Back-to-Basics (BtB)

I think that it's an improvement in that DAU's 200- and 300- level courses will no longer be required for certification. The memo states that mandatory training hours went down from 650 to 200. To that I say "Great, now let's make it zero."

I still like the way the Actuarial profession does it better:

@Jamaal Valentine

Jamaal Valentine said:

What are your thoughts on the changes, specifically adopting a single level of certification with foundational training and an examination?

The key to understanding the changes is in a single sentence in the September 2, 2020, "Back to Basics" (BtB) memo signed by former Under Secretary of Defense (Acquisition & Sustainment) Ellen Lord:

Quote

To support the NDS [National Defense Strategy], it is imperative that we pivot from the past broad workforce focus and get "Back to Basics" (BtB) by streamlining our function area framework and prioritizing limited training resources for the Defense Acquisition Workforce (AWF) who develop, acquire, and sustain operational capability.

Translation: We give up.

John Tenaglia's February 2, 2021 memo, which announced the "restructuring" of the 1102 certification program, should be understood as acknowledging that DOD has failed at developing competency among its 1102s and lacks the resources and the will to make another serious attempt. So DOD will now "certify" that when a person has completed four courses and taken an exam he or she is ready to do whatever he or she is paid to do as a contract specialist. That's not to say that the old program was worth much, with its Levels I, II, and III and myriad half-baked DAU training courses, but it seemed ambitious.

I have seen nothing about improving OJT, probably because it is too hard to do.

Of course, Ellen Lord is gone. DOD will have a new USD(A&S) soon, and "Back-to-Basics" will likely be forgotten or allowed to languish. Who knows what new policies will soon be slouching toward Bethlehem.

If you are an 1102, and if you want to learn and develop as a practitioner, as I suspect most do, you must educate and train yourself. Don't count on your employer.

Vern Edwards said:

So DOD will now "certify" that when a person has completed four courses and taken an exam he or she is ready to do whatever he or she is paid to do as a contract specialist. That's not to say that the old program was worth much, with its Levels I, II, and III and myriad half-baked DAU training courses, but it seemed ambitious.

Having been through the DAWIA training courses through LEVEL III certification for Contracting, I wouldn’t argue about the quality of much of the training course material and instruction and agree that it was ambitious.

Fortunately, I had over 15-18 years previous of experience and education/training within my agency at the time and had reading and other training resources as well as having some teaching duties myself. I just needed the DAWIA training for the certification. I admit that it was simply necessary credentialism. 

Most of the DAWIA courses I took were in-person, live classroom.

Vern Edwards said:

If you are an 1102, and if you want to learn and develop as a practitioner, as I suspect most do, you must educate and train yourself. Don't count on your employer.

Absolutely. Also, please encourage/beg/demand that your employer subscribe to various periodicals and journals, such as the “Nash and Cibinic Report”, “Briefing Papers”, etc.

Keep up to date with the GAO protests, Boards of Appeals decisions and Court Decision caselaw. Bob Antonio does an excellent job of listing and linking many of these at WIFCON. 

If your organization won’t buy reference books, purchase the excellent books that have been written and updated from the George Washington University,  Government Contracts Program

https://law.gwu.libguides.com/c.php?g=187806&p=1240802.

I can guarantee that, if you negotiate contracts and/or administer contracts and/or evaluate and negotiate mods,  claims,  terminations and other contract actions and/or supervise and/or have oversight duties of others, the value of the knowledge gained from these resources will greatly exceed their cost.

As most here know, I work at a contractor, not in the government. My interaction with contracting officers, contracting specialists, cost monitors, and government contract auditors is from the receiving end; I may be biased.

I see a lot of hard-working people struggling to do the right thing within a broken acquisition system. There are multiple levels of review, and it seems the higher up one goes, the less knowledgeable the reviewer is. Why even have reviews/approvals if the people don't know what they are reviewing? Anyway ...

I also see experienced, trained, people who don't know what they are doing. They've been to training; they have their DAWIA Level x Certification. They have years of experience. Yet they do not know what they are doing. They do not understand the clauses in their contract. They do not understand how to write an unambiguous SOW. They don't understand the basics of cost-reimbursement contracting. That tells me that the training system is as broken as the acquisition system is.

Vern posted above that everybody should take responsibility for their own training and development. I think that's absolutely correct, not only within Federal acquisition, but also pretty much anywhere. Go to the office and grab a book from the bookshelf and then read it. One chapter a night. Or even one chapter a week. Just read it. Think about what you don't know, or what you want to know more about, and then follow your curiosity. My 30-year career in this business started because I was an bean-counter who wanted to learn how government contracts worked. That led to night school, one class at at time. That led to external training seminars, which led me to the books from which the instructors were teaching.

One of my personal disappointments is that I have three bookshelves in my office filled with reference books, and nobody ever asks to borrow one. Ever. And I have a staff of 20. Do they think those books are just there for decoration? NO. I have read most of them. And they could (and should) do so as well. *Sigh*

Federal contracting, like many professions, starts off with a common basis, and quickly branches into specialization.   The certification process Levels I, II, III are very general, and don't account for specialization (aka, 'reality'), and therefore I don't think they are particularly useful. 

There are other better ways of quantifying levels and types of expertise and experience.  Don Mansfield's take ('performance based certs') is a good one.  I also find inspiration in software/IT world, where there are many types of certs across domains and expertise.  Some IT certs are niche, some are broad.  Some are basically evidence of 'I am not a total idiot' while others are really, really difficult, prestigious, and valuable ( check out 'AWS Certified Solutions Architect').

On 2/19/2021 at 3:34 AM, Vern Edwards said:

I have seen nothing about improving OJT, probably because it is too hard to do.

Providing good OJT is one of my main concerns. Outside of the need for just-in-time or specialized training, I prefer learning “the basics” through a linear curriculum that builds on previous learning and follows a logical sequence of government contracting events and activities. I want to create OJT that is structured, repeatable, and can be delivered virtually...A lot of my offices are geographically separated.

I remember you writing about starting with FAR Part 7 and FAR Part 2 as a good overview of government contracting. Do you have any recommendations on how I can create, organize, and deliver OJT? Do you have any recommended OJT? I have a decent budget and time.

On 2/19/2021 at 5:23 AM, joel hoffman said:

Absolutely. Also, please encourage/beg/demand that your employer subscribe to various periodicals and journals, such as the “Nash and Cibinic Report”, “Briefing Papers”, etc.

Keep up to date with the GAO protests, Boards of Appeals decisions and Court Decision caselaw. Bob Antonio does an excellent job of listing and linking many of these at WIFCON. 

If your organization won’t buy reference books, purchase the excellent books that have been written and updated from the George Washington University,  Government Contracts Program

https://law.gwu.libguides.com/c.php?g=187806&p=1240802.

I can guarantee that, if you negotiate contracts and/or administer contracts and/or evaluate and negotiate mods,  claims,  terminations and other contract actions and/or supervise and/or have oversight duties of others, the value of the knowledge gained from these resources will greatly exceed their cost.

Agreed. I think it will always be the individual’s ultimate responsibility. I just need to make sure I create a respectable training environment in the office that matches my beliefs. Thanks, @joel hoffman.

I started as an Army intern knowing nothing about the field.  Training consisted of three mandatory off-site courses (160 hours basic at Ft Lee, 120 hours cost/price analysis and negotiation techniques at navy Crystal City and 120 hours contract adm at Wright Pat).  We stayed in hotels and had lots of reading and assignments off hours. Negotiations involved lots of mock sessions.  Starting the field fresh, I learned a lot without the baggage of thinking I already knew the subjects.  Much of that education still remains in my head.

I was also fortunate to be assigned at a major buying command during that period with lots of challenging work.  I even was a witness at an ASBCA hearing.  My first duty station at that was a major R&D office and all my learning was through OJT.

After that I worked at numerous agencies and was exposed to many good things and also seeing how things were done improperly.  But I learned as much seeing how things shouldn’t be done thinking back afterwards.

As far as other training classes, the only one outside the three I mentioned really helpful was Contract Law taught by a GAO attorney.  He used lots of case studies based on actual GAO decisions.  Every other course I had (and that includes everything required to get Level III certification) was mostly a waste of time.

There is nothing like OJT providing it’s done properly.  The other beneficial thing is rotating through lots of offices and picking up best practices.  Every 1102 should have critical performance assessments done by someone senior and knowledgable and given performance improvement plans.  That includes rotational assignments.

@Jamaal Valentine I'll call you privately next week.

formerfed said:

There is nothing like OJT providing it’s done properly.  The other beneficial thing is rotating through lots of offices and picking up best practices.  Every 1102 should have critical performance assessments done by someone senior and knowledgable and given performance improvement plans.  That includes rotational assignments.

True, but only up to a point. "Done properly" is a big proviso. You're just as likely to pick up bad practices through OJT. It all depends on who is doing the OJTing.

"Senior" and "knowledgable" don't necessarily go hand-in-hand.

Direct to the discussion about OJT only a snippet of your intentions are visible in this thread.   That said I might be putting forth a thought that you have already considered but here you go anyway.

Consider a Mentor Element - More specifically put the ability and responsibility on the mentee to reach out.  And engage willing and committed mentors   I probably do not have a great handle on the new world of virtual but from my view the ability for me to make decisions on who, when and with regard to what I could do in reaching out for knowledge with regard to "mentors" and go to them was very valuable to me.   In the days when funds were available being able to go to my supervisor who was unimpeded by fiscal constraints and embraced OJT, as you seem to be, was big.   As to OJT I am not just talking about the work stuff I am talking about the ability to have the leeway to decide participation in professional organizations and events, walking the ground with program people on an anticipated project (I helped a survey crew layout a dam site), given the opportunity to be an inspector and COR on large construction projects, and participate (mostly observe) in management level meetings.   It was the time when saying "What do you think?" to the supervisor and his/her answer was "Yes you can."  Best I can do in short order to offer  an ideal that was very beneficial to me, it was personalized!  I created my success!

I agree with Carl about the utility of mentors. But my idea of a mentor is someone who provides sage advice, not direction or supervision. There is  nothing worse to my kind of mentor than a nightmare mentee who shows up several times a day wanting to know what to do next.

In my view, a mentor-mentee relationship is not the same as a master-apprentice relationship.

But there are other opinions.

Vern Edwards said:

True, but only up to a point. "Done properly" is a big proviso. You're just as likely to pick up bad practices through OJT. It all depends on who is doing the OJTing.

"Senior" and "knowledgable" don't necessarily go hand-in-hand.

Agreed.  What I should have said was knowledgable and objective.  Lots of immediate supervisors are biased (both positively and negatively) and some don’t know what’s good or bad.  

Also Vern, so glad you’re back.  This place isn’t the same without you.

Thanks, formerfed.

Vern Edwards said:

@Jamaal Valentine I'll call you privately next week.

Excellent. Thank you!

@C Culham thank you ... I believe mentors are essential; however, I do not like formal arrangements. Your post just gave me an idea.

I have no problem the with the new approach, but like many of you, I have a concern with on-site training. Having a good mentor, supervisor and professionals around someone new is the most beneficial to development. I come out a civilian agency intern program. 80% of the current training up front and then they had Skill Building and Learning Development (SBLD) courses after each CON course to put what you just learned (should have learned) into action. The setup was very well done and when I got to the field I was ahead of most in in a few. Then I picked those who were the best and learned from them (surround yourself with who you want to be). 

One more thing that I think should be mentioned. You can surround some people with the top 10 COs in the government, send them to 5,000 hours of training and mentor them all you want, but their comes a point where they are going to take responsibility for their own development/technical capability or they won't. No mentor, training program or paycheck will make someone take that step. Sadly, 75% CS/CO are those that Vern didn't choose in 2008:

"I want someone who is never content to simply follow instructions, but wants to know the why of everything and won't accept "Because I said so," or "Because that's the best (usual, standard, generally accepted) way to do it." - Vern's Words of Wisdom - Contracting Workforce - The Wifcon Forums and Blogs

Did anybody read the recent DoD IG report on DCMA contracting officers' failure to follow procedure (DCMA Instruction) when they negotiated final billing rates with two of the largest DoD contractors? I did.

Based on that report and DCMA's agreement with the findings/recommendations, I don't think DCMA contracting officers need much if any training in contracting matters. What they need is training in DCMA's very prescriptive Instructions, which tells them to go to Legal anytime there may be a question that touches on an interpretation of a judicial decision. 

Who needs training? Just do what Legal says and all will be fine. If you fail to consult with Legal and try to use any kind of professional judgment on your own, you will be soundly criticized by both the IG and your leadership.

That's what I took away from the report, anyway.

here_2_help said:

Who needs training? Just do what Legal says and all will be fine. If you fail to consult with Legal and try to use any kind of professional judgment on your own, you will be soundly criticized by both the IG and your leadership.

Exactly what the "legal" side of the house would right.

Constricting Officer said:

Exactly what the "legal" side of the house would right.

Perhaps but it's essentially what the IG wrote and it's what the DCMA leadership agreed with.

Would simply giving contracting officer warrants to attorneys solve the alleged problem?

ji20874 said:

Would simply giving contracting officer warrants to attorneys solve the alleged problem?

I don't know the answer. It's not my problem to solve. 

Again, the issue seems to be prescriptive DCMA Instructions. Follow the Instructions to the letter, or risk criticism. I assume DCMA Leadership is fine with the Instructions saying what they say, because they were approved for release. My theory is that DCMA COs don't need a lot of training because all they have to do is follow their Instructions and all will be well. Or so the IG seems to be saying, with DCMA Leadership agreement.

Is that right or wrong? Doesn't seem to matter.

ji20874 said:

Would simply giving contracting officer warrants to attorneys solve the alleged problem?

I like that the U.S. Army Corps of Engineers gives warrants to their engineers. I wonder what lead to that decision.

Jamaal Valentine said:

I like that the U.S. Army Corps of Engineers gives warrants to their engineers. I wonder what lead to that decision.

It’s a decades old practice.

joel hoffman said:

It’s a decades old practice.

Do you know what led to the decision? Do you have any guesses?

On 3/5/2021 at 12:48 AM, Jamaal Valentine said:

Do you know what led to the decision? Do you have any guesses?

The Army Corps’ Resident Engineers (0800 series) were Resident Contracting Officers (now are ACO’s).  RCO’s had limited $$ authority to sign mods for changes as far back as the 1970’s,  when I was in the Air Force.  Definitely so in 1980, when I joined the Corp’s as a civilian employee.

The District Engineers (DE’s) and their Deputies , all Military Officers, were the Contracting Officers (KO’s**) for A/E and Civil Works and Military Construction contracting (today’s designation as PCO’s).

The 1102’s were in “Procurement and Supply”. They were KO’s for services and supplies. They conducted the IFB’s for construction.

The DE’s (now  called “District Commanders” or “Commanding Officers”) and their Deputies signed the contracts and decided Claims, Terminations, signed all mods outside the RCOs’ authority. Today’s designation is PCO. 

It was in the late 1980’s when 1102 Chiefs of Contracting and their senior level 1102’s began taking over the KO (PCO) duties.  Military DE’s were no longer assigned as the KO’s, to conform to the FAR. When I returned from overseas in 1989, the Military Deputy District Engineers were still the KO’s for civil works and military construction contracts in Mobile District -  until a couple of years later. 

The civilian District Chiefs of Construction and their engineer staffs within Construction Division  and the field offices have traditionally administered the contracts with area and resident engineers having warranted RCO now ACO authority. District Contract Admin Branch provides oversight, policy and handles the non-routine CAB matters. ACO’s have always been the COR’s for non-modification contract admin duties.

In some of the Districts I was in,  Construction Division negotiated all sole source construction contracts.

In Mobile District, we also managed and conducted all construction source selections and some service contract source selections directly for the  Chief of Contracting. 

The Office of Counsel works closely with Contracting, Project Management (PM), Construction and Engineering Divisions in awarding and administering the construction contracting program.

A/E contracts and selections are negotiated and administered within Engineering Division.

USACE had a very robust Training program for negotiating contracts and mods and for Contract Administration procedures including the clauses, contract interpretation, etc. and for technical, construction safety, QA, supervision and leadership, ethics, etc.

To be a supervisory, warranted resident or area engineer a person has to be a registered professional engineer or architect. They must have supervisory and leadership training. They must have yearly technical and ethics continuing education training to maintain their professional licenses. In addition to the Corp’s contracting and negotiating training, they also have to meet the DAWIA qualification and course training requirements for contracting. They have annual mandatory appropriations and procurement integrity refresher training. Many are members of the Army Acquisition Corps.

You ask why engineers? Engineers and architects have long been involved in the full life cycle of construction contracting both within and outside of government.

A/E firms work the life cycle of construction programs and projects. They plan and design projects, write solicitations complete with standard clauses, contract forms, etc. They negotiate contracts, participate in public bidding and often handle private client bidding procedures. They administer contracts, etc. Most standard contract formats are written where the Architect of Record or Engineer of Record make decisions during the execution phase.

Every state has laws, building codes and administrative code which place legal authority and responsibility upon the licensed Designers of Record for public and private construction projects. 

I think the the USACE was fairly unique in having RCO/ACO authority with DoD.

In 1980, I was told by some NAVFAC engineers that every construction contract mod went up to their HQ at the Washington Navy Yard(?) in DC for signature. Seemed like a horribly inefficient way to administer contracts. I don’t know if Resident Officers in Charge of Construction (ROICC’s) have any monetary ACO authority these days. 

Air Force Contracting Offices handle all KO duties for their contracts. Air Force Contracting Offices and the Base Civil Engineers are both located on Air Bases. So, their Contracting Officees handle contract award and contract admin duties. The Base Civil Engineer offices are the technical and QA reps and project managers. They may handle routine contract change negotiations, progress payments, submittal reviews, etc.

The Corps of Engineers are the design and construction agents  for the MILCON program and contracts for most Air Force and Army installations and for some Naval facilities overseas.

My Base at my first Active Duty AF assignment directly contracted for a 250 unit Military Family housing Design-Build project in 1970-1972.  BCE and Procurement handled the whole project.

General Leslie Groves of the Army Corps of Engineers was the Chief of the Manhattan Project. I don’t know if he had any KO authority. But the original Corps’ issued contract for the Los Alamos National Laboratory was at one time the oldest single contract in US government history, I think. The University of California Berkeley was the prime contractor from 1942-2005. UCB is still a member of the current contractor team. Vern Edwards mentioned it on WIFCON once.  

**USACE uses the term “KO” for contracting officers to distinguish from “Commanding Officer” (“CO”), since the USACE is an Army Command. The District Engineers wear two hats [District Engineer (“DE”) = District Commander = Commanding Officer “CO”].

I do not know of any agency that has set a rigorous, objective, and documented standard of knowledge and ability for the appointment of contracting officers, now or at any time in the past. Nor do I believe that there ever will be such an agency in the United States. 

Particular offices within agencies have been demanding from time to time, but none have been so consistently, and the need for enough COs to keep work moving has likely been a factor in many appointments. It is also likely that many COs have been appointed because their superiors considered them to be ambitious, earnest, smart, and promising; because they had done a good job on some project; because it was feared they might leave if not appointed; and because they were well-liked, rather than because they were especially knowledgeable. Such persons tend to have "sponsors."

CO "boards" and "exams" have never been especially demanding, though they were asserted to be so, and it is common practice to "prep" candidates for "boards."  A serious CO exam would test for knowledge of a lot more than just the FAR, and would test skill at analysis, reasoning, and written and oral argument. 

The proof of what I've stated can be found at beta.SAM.gov. Read the RFPs.

If COs were on average more knowledgeable in the past, it is likely because (1) the public education and college systems were generally better in the 1950s and 60s than they have been in more recent decades and (2) CO positions tended to be supervisory; GS-1102s didn't get promoted as quickly as they do now, so they spent more time as working level contract specialists before they were appointed.

If agencies were to start appointing COs on the basis of rigorous, strictly applied standards of knowledge and ability, there would many fewer COs than there are now, and not enough to get the work done.

There are some smart, knowledgeable COs out there, but not enough.

@joel hoffman thank you!

Quote

If COs were on average more knowledgeable in the past, it is likely because (1) the public education system was generally better in the 1950s and 60s than it is today and (2) CO positions tended to be supervisory, GS-1102s didn't get promoted as quickly as they do now, and so they spent more time as working level contract specialists before they were appointed.

I agree.  Grade creep and grade inflation occurred throughout government and it is especially prevalent with 1102s.  I started as an Army/AMC intern at a major buying organization.  The agency was responsible for the consolidation acquisition of ammunition across DoD during the Viet Nam era.  A GS-12 CO usually had 12-15 years experience and heavy responsibilities.  A GS-13 with an unlimited warrant had at least that much experience and had to demonstrate good judgement and initiative to get that warrant.

Today a GS-13 has around 5 years experience and good ones leave jobs for a GS-14 at another agency rather than spend another year at the same grade.  When I worked for the government in my last job, we created non-supervisory GS-14 positions just to keep good performers.  

I’m not saying someone can’t learn the field well in an accelerated manner.  But it takes a long time with lots of exposure to a wide variety of situations to become seasoned and knowledgable.  I’ve seen lots of high grade COs fall apart in challenging situations such as conducting complex negotiations and conducting debriefings, handling claims, or being a witness at a ASBCA hearing and examined by opposing attorneys.

formerfed said:

But it takes a long time with lots of exposure to a wide variety of situations to become seasoned and knowledgable.

There it is.

I'm still lost as the alternate courses that will be offered for those we are needing one or two courses for level 1 whether it's CON170,or CON/091 and CON 280and or 290 for level11. There is still no clear direction and I believe that there should be precise instruction to those of us we are waiting and eager to know what's our faith in reference to getting either levels certified before 1 Oct 2021 . I went on to look at the courses that were just released and I have not seen CON 280 or 290 which is what most if not all persons who0are pursing level 11 . I trust there are some answers that can shed some clarification on these courses.