contractor seeking advice on contract type

The Feds can't just obligate a "bucket of money" and then decide what it's for later. There has to be a requirement for actual work, not anticipated work in order for an obligation to exist. This is required by the Recording Statute. So, unless the GSA IT staff has the authority to obligate funds, someone will have to "bother the contracting officer for every little task order."

If it were that easy to cut the contracting officer out of the process, don't you think everybody would be doing it?

The Feds can't just obligate a "bucket of money" and then decide what it's for later. There has to be a requirement for actual work, not anticipated work in order for an obligation to exist. This is required by the Recording Statute. So, unless the GSA IT staff has the authority to obligate funds, someone will have to "bother the contracting officer for every little task order."

If it were an easy way to cut the contracting officer out of the process, don't you think everybody would be doing it?

Good answer Don Acquisition. But I would add that stating things like, "the GSA IT staff who are managing us do not understand acquisition" is just a tad offensive. I know we're not all brilliant but we darn sure didn't get our warrants for having a pulse either.

Good answer Don Acquisition. But I would add that stating things like, "the GSA IT staff who are managing us do not understand acquisition" is just a tad offensive. I know we're not all brilliant but we darn sure didn't get our warrants for having a pulse either.

How did you get your warrant? Did you have to go before a board? Did you have to take an oral or written exam? Did someone in authority simply decide that you should have it? In my experience--and I see more COs in a year than most people--COs know local policies and procedures, but their knowledge of acquisition is not broad or deep. In some agencies, almost every 1102 has some kind of warrant. I know COs with unlimited warrants who would tell you that they don't know the FAR well.

Great! Now the problem is that the GSA IT staff who are managing us do not understand acquisition, and our own IT staff is not knowledgeable on federal contracts.

Great! So, neither of you knows what you are doing!

What exctly is the criteria for a person in DOD to obtain a warrant?

There isn't any from the government-wide perspective. Some agencies have criteria in terms of training and experience; others do not. A few say a supervisory position means you have an unlimited warrant. I know one agency that gives warrants based upon GS grades for 1102 contract specialist positions- a GS-9 is a warrant with a minimal dollar threshold; a GS-11 is a higher warrant level; a GS-12 still higher, etc.

What exctly is the criteria for a person in DOD to obtain a warrant?

See DFARS 201.603:

201.603 Selection, appointment, and termination of appointment [of contracting officers]:

201.603-2 Selection.

(1) In accordance with 10 U.S.C. 1724, in order to qualify to serve as a contracting officer with authority to award or administer contracts for amounts above the simplified acquisition threshold, a person must?

(i) Have completed all contracting courses required for a contracting officer to serve in the grade in which the employee or member of the armed forces will serve;

(ii) Have at least 2 years experience in a contracting position;

(iii) Have?

(A) Received a baccalaureate degree from an accredited educational institution; and

( Completed at least 24 semester credit hours, or equivalent, of study from an accredited institution of higher education in any of the following disciplines: accounting, business finance, law, contracts, purchasing, economics, industrial management, marketing, quantitative methods, and organization and management; and

(iv) Meet such additional requirements, based on the dollar value and complexity of the contracts awarded or administered in the position, as may be established by the Secretary of Defense.

(2) The qualification requirements in paragraph (1)(iii) of this subsection do not apply to a DoD employee or member of the armed forces who--

(i) On or before September 30, 2000, occupied--

(A) A contracting officer position with authority to award or administer contracts above the simplified acquisition threshold; or

( A position either as an employee in the GS-1102 occupational series or a member of the armed forces in an occupational specialty similar to the GS-1102 series;

(ii) Is in a contingency contracting force; or

(iii) Is an individual appointed to a 3-year developmental position. Information on developmental opportunities is contained in DoD Instruction 5000.66, Operation of the Defense Acquisition, Technology, and Logistics Workforce Education, Training, and Career Development Program.

(3) Waivers to the requirements in paragraph (1) of this subsection may be authorized. Information on waivers is contained in DoD Instruction 5000.66.

To expand on DFAR requirements to ?qualify? for a warrant the following is offered as simply quoting the DFAR, or FAR for that matter as it applies to the civilian agency side, does not do justice to requirements expected of a 1102 for qualification. Here is the DoD standard which is mimicked in the civilian agencies as it relates to OFPP?s standards regarding FAC-C. Ref - http://www.fai.gov/pdfs/fac_contracting_program.pdf

DFAR 201.603-2 (i) ? Completing required courses. The standard expected by most if not all DoD agencies is that a Contracting Officer becomes qualified for a warrant at a certain level only if the individual has qualified, or been waived from certain Defense Acquisition Workforce Improvement Act (DAWIA) standards, by taking a set schedule of courses. Further to maintain the warrant the individual must take at least 80 hours of update training every two years again based on a set schedule of requirements required by DAWIA . Ref - http://uscode.house.gov/download/pls/10C87.txt

Example is the Air Force at AFFARS 5301.603-2(S-90) - ?(a) Individuals selected for contracting officer appointments shall be limited to military personnel in Air Force Specialty Codes (AFSCs) 64PX or 6C0X1 and civilians in the GS-1102 or equivalent local national occupational series possessing an Intermediate (Level II) or Advanced (Level III) Acquisition Professional Development Program (APDP) certification in contracting who occupy a manning authorization listed under these specialty codes, except as otherwise authorized below.?

Following the DFAR and AFFAR trail means that in the Air Force 64PX, 6COX1 and 1102 shall have taken, and passed the following courses ? CON 090, 100, 110, 111, 112, 120, 214, 215, 216, 217, 218 & ACQ 101 and have 2 years of contracting experience before he/she could reach APDP Level II and ?qualify? for a warrant. Ref - http://ww3.safaq.hq.af.mil/career/ and http://icatalog.dau.mil/onlinecatalog/CareerLvl.aspx

Using this example, having experience with several agencies and in light of DAWIA implementing regulations and OFPP FAC-C policy I would doubt seriously that any agency simply issues a warrant based on grade level. Every agency would make the individual first achieve either DAWIA or FAC-C level certification to qualify for the warrant and then and only then review the application of the individual for other qualifying factors particular to the agency prior to issuing the warrant. Example from the civilian side, individuals of the USDA ? Forest Service are not granted a warrant of more than $25,000 for either construction or A-E contracting , regardless of FAC-C level certification, without first taking a specific class in acquisition in these specialty areas. As I have acknowledged above there are waiver allowances that most agencies have but again in my experience most exercise the waiver in rare circumstances.

Bottom line is that discussion in this thread regarding what is needed to be a warranted CO by an 1102 is a perfect example of the misunderstanding and innuendo that is detrimental to the moral of the acquisition workforce. Everyone posting here that considers themselves an expert should know these standards in general and be able to articulate them to an inquiring mind. These standards are the basis for creating and maintaining a qualified workforce. Current requirement is that 1102?s must met a standard to qualify for a warrant. Training is required, passing the classes provided as the training is required, having a certain period of experience is required and having met a positive education requirement is required.

Current requirement is that 1102?s must met a standard to qualify for a warrant. Training is required, passing the classes provided as the training is required, having a certain period of experience is required and having met a positive education requirement is required.

I'm not sure what all of that in the last post was about. I will say this: Training, experience, and meeting a "positive education requirement" is de minimis. It is not enough. Not nearly enough. The notion that passing a DAU class qualifies anyone for anything is laughable. Let's not have any misunderstanding or innuendo. I will say it straight out: Too many unqualified people have received and are receiving warrants. As for the morale of the acquisition workforce, it would be better if CO appointment standards were raised to a truly professional level and periodic requalification were required. It should be at least as hard to become and stay a CO with "unlimited" authority as it is to become and stay an attorney or a certified public accountant. Given the breadth of CO responsibilities, it should be harder.

To argue the current law and policy of the Executive Branch with regard to CO certification is trifle is without merit based the fact that it is in fact policy and law and have achieved results in educating and training the workforce. I would agree the third leg is performing but a system a kin to a State bar exam or a UCPAE is not the end all either. There are lawyers and CPA's out there that are bad performers as well. It takes experience, mentoring and self discipline to become grand at being CO. Effort that will take a lifetime just to be accomplished rather than the snapshot of time exemplified by a test that gives you a banner to hang on your wall whether it be to practice law, be certified as a public accountant or be warranted as a Contracting Officer. Effort that includes separating sensationalism and innuendo from fact for a full understanding of the 1102 series and the requirements that are needed to become a Contracting Officer.

To be clear My post was to point out this exactly in that the discussion in this thread intentionally suggests, from my read, that a prospective CO does not take a exam, does not go before a board, gets a warrant just because they are GS-X , or because one is handed it on a silver platter . Hogwash. A prospective 1102 wanting to be a CO has to take specific effort to qualify for a warrant and then prove they should be issued one. Further they must prove on a two year basis that they should retain the warrant.

I didn't say that any law or regulation is "trifle." So I don't know where you are coming from on that. I said that the current rules are not enough, and they aren't, and there is plenty of merit to that. In any case, there are plenty of trivial laws and regulations.

I also don't know where you're coming from on the exam thing. I did not say that taking an exam would be enough. The bar exam and the CPA exam come after several years of intensive education, education that at a good school is far superior to anything offered or even thought of by DAU. I have written before that there should be a CO academy for qualified candidates, and that the courses should be as rigorous as any at a good graduate school of business. I know that several agencies conduct put CO candidates through oral interviews. I don't know if they rise to the level of "exams." I don't know of any that require CO candidates to take a written exam, but there may be some. Any such orals or written exams are not enough. There should be a common, governmentwide standard, and a high one, since anyone who gets a warrant at one agency is likely to be considered qualified to get one at another agency. And the exam should be rigorous. If no one ever fails such an exam, then the exam is too easy. There should also be a requirement to be able to write analytically and speak extemporaneously.

You said: "My post was to point out this exactly in that the discussion in this thread intentionally suggests, from my read, that a prospective CO does not take a exam, does not go before a board, gets a warrant just because they are GS-X , or because one is handed it on a silver platter." I don't know who said those things. Not me. I asked Crazy KO how he/she got his/her warrant, but never got an answer. I honestly wanted to know. I was not suggesting that he had not been through an oral or written examination. I don't know of any requirement for a CO to "prove" on a two-year basis that they should retain their warrant. What I do know is that if that is true, then the proof does not amount to much, since I see an awful lot of COs who don't know enough and can't do enough.

So, if you're mounting some kind of defense of 1102s, spare me. There are many first-rate people in the workforce, but there are many who are not up to snuff. They are not bad people, and if properly educated and trained many of them would be first rate. The fact is that the system has failed the very best of them. In my experience, morale and effectiveness have always been highest in organizations that demand a lot from their members. Fewer people will qualify to be members of such organizations, but the ones who do are elite and will move the planet for you. At present, the public does not think that the government is competent or trustworthy. Almost no one things well of government contracting. If I could have my way, that would change: COs would be depended upon, respected, and even admired; morale would be high, the quality of the work would be first rate, and the very best candidates would kill to get into the workforce and once in would stay there. I'm not happy with the way things are and I want to change it. My motto: Destroy the status quo and all who defend it.

Of course there are those that would argue on semantics until the sun sets. What Vern did say is this - "Training, experience, and meeting a "positive education requirement" is de minimis" or in other words each is a small or trifle matter. Again hogwash because each of these needs for a 1102 CO is based on law and/or regulation and is required. In fact if I did not have positive education requirements and I wanted to be an 1102 I simply would not be hired as an 1102 to even begin to think about qualifying for a warrant.

There is, by my read, a clear intent to discredit the warranting process in the discussion thread. Agreed warranting is not perfect but I suggest comments in the thread are based on misunderstanding and lack of knowledge of the warranting processes of today. I am simply trying to educate those that read the thread that the requirements of today are not the status quo.

For specifics, DAWIA standards while created in law in 1990 continue to progress through DAU with the latest updates as current as April of 2010. FAC-C came about for the civilian side in 2006 and they too continue to be adjusted by FAI. All are constantly adjusted by agency regulation and/or policy as well. Further there is an absolute requirement for an 1102 CO to accomplish CLPs on a two year basis and prove that they have done so to retain DAWIA or FAC-C certification and therefore retain their warrant. Read the requirements already noted in my previous post, bone up on ACMIS as well, read your own agency policy and regulation regarding warranting. If you are a 1102 - CO you need to, it is your responsibility, and hopefully you will care about it! Care about it enough to educate anyone who would suggest that you simply got handed a warrant!

I am not defending the status quo I am defending new requirements for 1102 CO's that I have already stated and I am defending that the requirements are making inroads to solving the very issues that are raised in this thread. Some of which I am exactly on the same wave length on but clearly others I am not.

I might say that I'm sorry I brought the CO/KO warrant issue into the picture, but I guess it did stimulate some valid arguments about how we get warranted, how we stay warranted, etc., but my intent was to emphasize the originial poster's comment about the GSA IT Managers not knowing acquisition. I should have said this:

"I believe that the poster just offended the GSA IT CORs."

I wonder what that statement will bring.

BTW, I got my warrant the hard way. I cut my teeth at the bottom, serving as a procurement technician, then a buyer, then as a contract specialist, procurement analyst, cost/price expert, and finally, after a good many years of study and training, and experience, I was elevated to the ranks of the warranted few (at that time). And while I agree that some agencies will hang a warrant on you if your "qualified", sometimes it's done by design. I actually worked for an unnamed agency that did so on some "older" folks just to make them work harder. And when they didn't, the supervisor was were able to give them a less than stellar appraisal and out the door they went! Pretty risky if you ask me.

The statutory and regulatory floors for warrant status mean nothing to me. I know the warranting process of several agencies. I meet more COs in the course of a year than most people in our business--many more than the administrator of OFPP, and I spend time with them and get to see what they know and can do.

A "positive education requirement" means little. A degree proves nothing about what a person knows and can do. It just means that he or she attended enough classes and gotten enough passing grades to earn a piece of paper.

DAU training does not prepare one to be a contract specialist, much less a CO. The training is generally of very poor quality.

Experience is a meaningless term without further explanation. It is meaningless to talk about the number of years that a person has worked as an 1102 unless you know what that 1102 did during that time and how well he or she did it.

The warranting process is discredited and I think it should be so. It depends too much on individual office culture and management competence. There should be rigorous governmentwide standards, rigorously applied. Beyond the statutory and regulatory minimums, there should be demanding standards for knowledge and for skill. There should be standards for reasoning ability and for communication skill (speaking and writing).

The best way to judge the warranting process is to judge the people with warrants. Each and every one of you can do that for yourself, assuming that you know enough to do so.

The warranting process cannot be defended on grounds of formal requirements. Formal requirements do not a CO make, unless your standards are low.

In the interest of bringing this protracted discussion to a enlightened conclusion I ask any reader of this discussion thread to post a specific reference to any agency regulation or policy that provides that a 1102 can qualify for a warrant without specific waiver to the DAWIA or FAC-C certification requirements rather than simply quoting anecdotal examples that it can be done and is happening. It may have during the years of the status quo but today it is not happening except in very rare circumstances, if at all.

Further please note previous posts where contradictory statements are offered that provide "The bar exam and the CPA exam come after several years of intensive education, education that at a good school is far superior to anything offered or even thought of by DAU." yet in another it is stated that "A degree proves nothing about what a person knows and can do. It just means that he or she attended enough classes and gotten enough passing grades to earn a piece of paper." I challenge these posts from the perspective that only in very rare circumstances can one pass the bar and become a practicing lawyer without a degree with the rare cases still requiring CLEPs that are equal to a degree, an individual cannot sit for the UCPAE to earn CPA designation without a degree, and an individual cannot become a 1102 and therefore qualify for certification of DAWIA or FAC-C and a subsequent warrant without positive education requirements unless covered by a waiver. Formal requirements do a better CO make and this is a proven fact as supported by other certification programs whether it be the bar, UCPAE, professional engineer ,etc.

I will watch intently to see if any agency regulation/policy is offered that disputes that DAWIA or OFPP FAC-C requirements are necessary for qualification for a warrant by an 1102.

Carl:

Did I say that people are getting warrants without a proper waiver? If so, when did I say it? If not, who did say it? In any case, the DAWIA/FAC-C requirements don't amount to much. To be DAWIA/FAC-C Level III qualified you must (1) have a bachelor's degree with 24 semester units of business classes, (2) have four years of unspecified "experience," and (3) have taken prescribed DAU courses. I don't think that amounts to much.

By comparison, in order to become a lawyer in New York you must qualify to take the bar exam. Here are the qualification requirements: http://www.nybarexam.org/Eligible/Eligibility.htm#A. You must then pass the bar exam. Here is the description of that exam:

The New York section consists of five essay questions and 50 multiple choice questions prepared by the New York Board, and one Multistate Performance Test question, developed by the National Conference of Bar Examiners. The second day of the exam is the MBE section which consists of 200 multiple choice questions. Each day of the examination will consist of a morning session and an afternoon session with a lunch break in between. The examination is given at the same time and date at various testing locations across the state.

Schedule for First Day of the Examination (Tuesday):

In the morning session, which begins at 9:00 A.M. and ends at 12:15 P.M., applicants must complete three essays and the 50 multiple choice questions in three hours and 15 minutes. Although applicants are free to use their time as they choose, the Board estimates an allocation of 40 minutes per essay and 1.5 minutes per multiple choice question.

In the afternoon session, which begins at 1:45 P.M. and ends at 4:45 P.M., applicants must complete the remaining two essay questions and the MPT in three hours. Again, although applicants are free to use their time as they choose, the National Conference of Bar Examiners developed the MPT with the intention that it be used as a 90-minute test. Therefore, the Board recommends that applicants allocate 90 minutes to the MPT and 45 minutes to each essay.

Schedule for Second Day of the Examination ? MBE (Wednesday):

The second day of the examination is the Multistate Bar Examination. The Multistate Bar Examination (MBE) is a six-hour, two-hundred question multiple-choice examination covering contracts, torts, constitutional law, criminal law, evidence, and real property. The examination is divided into two periods of three hours each, one in the morning [9:00am to 12:00pm] and one in the afternoon [1:30pm to 4:30pm], with 100 questions in each period.

http://www.nybarexam.org/TheBar/TheBar.htm#descrip

By contrast, you can be DAWAI/FAC-C qualified to have "unlimited" authority to do one of the most complicated jobs in the world and to obligate the government to pay very large sums without having passed any kind of exam. You don't have to prove that you know the rules and can do the job in order to be eligible. Bottom line: the DAWIA/FAC-C requirements don't amount to much. Are they better than nothing? I would not say so. Personally, I don't think the 24 units of business classes are necessary.

Do formal requirements a better CO make? Yes, if they are rigorous. I don't consider DAWIA/FAC-C to be sufficiently rigorous.

I will watch intently to see if any agency regulation/policy is offered that disputes that DAWIA or OFPP FAC-C requirements are necessary for qualification for a warrant by an 1102.

I assume DAWIA/FAC-C is a given for just about everyone in the 1102 series regardless of whether they have a warrant or not. That's not really a factor in my mind.

Edit: Just saw Vern's post above. I was slow in reponding.

At a minimum, in order to qualify for an unlimited warrant (i.e., to be a "super" contracting officer), a candidate should be tested for knowledge of the following:

Organization of the federal government

Organization of the laws and regulations

Fundamentals of economics

Institutional structure of the U.S. economy

U.S. industrial structure

Fundamental business concepts and practices

General business law

Federal appropriation processes and law

Federal Acquisition Regulation (basic knowledge and ability to interpret and apply)

Other sources of acquisition rules

Key acquisition processes

Acquisition roles and responsibilities

Specific procedural rules (i.e., incentive contract design, source selection, contract pricing, contract funding, contract modification, claim management, etc.), including basic knowledge of relevant case law

The test should be developed by a joint government/industry committee, and they should develop more than one version--at least four. It should be a combination of question/answer and essay, much like a bar exam. The test should be administered on a quarterly basis at different locations in the U.S. and overseas. Anyone who fails the test by more than a certain margin should be required to wait one year before taking it again. The test should be open to both current and prospective government employees.

CO candidates should also be tested for the ability to write and speak. Candidates should be required to submit a 5,000 word essay on a contracting topic selected by the appointment authority. The paper should be graded, and qualified candidates should then be required to answer questions about their paper before an oral board, which will grade the candidates for reasoning ability, knowledge, judgment, and general oral communications skill.

All grading standards should be established by OFPP and apply government-wide.

In addition, CO candidates, like contractors, should be qualified and evaluated on the basis of breadth and depth of relevant experience and past performance. Minimum experience requirements would not be stated in terms of a number of "years," but in terms of the number and nature of contracting projects worked.

Candidates should be permitted to qualify for an unlimited warrant before a specific position becomes available. Once qualified, they should be eligible for a position in any agency, but still be subject to competitive selection procedures, including personnel interviews. If they do not get a position within two years of qualification, they should be required to qualify again.

These would be requirements only for unlimited warrants. I would impose lesser requirements on candidates for dollar-limited warrants to conduct procurements using other than simplified acquisition procedures.

OK, suppose there were some "Procurement/Acquisition/Contracting" schools at some prestigious universities around the country, like "Law School" or "Med school", and high schools around the country were pushing the best and brightest business students to apply. Now let's add to this scenario that the Government takes it's existing warranted 1102 workforce and imposes new standards, much like the ones you suggest, and the result is that 75% of them (just to give it a number) become disqualified. Now what? Until we get the first wave of graduates from our new school, the remaining 25% who do possess the ability to pass the rigorous standards become overworked, (are not paid well, unless of course the field itself becomes recognized as worthy of its own elevated pay scale) how do you deal with that? Phase in each rigorous standard? How much time would this Utopian environment take to build? We are already dealing with a large gap in the workforce population.

While I agree that a lot of 1102s are handed their warrants on a silver platter, I believe that most of them really take their jobs seriously. There isn't a single contract written that doesn't have a mistake in it, I don't care who wrote it. There isn't a single 1102 out there who hasn't made a error in judgment. There isn't a single lawyer out there who hasn't made a mistake either, or a CPA, or a doctor, or a scientist, or a truck driver, or a janitor.

Perhaps the government would be better served if the 1102 series could be broken up into more defined specialties. Given the ever growing heap of responsibilities that an 1102 is tasked with, it may make a lot of sense to accept the fact that a cradle to grave work description is just too much for one person.

Another thought: If we finally came to this new and improved contracting officer with some nice title before or after their name, would that cut down the gigantic amount of procurement oversight we deal with? I would think that since we have such low standards for the warranting process that it correlates to the massive amount of errors creating the oversight. So, wouldn't we be reversing then the whole game? I mean, if we had this new and improved KO, we surely could trust that they would then do the overseeing in a way that could eliminate some of it. No?

I agree that implementation would be a challenge, but so was going to the moon, and we did that successfully. So the challenge is not unmanageable. Keep in mind that my post applies only to COs with unlimited warrants. How many of those do we really need? In any case, I have written before that we need to restructure the contracting workforce, and any new policy about CO appointments should be part of a comprehensive program of workforce reform.

The issue in not whether COs take their jobs seriously. I think that the overwhelming majority do and that they work very hard. That is not the problem. The problem is whether they are sufficiently well qualified, educated, and trained. I also agree that there will always be mistakes, but a more qualified workforce would, in my judgment, make fewer of them. However, the problem is not simple mistakes. The problem is bigger than that. For example, many of our problems today can be traced to an excessively complex, time-consuming, and resource-intensive source selection process. I believe that we cannot fix that problem with the COs that we have now. They simply don't know enough or have enough prestige to fix it.

As for oversight--no, I don't think my program would reduce oversight. This is government we're talking about and government needs a lot of oversight. Why should anyone in a democracy want reduced oversight? I didn't trust the government when I worked for the government. Think Department of the Interior, Minerals Management Service. Oversight is not the problem. The problem is what oversight finds. I think all the whining about oversight is just that: whining. Anyone who can't stand oversight should leave government and go to work for a privately held (unlisted, unquoted, close corporation, private corporation) company. Of course, if you work for one of those outfits they fire your a-- if you don't know what you're doing, and there ain't no appeals.

And, oh, by the way, as OFPP administrator I would try to establish "acquisition academies" at four universities with schools of business and public adminstration in four regions of the U.S. The classroom program would be two years in length and include summer internships doing work other than simplified acquisitions or routine orders against existing contracts. I would seek the elimination of FAI and DAU. I would give scholarships to qualified applicants in return for a binding commitment to work for the government for three years after graduation. The program would not be run or managed by private training contractors.

Well those are all great ideas but none of them are mentioned in the DAR Interim Report (3-4-2010) Part III, http://armedservices.house.gov/pdfs/DARPan...terim030410.pdf. There is some suggestion that the re-certification process be more stringent, but no mention of KO warrant levels congruent with education, experience, etc. Why is that since 1990 and the DAWIA legislation, all this talk of improving and reforming the acquisition workforce, have we only gotten to this point? Which is nowhere close to where it should be.

Well those are all great ideas but none of them are mentioned in the DAR Interim Report (3-4-2010) Part III, http://armedservices.house.gov/pdfs/DARPan...terim030410.pdf. There is some suggestion that the re-certification process be more stringent, but no mention of KO warrant levels congruent with education, experience, etc. Why is that since 1990 and the DAWIA legislation, all this talk of improving and reforming the acquisition workforce, have we only gotten to this point? Which is nowhere close to where it should be.

Primarily, a lack of emphasis and leadership. Congress and the congressional staffs are clueless. We haven't had a game-changing OFPP administrator since Kelman left, and there is no leadership within the agencies. There is no real sense of professionalism among contracting personnel, so they haven't acted on their own behalf. The executive branch has been pre-occupied with wars, terrorism, health care, economic woes, and now environmental catastrophe--so acquisition/contracting, for all the yakkity-yak to the contrary, is not a priority.

My posts reflect my ideals and dreams. There is little chance of seeing them realized.

I am "new" having started December 2005. My command was pretty good at moving me around so I got lots of different experience. My experience with CO's has been a few good and mostly really bad. The good ones knew the FAR and DFARS applied them, showed me how to apply them, and when I was done building a solicitation, modification, or award, I was very sure I was correct before I sent it for review (I was painfully slow but am much faster now).

I have had several CO's who don't know how to use any of the contracting software (PADDS,PD2, etc) and their advice on building a requirement is to "find the last contract we had for this item and copy it". Most of the "bad" CO's were highschool graduates that got grandfathered, but I have seen college grads CO's that were the same. The bad ones couldn't determine an acquisition strategy, run a acquisition planning meeting, or have any sense of reason. For example I was given a Performance Spec for a new system that had gross errors in spelling, grammar, and even contradicted itself on technical requirements. I was told not to question it and just put it in the Solicitation. I almost got put through the wringer because I decided to ask the Program Engineer about it in a meeting. He said he knew there was problems with it and that is why he wanted us to help him find the problems since his team had seen it so many times they couldn't see the mistakes any more. I was allowed to make the changes, but the PCO took all the work away and gave me the next job. As "punishment" I spent 6 months doing the same $600 commercial buy over and over again because the PCO couldn't figure out the best method, I wanted to just get a few oral quotes and do a micro purchase, but we ended up doing a formal RFP and DFAS billing.

Vern is right, the sandards need to be revised. The old had PCO's that encumber good possitions while some of my more briliant peers have no upward mobility is very demoralizing. I don't think education is per-se the ticket either. I have known people to skate through a degree program and get almost nothing out of it, and I have known high school grads that have better reasoning ability than most accounting, business, or economics majors. In working on my masters, I have people look down on my Bachelors' Degree, but honestly, DeVry's Bachelors Degree courses were much tougher than the Elite Midwestern Catholic College I started my Masters at. I soon figured out that the Army just wanted paper anyway. I am at an online self paced program now, with much less busy work and a faster completion. I learned more about real business by working than I ever learned in college.

thomas.rutherford, that's a very sad story. But it is exactly that kind of CO to learn "how not to be" when you do become a CO yourself. And vice versa for the good ones. I am a strong advocate of getting to know your customer. The customer generates the need, you support them by producing the right instrument on which to achieve their need. I always tell my people that there are two top priorities and they take on equal weight...no matter what. Support the customer and produce a product that you're proud of because it goes out the door for the world to see. And oh yea...don't be afraid to ask questions. Keep up the good work!

I would seek the elimination of FAI and DAU.

Does your plan consider how to deal with displaced DAU employees?

Well, they're acquisition experts, right? And DOD acquisition offices are short-handed, right? Wouldn't you think they'll have to fight off suitors? I know a couple of DOD offices that would kill to get you.

I agree that implementation would be a challenge, but so was going to the moon, and we did that successfully.

Going to the moon is easier than trying to implement this great idea. I can imagine the pushback from employee unions, the greivances from those not picked for unlimited warrants ("super COs"), the arguments about higher grades/higher pay for COs with unlimited warrants, people wanting to study on work time or work assignments not done timely because of study demands, etc.

Yes, I agree. We live in the Epoch of Mediocrity, in the Days of the Second Rate.

Well, they're acquisition experts, right? And DOD acquisition offices are short-handed, right? Wouldn't you think they'll have to fight off suitors? I know a couple of DOD offices that would kill to get you.

That sounds like I would have to do real work, which isn't for me. I'll have to oppose that portion of your proposal in my own self-interest.

Vern ? Slow response on my part yet here is my re-entry to the discussion. The discussion has moved on however I feel compelled to address your specific response to me.

Reference Your Post 958 -

You did not say the folks were getting warrants without waiver but you and no one else did not say they were. I would offer that posters were either purposely implying that warrants were being issued without waiver to support arguments or they were stating that the warrants were being issued without proper certification or waiver because they flat do not know what the processes for warrant issuance are. To me the latter supports exactly a point that you make on many occasions that some 1102?s of today are woefully not prepared to participate in their career field. However in my experience of TODAY where I work with several CO?s on a daily basis most do know the DAWIA/FAC-C and warrant qualification requirements. Some do not, which I believe is exemplified by some of the posts to this thread and as I pointed out for a 1102 to not know the DAWIA/FAC-C certification requirements and the related warrant qualification process and requirements of the their individual agency, whether one likes the red tape of the process or believes that it is not representative of a good measure of qualification, is in my view unacceptable. At the expense of repeating myself the certification and qualification requirements are not de minimis they are required.

Next to your reference to the New York State eligibility standards. I accept your facts but not your attempt to detract and avoid my stated facts, You cannot dispute them so instead you want to take the conversation another direction to support and further your ideas. Fine, but the fact that I presented was that only ?in very rare circumstances can one pass the bar and become a practicing lawyer without a degree with the rare cases still requiring CLEPs that are equal to a degree?. While you offer one State?s requirement in the context of this thread it is a fact that every State requirement for sitting for the bar is different. So again the New York reference is not material to the discussion. I stand on the statement I made.

You then state that ?By contrast, you can be DAWAI/FAC-C qualified to have "unlimited" authority to do one of the most complicated jobs in the world and to obligate the government to pay very large sums without having passed any kind of exam.? Patently wrong. To obtain an unlimited warrant in many agency?s means that one shall have ?passed? exams to obtain a Bachelors Degree and must show satisfactory completion of the required combination of CON courses to be DAWIA/FAC-C certified at Level III. Completion of a CON course in many cases means one must ?pass? that course exam, Noted too is that many CON courses are accredited as being equal to college level courses and is the purpose that they include exams. Granted there is not one big exam as required for the bar or CPA but you must pass ?any kind of an exam?.

Moving to the sum of the other posts regarding your preferred alternative all ideas are palatable save one, the writing of a 5,000 word essay. It is an unnecessary entry into a subjective evaluation that does nothing but to further the personal biases of an individual or group of folks who would grade the exam. You and I have been down this path before of sorts in past discussions. I know by personal experience that I could submit an essay to one evaluator for grading and receive a passing grade and take it to another and not. I know because I lived this exact experience in college. Further the essay is duplication of the learning experience rather than an objective test of knowledge.

And to Don ? It would be a loss if you did not seek to transfer to one of the acquisition academies.

Carl,

I have made my positions clear. I am on record. I think the DAWIA/FAC-C standards are contemptibly inadequate. Passing tests in CON classes comes nowhere near what I would require by way of professional examination. (I can't believe you even brought that up.) In light of the clarity of my position, I see no reason to argue with you about who said what. Given the depth of our disagreements, I see no reason to address the palatability to you of my ideas. To me, you are defending the status quo that I despise, and "despise" is not too strong a word for how I feel about it. To continue a discussion of professional standards in the mode that you are pursuing would be like discussing intergalactic space travel with a 14th century bricklayer. As you say, the discussion has moved on. I see no reason to go backward.

If I see you at the Roundup, I'll buy you a beer, but we won't talk contracting.

Vern

Vern - If you are in fact coming use the usual methods to get my number so I can show you around. You are on for the beer, which I understand is your first preference even though around here it is Pendleton. Your critic of the city's new and first brew pub ever would be more than welcome. And we will be sticking with the code of the west with regard to hospitality, it will always be my treat!

Agreed no contracting!

Carl

Just to comment on the DAU classes which I (and two of my peers) recently finished. We took the classes at the same time, worked through any and all problems, and discussed in depth most of the questions. However we quickly learned that to pass the test you just had to save the entire course as a pdf and use the search function to find the answer. There were a few ?trick? questions but with multiple attempts given to pass the test it was never an issue.

One of my final college classes was done online. We had to read, make weekly intelligent posts (as judged by the professor AND peers), respond to multiple posts per week, take online quizzes, and submit papers. It was as academically challenging as any brick and mortar class I attended. Why can't DAU online classes be held to the same standard?

Hi guys, I am the original poster and surprised to come back to the WIFCON forum and see so many responses! It is great to see that we have a mix of all kinds of individuals - visionaries, veteran experts, hungry up-and-comers, etc. It is great to have a forum where people can have a civil discourse and agree to disagree without it devolving into name calling like so many industry forums tend to.

I did not mean to upset or disparage any contracting folks. I think the problem is with the Customer and myself (Vendor) in that we don't know who to contact. The GSA is vast and different regions/departments *seem* to be specialize in IT acquisition and others specialize in XYZ. I really have no idea what I am talking about, that is why I use the word seem. I am a computer programmer/business owner. Because of my experience I consider it a miracle that we've made it to this point and have some large contracts.

Could anybody begin to nudge me in the right direction? Who is the kind of person/consultant I should hire? What would the terms I should google for? 80% of what has been stated in this thread goes straight over my head. Am I on the wrong forum?

To reiterate, what I am looking for is an expert who can talk with me and our End Customers in plain English. I will tell them "Hey, we have identified some IT products/services that our end user at GSA is interested in acquiring from us. We have an 8a SDB designation but they need about $50m in services and products and that is over the $3.5m threshold that our current contracts with them are. Blah blah". The expert will reply "Ok, from everything you told me so far, I suggest we meet together with the end user at GSA and we can show them two options on how to approach the contracting folks and get this awarded. For example, we could try to get a BPA setup, or maybe a Limited Sources competition. Blah blah. I recommend use GSA Region X office for this."

My end goal is to reduce the lengthy discussions that go on between end users and the contracting staff as they try to figure out this and that. If we can arm our End User with valuable information then it helps everybody out!

I know that many of my peers rely on their Federal Sales people to try to help the End Users navigate these treacherous waters. I would rather find a specialized expert to help us out.

We have a potentially $50m project at DHS on our long term horizon that we also need help with.

Please send me a Private Message if you know of anybody who we can hire for this.

Thank You!

Hi guys, I am the original poster and surprised to come back to the WIFCON forum and see so many responses! It is great to see that we have a mix of all kinds of individuals - visionaries, veteran experts, hungry up-and-comers, etc. It is great to have a forum where people can have a civil discourse and agree to disagree without it devolving into name calling like so many industry forums tend to.

I did not mean to upset or disparage any contracting folks. I think the problem is with the Customer and myself (Vendor) in that we don't know who to contact. The GSA is vast and different regions/departments *seem* to be specialize in IT acquisition and others specialize in XYZ. I really have no idea what I am talking about, that is why I use the word seem. I am a computer programmer/business owner. Because of my experience I consider it a miracle that we've made it to this point and have some large contracts.

Could anybody begin to nudge me in the right direction? Who is the kind of person/consultant I should hire? What would the terms I should google for? 80% of what has been stated in this thread goes straight over my head. Am I on the wrong forum?

To reiterate, what I am looking for is an expert who can talk with me and our End Customers in plain English. I will tell them "Hey, we have identified some IT products/services that our end user at GSA is interested in acquiring from us. We have an 8a SDB designation but they need about $50m in services and products and that is over the $3.5m threshold that our current contracts with them are. Blah blah". The expert will reply "Ok, from everything you told me so far, I suggest we meet together with the end user at GSA and we can show them two options on how to approach the contracting folks and get this awarded. For example, we could try to get a BPA setup, or maybe a Limited Sources competition. Blah blah. I recommend use GSA Region X office for this."

My end goal is to reduce the lengthy discussions that go on between end users and the contracting staff as they try to figure out this and that. If we can arm our End User with valuable information then it helps everybody out!

I know that many of my peers rely on their Federal Sales people to try to help the End Users navigate these treacherous waters. I would rather find a specialized expert to help us out.

We have a potentially $50m project at DHS on our long term horizon that we also need help with.

Please send me a Private Message if you know of anybody who we can hire for this.

Thank You!

There are many many many firms out there looking for you! I know of several that would gladly take you by the hand and get you through these processes. I'm not sure that if I mention any here in this forum that it would be appropriate. Can anyone out there give me guidance on that issue first?

We are an 8a SDB company serving the Federal Government. We have a GSA Schedule (70). Our schedule contains approximately 30 labor categories.

The GSA in 4/2009 awarded us a FFP contract with ceiling of $3.5m and have spent $2m to date on this contract. They loved our performance and indicated they want to give us more work. In 2/2010 we were awarded a new TM contract with ceiling of 3.5m. Our performance has been stellar and they have again indicated they want to give us more projects!

Great! Now the problem is that the GSA IT staff who are managing us do not understand acquisition, and our own IT staff is not knowledgeable on federal contracts. The GSA IT staff has many different projects of all different sizes and scopes that are looming on the horizon and we want to work with them to help complete these different projects. We are searching for a way to have a bucket of money ($50 million) obligated and they can easily write task orders and have us rapidly complete the task orders without having to bother the contracting officers for every single project/task. Time is of the essence for us to be assigned projects and have them completed. We love to work fast and get things done fast. Surprised!?

Can anybody advise what the best course of action is? What contract type? How to make it sole source? We are searching for a professional consultant to help guide us (and the GSA IT staff).

Thanks!

As a taxpayer and a contracting officer, this email from this contractor offends me. There is nothing wrong with making a buck; I am all for it!!.

It's the description of dumping of a "bucket" of taxpayer money in apparent violation of bona fide needs rule that disgusts me.

As a taxpayer and a contracting officer, this email from this contractor offends me. There is nothing wrong with making a buck; I am all for it!!.

It's the description of dumping of a "bucket" of taxpayer money in apparent violation of bona fide needs rule that disgusts me.

As I was trying to state from the beginning I don't know what I am doing, I am a PWIC who is trying to hire a PersonWithAClue to help educate me, my team, and our potential customers. My point about the bucket of money should probably have been stated "obligate funds" and it should have been stated "we have identified 50m worth of work, we are not sure how verbose the SOW needs to be for this work, we'd like to have the flexibility to have the government assign tasks easily". Similar to how 8A Stars works. Again, sorry for my writing, I am still trying to understand how everything works on a realistic level.

Mucho Gracias to all those who've helped me to date!

As I was trying to state from the beginning I don't know what I am doing, I am a PWIC who is trying to hire a PersonWithAClue to help educate me, my team, and our potential customers. My point about the bucket of money should probably have been stated "obligate funds" and it should have been stated "we have identified 50m worth of work, we are not sure how verbose the SOW needs to be for this work, we'd like to have the flexibility to have the government assign tasks easily". Similar to how 8A Stars works. Again, sorry for my writing, I am still trying to understand how everything works on a realistic level.

Mucho Gracias to all those who've helped me to date!

ServingTheFeds,

Your questions about sole sourcing and establishing a bucket of money run counter to what most of us preach about. A good many of us here are Contracting Officers or former Contracting Officers and our jobs are to promote competition and get the best possible business arrangements for the government. So that's why you haven't received much help.

What you need your program office to do is sit down with their Contracting Officer and work out a strategy. It sounds like they have a long term requirement and need flexibility in approaching the work that needs done. What makes sense is conducting a competitive action to establish a single or multiple Blanket Purchase Agreement (BPA) against a Group 70 GSA Schedule contract. They can compete the action using a broadly defined Statement of Work for the overall need. The selection criteria can be corporate qualifications, experience, past performance, and price. Pricing consists of offerors proposing against a defined level of effort.

Once the BPA is awarded, individual needs are set out in a Statement of Work and the BPA holder proposes against it. Then the details get worked out and a task order gets issused for that descret piece. However this process only allows money to be obligated against the individual needs and not the full amount upfront.

Serving ? In this particular instance the opportunity to leverage your 8(a) status or your Schedule Contractor status provides limited opportunities but there are some.

With regard to approaching the work as an 8(a) set aside with the agency the following is offered.

The identified need is $50 million, and even though you have indicated it covers several projects, it sounds as if could be procured in total as well. Therefore as a standalone 8(a) project the agency would be required to compete among 8(a) firms if offered to and accepted by the 8(a) Program. If the projects can in fact be separated out those that fall below the competition requirements of the 8(a) Program (See FAR 19.805) you could request separate sole source matches for each project, while those over the competitive threshold would need to be, again, competed among 8(a) firms. Whether all the projects fall within the same scope or not is a determination left to the Agency.

Note that 8(a) Program requirements regarding competitive mix your firm should be achieving would have to be compared to the extent of projects you are hoping to be matched with. Further, consideration should also be given to FAR 19.804-4.

From the view of your Schedule status Former Fed has offered the idea of BPA?s. In considering this idea or even others under the Schedule Program your status as an 8(a) offers you no opportunity other than agencies are encouraged to include one disadvantaged business in the mix of selected Schedule contractors to received quotes from. Simply for the purposes of Schedule 70 you are one of the thousands of contractors that an agency should consider in selecting the minimum required to solicit quotes from per GSA's guidelines on ordering from schedules found here - http://www.gsa.gov/Portal/gsa/ep/contentVi...tentId=8126#bpa . Whether looked at as opportunity or not, at least Schedule competition provides the opportunity for limited competition as compared to a full and open or full and open after exclusion of sources (FAR Part 6).

Vern...I think we got "bleeped."