Tag Archives: DPAP

Can the Department of Defense Make Bold, Radical Changes to its Acquisition Process?

commercial item acquisition

Is commercial item acquisition the pathway for the Department of Defense (DoD) to fulfill its goal of having better access to the latest technological advances, and do DoD’s current acquisition rules and regulations hinder that goal?

Do commercial contractors think selling to the Federal Government, particularly to the DoD, is a worthwhile endeavor?

Are there too many DoD procurement regulations; and are the current regulations relevant?

A body of experts commissioned by Congress in the FY16 National Defense Authorization Act (NDAA) is addressing these questions and more.  

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Department of Defense (DoD) Seeks Comments on Draft Commercial Item Acquisition Guidebooks

The Department of Defense’s (DoD) goal for procurement is to have an efficient acquisition system that is effective in providing support to the warfighter. The use of commercial item acquisition is seen as one way of achieving this goal, however there are currently varying levels of understanding and consistency within DoD regarding determining commerciality and in determining fair and reasonable prices.

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DoD Now Awarding more than Half its Contract Spending without Competitive Bids

By Federal News Radio – originally published August 22, 2016

This week marks the two-year point since the Defense Department — worried that only 56.5 percent of its contracted dollars involved a meaningful competition between two or more vendors — issued a series of corrective actions to reverse a downward slide that’s been ongoing for nearly a decade.

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Are Your IR&D Costs Allowable?

MH910216329It’s time to <RETHINK> how you determine allowability of IR&D costs.  Not rethinking your approach could result in the government deeming your IR&D costs expressly unallowable.  Spending a few minutes reading this blog will provide you with the required knowledge to ensure your IR&D costs continue to be allowable.

Effective January 30, 2012, the DFARS IR&D cost principle (DFARS 231.205-18(c)(iii)(C)) now requires, as a condition of allowability, contractors to report their IR&D projects to the Defense Technical Information Center (DTIC).  Even though this requirement applies only to “major contractors”, as defined in DFARS (DFARS 231.205-18(a)(iii)), the government encourages all contractors to follow this process.

There are additional consequences of not reporting your IR&D project to DTIC.  On April 24, 2014, DCAA issued guidance to their auditors explaining how the failure of complying with the DFARS requirement could impact Forward Pricing, Incurred Cost, Cost Accounting Standards, and Accounting System audits.  For example, DCAA asserts that a failure to comply with the reporting requirement may constitute a CAS 405 noncompliance and an Accounting System deficiency.

Haven’t reported your IR&D projects to DTIC?  Have no fear! Fortunately,

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DoD is Rethinking Fair and Reasonableness of GSA Schedule Pricing


DoD has decided that GSA Schedule prices may not be fair and reasonable and is instructing Contracting Officers to conduct their own pricing review on GSA task orders.

For those unfamiliar with FAR 8.404(d), its authority provides one of the primary values of the GSA Schedules program.  It states: “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing…”. By pre-determining that prices/rates for goods and services under schedule contracts are “fair and reasonable”, purchasing agencies have been relieved of performing the proposal analysis techniques described in FAR 15.404-1. Since they don’t have to duplicate the work already done by GSA COs in reviewing pricing, utilizing the Schedules program provides government buyers with a significant savings in time and effort. Well, not anymore for DoD buyers… 

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