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Navy Ability to Bid on Government Contracts document sample
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TOP 12 BARRIERS LIST
Submitted by Acquisition Improvement Team
Following are the top 4 Barriers for initial AIT focus.
BARRIER NUMBER ONE – Navy IDIQ Multiple Award Contract (MAC) Policy Change
Adve rsely Impacts Cost of Contracts and Limits Competition.
Issue: The Navy Policy to apply the Section 843 requirements to all IDIQ procurements
under $100M increases costs for both the Government and Industry which may lead to a reduced
ability to compete.
Discussion: The IDIQ/MAC process requires larger Bid and Proposal staffs for the
contractors and more contracting staff for the Government because of the manpower necessary to
submit and evaluate competitive proposals for the basic MAC contract award and for the
competitive award of each task order each year. Over the five year life of a normal service
contract, a MAC/IDIQ with 10 annual task orders would require 51 competitive proposals from
each schedule holder versus 1 competitive proposal for a single award IDIQ. Application of the
MAC/IDIQ process to contracts between $10M and $100M will generate extraordinary growth
in indirect staffing costs disproportionate to any savings that the Government may achieve
through the added competitions. The MAC/IDIQ process causes hardship for small business
competitors who do not have dedicated Bid and Proposal staffs and increases costs to the
Government as a result of the growth of indirect labor staffing necessary to support the repetitive
proposal process.
Summary: The single award IDIQ contract under $100M is a versatile, responsive and
economical contract type ideally suited to smaller contractors and small Government contracting
shops. The Navy policy changing the threshold of the IDIQ/MAC to include all procurements
will virtually eliminate the single award IDIQ contract in favor of the labor intensive IDIQ/MAC
process which will lead to B&P cost growth, increased load on Government contracting offices
and, longer procurement lead times.
BARRIER NUMBER TWO - Inconsistent Methods of Collecting Past Performance
Discourages Use of CPARS As the Single Standardized Source of Past Pe rformance
Information.
Issue: Repetitive submission of identical Past Performance information is burdensome
and unnecessary to meet competitive evaluation requirements.
Discussion: Multiple methods currently exist for providing past performance information
as part of a proposal package. Solicitation language in Sections L & M for the submission and
evaluation of Past Performance vary substantially. Based primarily on the submission of
questionnaires, submission of past performance data can be inconsistent, time consuming and
inaccurate.
Summary: Use of CPARS as a single source would minimize repetitive submission of Past
Performance information and create structural incentives to the completion of CPARS.
(Ongoing project)
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BARRIER NUMBER THREE – Shift Away from GSA Service Contracts Impacts
NAVAIR Custome rs and Contractors. (#12 – 5 votes)
Issue: NAVAIR customers do not have access to short term rapid award service
contracting vehicles to support emerging and short term requirements of its internal and external
customers.
Discussion: DoD policy discouraging use of GSA and other similar Non-DoD service
contracting vehicles has essentially eliminated these useful short lead-time contracting vehicles.
Continued non-use of GSA service contracts causes locally based contractors to lose their
existing GSA schedules and discourages the substantial investment of Bid and Proposal
resources to obtain new GSA Schedules. DoD has no alternative to the GSA schedules.
Seaporte has not delivered the short award lead times promised. Conversion of single award
IDIQ contracts to IDIQ/MAC’s adds substantial lead time to order placement. Restrictions on
use of Non-DoD Agency contracts effectively eliminate these tools for short term service
requirements. The small purchase threshold is too low to substitute for the non-availability of
other streamlined contracting methods.
Summary: DoD’s focus away from GSA and other Non-DoD service contracting vehicles
impacts operations and growth of local businesses and increases award time of service contracts
supporting NAVAIR customers.
BARRIER NUMBER FOUR – Limited Access to Information Dissemination Impedes
Competition and Marketing. (#6, #24#, 8 votes)
Issue: Information including acquisition improvements, lessons learned, existing and future
requirements, and contact information is not readily available to the community.
Discussion: The lack of access to various types of information adversely impacts the
acquisition process. This information is necessary to make intelligent business decisions,
perform advance planning, market new ideas, receive feedback o n the latest trends and maintain
quality communications between the commercial and government components of the acquisition
community. The information includes but is not limited to;
Existing Contracts (future requirements listing)
Projected new work
Lessons learned
AIT Communications
Base locator information (telephone/e- mail book)
Summary: Equal and fair access to a variety of classes of information would improve the
flow of information for the mutual benefit of the Government and contractor community.
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REMAINING TOP 12 BARRIERS
(listed in no particular orde r)
Barrie r – Selection of Appropriate Services Contract Type.
Issue: The selection of the contract type and structure must consider the type of services to
be performed, the complexity of the task, the variables of task performance and schedule, the
probability of changes, and other factors related to the most efficient ordering of the work. .
Discussion: The Federal Acquisition Regulation provides wide latitude to the Contracting
Officer in the design of a contract document. One method to reduce the number of contract
actions is to make contracts for common types of services widely available for use across
organizational lines. The avoidance of stovepipe contracts will reduce repetitive contract actions
and duplicate contracts. Appropriate use of C and D contracts can be improved through research
of the intended contracting environment, the customer’s needs, and the funding profile. A
thorough understanding of the requirement in relation is be beneficial in the selection of the
pricing and fee structure as well as the means to direct contractor performance for C and D
contracts. Where work is fairly well defined a C contract with Technical Instructions would
perhaps be the best choice. In a situation of indefinite requirements a choice must be made
between various indefinite type contracts and the use of Multiple Award procedures. The time to
process the actions most likely to occur during performance should be a prime factor in the type
decision. Where a technical instruction is appropriate it would be the most time efficient
process. If the work is so undefined that orders would be appropriate the D type contract may be
the best match.
There is limited differentiation in contracts for specialized and highly complex services
versus administrative and general project support efforts. Clients cannot seem to get contracts
that support the various "levels" (specialized expertise, senior level expertise) of services they
need. One size fits all SOWs and contracts drives contractor community to lowest/moderate
price talent and limits ability to provide the right level of specialized services to meet clients’
needs.
Award Fees provide greater incentives for service. Fee levels on service contracts do not
motivate contractors to provide top talent and bring the best to NAVAIR and NAWC-AD. There
is limited use of award fee to reward top performance on service contracts.
Summary: Although the selection of contract type is a contracting officer prerogative, it
should be based upon a careful consideration of how the contract will be used and how the
processes incorporated in the contract will be the most efficient post award solution to the
customers needs.
Barrie r – Seaporte Orde rs have no Provision for Growth.
Issue: The Seaporte IDIQ/MAC contract awards are actually 5 year orders that are for
definite services and have no provisions for growth customarily required by the customer with an
IDIQ requirement.
Discussion: NAVAIR SeaPort-e orders are awarded with little to no provisions for
growth. This situation negatively impacts the ability for the customer to address unknown
requirements in a timely fashion. Because Seaporte took the place of a large number of single
award IDIQ contracts, the Seaporte process has replaced the simple delivery order process with
the more burdensome Seaporte process. In order to manage workload caused by the large
number of competitions inherent in an IDIQ/MAC type contract, the average Seaporte Order is
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awarded for defined services over a 5 year term. The result is that the IDIQ nature of the
Seaporte contract has been lost. The only method available to meet emerging requirements
while maintaining the customer/contractor relationship within a Seaporte order is to accelerate
delivery. Because of the proliferation of these large long term Seaporte orders, there is no longer
a true IDIQ contracting instrument available to the NAVAIR customer with an indefinite
requirement. The responsiveness, flexibility, and efficiency of the IDIQ single award contract
which maintains a long term customer/contractor relationship still has a useful roll in meeting
customer requirements where there is truly an inability to define the work in advance.
Summary: There remains a need for large IDIQ type contracting vehicles.
Barrie r – Excessively Frequent Incre mental Funding Modifications.
Issue: Frequent incremental funding actions have a large and often negative impact on
cost and performance.
Discussion: Incremental funding that requires multiple extensions each year, often on the
last day of the period of performance or perhaps late, causes work at risk or withdrawal from task
performance. The incremental funding process adds administrative work for contractors and the
USN. Administration of multiple projects funded in small increments for short periods of time is
difficult and wasteful requiring frequent repetitive estimates of funds consumed to date and
required funding to complete the task or term. If the delay in funding causes a break in
performance it may be necessary to renew badges/security on a more frequent basis. The
incremental funding has an adverse effect on employee morale because the employees feel
insecure as their POP approaches its end date without funding. At times it is necessary to pull
employees out of task. Employees often look for more secure work situations.
Summary: The process of providing funds via a large number of small incremental funding
modifications disrupts work, increases work on risk, adversely impacts staff morale and retention
and results in growth of costs through added administrative tasks, more frequent reporting, and
repetitive security processing.
Barrie r – Meeting Small Business Subcontracting Goals.
Issue: Meeting small business (SB) subcontracting goals is difficult when: (a) the only
qualified SB(s) holds a competing IDIQ/MAC award, and (b) when market research has
demonstrated there are no qualified SB sources and a large business is required to meet a
substantial SB subcontracting goal with qualified SB subcontractors in an unrestricted
competition.
Discussion: It is very difficult for large businesses to meet SB goals on the large IDIQ
multiple award contracts when awards are issued to both SBs and large businesses. There is no
incentive for the SBs to work through a large business prime to obtain work when they can use
their own contract vehicle to compete for award. Therefore, large businesses cannot subcontract
to SBs for resources to perform the technical work because the SBs who can perform the work
are already under contract as IDIQ/MAC schedule holders and would have to compete against
themselves. In other situations where market research shows that there are no qualified small
businesses to perform the work, it is not reasonable to require a substantial amount of the work
be subcontracted to small businesses. If the Government’s market research could not find
qualified small businesses it is unlikely that a large business can find them. Considering
demanding past performance and corporate experience requirements in competitions, the large
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business is presented with a very difficult task to locate qualified small business subcontractors
in order to compete for award.
Summary: the availability of qualified subcontractors should be considered when
determining requirements for SB subcontracting goals.
Barrie r – Accumulation of Burdensome Contracting and Financial Processes.
Issue: Performing contractual and financial processes and controls takes precedence over
achieving technical goals making the process slow and arduous.
Discussion: This needs to be investigated further to see if we can identify the areas of
concern. The AIT members thought the interpretation could be any one of the following:
(1) The focus on Pre-Award acquisition strategy development and approvals seems to
take away from getting the technical requirement accomplished.
(2) The Pre-Award competing and conflicting acquisition requirements (documentation
and/or regulations/policies) tend to overshadow technical requirement.
(3) For Post-Award activity, sometimes writing the required status report takes longer
than the actual technical task.
(4) For Post-Award activity, the management of the QASP tends to take time away from
executing the requirement.
(5) Managing to the requirements demanded because of Electronic Acquisition tools take
precedent over technical tasks
OLD DISCUSSION: The technical requirement for support is often seen as secondary to the
contracting and financial processes, approval levels, and controls which absorb a growing
portion of the contracting effort and dilute the ability to supply the customer with the required
service or product. As a result NAVAIR and NAWC-AD contracting has become less flexible
and less responsive to customer needs. Increased financial and contracting controls and approval
levels have eliminated many contracting methods previously available to respond to customer’s
specialized and emergent needs. The contracting process has become too slow and arduous to
provide discrete contract actions to meet specialized program requirements.
Summary: The contracting and financial process controls accumulate over time until they
become obstacles to the prime objective. Controls are often added but rarely withdrawn even
when the purpose for the control is no longer understood.
Barrie r - RFP Response Times
Issue: Request for Proposal response times can be inadequate for the purposes of fair
competition.
Discussion: FAR requires 15 days advance notice and 30 days response time for actions
above the small purchase threshold for most acquisitions. FAR minimum response time makes
no distinction between simple or complex requirements or relatively low value or very high
value requirements. The actual amount of time allowed for the response is at the discretion of
the contracting officer. Realistic timeframes for RFP release are not provided or committed to,
resulting in significant cost increases or extensions for preparation of proposal and planning for
resources. Response times for Seaporte orders, being orders under an IDIQ/MAC, are often
lower than those for an Non IDIQ/MAC RFP regardless of the size of the order.
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Summary: Complexity, value and other factors should be considered in determining the
response time for an RFP. The FAR minimum response times may not be adequate for all
circumstances.
Barrie r - Performance Based Contracting for Services
Issue: Performance based contracting procedures for services restricts competition and is
ineffective for professional services contracts.
Discussion: Performance based contracting processes are designed for manufacturing and
measureable and repeatable processes. Application of performance based procedures to many
professional and administrative services which are variable and often change from day to day
and month to month is not practical. Application of performance standards and formats tends to
create unnatural and tortured processes just to meet policy standards but having little to do with
the actual service. To do performance based contracting for services because it is policy even
though it is not practical is an example of an out of control process.
Summary: Performance based contracting for services has so far proved to be in form only
and has not been demonstrated as a practical process. It is perhaps another example of
legislation out running process capabilities.
Barrie r Contract Action Process Times
Issue: Process administrative lead time for completing contracting actions is too long to
support the contracting process.
Discussion: The pace of NAVAIR contracts definitely presents a barrier to doing
business. Communications aren’t always the best, and responsiveness is definitely lacking.
There does not seem to be a true understanding how process time affects a small business.
Summary: Excessive process lead time is a burden to businesses.
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