04 AMNo
  
Picture: ADAM STROUP
  • ADAM STROUP
05/13/2020 10:34 AM

The recently released, DODIG-2020-079 Report on the Joint Enterprise Defense Infrastructure (JEDI) Cloud Procurement presents the reults of the DoDIG review.

On July 26, 2018, the DoD issued a Request for Proposals to obtain cloud computing services using a single-award Indefinite Delivery/Indefinite Quantity contract. The Request for Proposals stated that the contract would have a maximum value of $10 billion, over a potential 10-year performance period, if the DoD exercised all option periods.  Multiple protests of the solicitation and more recently the award ensued.

I find the section "JEDI Cloud Acquisition Strategy and Key Acquisition Milestones" particulary informative with respect to single award Indefinite Delivery/Indefinite Quantity (ID/IQ) contracts.  The rationale selected by the USD(A&S) was use of a firm fixed price contract type.  This was part of Oracle's protest.  The DoDIG comments on this indicating that "regarding the firm-fixed-price exception under 10 U.S.C. 2304a(d)(3) (2018)" that the U.S. Court of Federal Claims concluded that the term “established” meant “at the time of” entering the contract.  The JEDI Cloud contract left some future requirements open with respect to pricing.

DoDIG's Recommendation 1:  We recommend that the Acting Director for Contract Policy, Defense Pricing and Contracting, consider developing and implementing appropriate policy to require some level of documentation and analysis supporting key acquisition decisions, including any legal reviews and advice, for contracts that exceed the $112 million threshold established by statute.

Feel free to reply to this post to discuss this and other points you find of interest.  Adam Stroup, Editor, ACE for Services

5/13/2020 10:34 AMNo

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Adam Stroup

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Jan
19

Proposed Rules for Operational Contract Support (OCS)
January 19, 2021
The Department of Defense January 7, 2021 issued a proposed rule to revise regulations on operational contract support (OCS) outside the U.S (OCONUS).  See ... Category: Opinions

Sep
10

Cost or Price not a consideration at the Base (Master) Contract level
September 10, 2020
It's here--Section 876 of the 2019 National Defense Authorization Act (NDAA) authority! The “unpriced multiple award contract (MAC)” where costs only matter at each individual task order level. Section...

Jul
16

FSMs Do You Need a Credential?
July 16, 2020
We have a proposed pair of Credentials for the Functional Services Manager (FSM).  Based on the...

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