Open Dialogue on Improving How to Do Business with the Federal Government 2. Procurement Rules and Practices

Having held a GSA contract for years, I make the following observations/recommendations: 1) There needs to be a mandated response time from GSA COs and buyers. We had a CO that never returned e-mails or calls. Truly never. We finally got transferred to a new officer but it still can take days to get responses. If there were no deadlines, that would be great. The same holds true for buyers who are responsible for ...more »

The FAR needs a top to bottom scrubbing as well as some thought as to how its utility could be improved. Many sections of the FAR were developed years ago or pieced together from predecessor regulations dating back to the 60s when Federal procurement was supply-focused. Other sections of the FAR are a patchwork of concepts that, while "politically correct" at inception, no longer suit the needs of modern procurement and ...more »

Transformation Innovation in IT/Services Acquisition: We must have open communication and collaboration with industry from day 1 of a new (large) procurement. Government publishes OMB 300, Report 15s and program-specific strategy on public website. Hold monthly Industry Days to openly communicate with Industry, verify requirements, get innovative ideas, and utilize digital market research. Utilize non-profits to assist ...more »

A significant challenge in procuring cloud-enabled IT services involves structuring an appropriate method of payment. For something simple, like Infrastructure as a Service, agencies should be able to contract directly with a cloud service provider without having to fund upfront (in effect, pre-paying) for a projected level of service consumption. These types of procurement arrangements are typically fixed price. This ...more »

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 »

IRS and CAGE validation can take 2 weeks for contractors updating their annual registration. The problem is companies doing business with agencies are ineligible from receiving contracts/contract awards until the validation process is complete. The process should be changed for conmpanies renewing their annual registration or adding new NAICS etc. Companies could potentially lose business and bid & proposal cost as ...more »

It seems that FAPIIS and CO’s do not look closely enough at a contractor’’ entire record, and that they look primarily at whether the company has been caught violating the law or cheating workers on federal contracts. This makes no sense. Contractors who cheat workers or who cut corners elsewhere are just as likely to do that on a federal job if it increases their bottom line, and they should not be rewarded with more ...more »

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 »

It’s easier to recognize a great idea, than it is to invent one! Using performance-based acquisition (PBA) and statements of objectives (SOO) allows the government to state it’s desired outcomes or objectives, while asking contractors to propose innovative solutions to meet the government’s need. PBA structures all aspects of an acquisition around the desired outcomes of the government’s requirement and ensures the ...more »

One possible solution to reduce the complexity associated with commercial item acquisition would be to address the burden of providing Commercial Sales Practices ("CSP") information in response to large contract solicitations (e.g. FSS, VA National Contract, DHA E-CAT). While we acknowledge that CSPs may be helpful to enable the determination of fair and reasonable pricing, the nature and type of data requested varies ...more »

Issue: The Relationship between Buyers, Acquirers, and Suppliers is increasingly silo-ed and divisive versus engaged in collaborative problem solving. Recent events and articles have highlighted the need for increased collaboration and alignment between business/IT sponsors, procurement organizations, and suppliers/contracts. PSC’s Commission Report, “From Crisis to Opportunity”, as well as NCMA’s recent article, “Becoming ...more »

Rewrite FAR Part 17.207 for options. Flip the requirement for due diligence to focus on those contracts where the option will NOT be exercised rather than when it will be exercised. Probably 99.99% of options are exercised each fiscal year. This is a huge resource drain on COs and keeps contractors in limbo for no reason. Eliminate this pencil whip exercise so that COs can focus on getting the funding modification correct ...more »