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1 A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS PIP Level 1 Raymond Jones.

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Presentation on theme: "1 A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS PIP Level 1 Raymond Jones."— Presentation transcript:

1 1 A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS PIP Level 1 Raymond Jones

2 2OBJECTIVES Address issues with Justifications Address issues with Justifications Discuss why Justifications are important Discuss why Justifications are important Discuss when Justifications are necessary Discuss when Justifications are necessary Discuss what is needed for an approved Justification for Sole Source Simplified Acquisitions (JSSA), Justification for Specific Make and Model (JSMM), and a Justification for other than Full and Open Competition (JOFOC) Discuss what is needed for an approved Justification for Sole Source Simplified Acquisitions (JSSA), Justification for Specific Make and Model (JSMM), and a Justification for other than Full and Open Competition (JOFOC)

3 3 DILEMMAS Inadequate Regulatory Guidance Inadequate Regulatory Guidance - No adequate written guidance - Causes variation between Contracting Officers (COs) - Disseminating among the Technical Community FAR Part 13.501(a)(1) Acquisitions conducted under simplified acquisition procedures are exempt from the requirements in Part 6.

4 4 DILEMMAS contd Inadequate justification of product or service Inadequate justification of product or service Poor planning Poor planning Lack of market research Lack of market research No justifying reason to preclude competition No justifying reason to preclude competition

5 5 WHY ARE JUSTIFICATIONS IMPORTANT? Needless competition Needless competition

6 6 WHEN JUSTIFICATIONS ARE WARRANTED Replacement Parts Replacement Parts Equipment Upgrades/Repairs Equipment Upgrades/Repairs Proprietary Data (source codes) Proprietary Data (source codes) Urgency Urgency Brand Name (compatibility) Brand Name (compatibility)

7 7 What is a Justification for Sole Source Simplified Acquisitions?

8 8 Definition Justification for Sole Source Small Purchases– A document that is required for procurements valued from $2,500.01 up to $100,000, for which it has been determined that there is no mandatory or intragovernmental source to meet the requirement and must be purchased from one responsible source. Justification for Sole Source Small Purchases– A document that is required for procurements valued from $2,500.01 up to $100,000, for which it has been determined that there is no mandatory or intragovernmental source to meet the requirement and must be purchased from one responsible source.

9 9 What Makes A Good Justification for Sole Source Simplified Acquisition ?

10 10 Sole Source Justification Up to $100K Identify the company and its size Identify the company and its size Identify the product or service Identify the product or service - Unique features - Estimated cost - Use or purpose - Specify delivery date if needed Describe Market research Describe Market research

11 11 Sole Source Justification Up to $100K contd Evaluation Criteria against minimum requirements Evaluation Criteria against minimum requirements Include recommendation made to FAR Part 13.106 Include recommendation made to FAR Part 13.106 Signatures Signatures - Technical Representative (Tech Rep.) - Contracting Officer (CO) Supporting Documentation Supporting Documentation

12 12 What is a Justification for Specific Make and Model?

13 13 Definition Justification for Specific Make and Model- Justification for Specific Make and Model- A justification explaining why the special physical, functional and performance characteristics of a brand name product should be purchased over the other product brands.

14 14 What Makes a Good Justification for Specific Make and Model?

15 15 Justification For Specific Make and Model Why specific product Why specific product - Compatibility Identify the requirement Identify the requirement Other products considered Other products considered Signature Signature - Tech. Rep. - CO. Supporting documentation Supporting documentation

16 16 What is a JOFOC?

17 17 Definition JOFOC – A document that contains sufficient facts that will justify why certain requirements over $100,000 should not be treated as full and open competition procurements. JOFOC – A document that contains sufficient facts that will justify why certain requirements over $100,000 should not be treated as full and open competition procurements.

18 18 What are JOFOC requirements?

19 19 JOFOC Requirements FAR Part 13.501(a)(1)(ii) Prepare sole source justifications using the format at 6.303-2, modified to reflect an acquisition under the authority of the test program for commercial services FAR Part 13.501(a)(1)(ii) Prepare sole source justifications using the format at 6.303-2, modified to reflect an acquisition under the authority of the test program for commercial services Be compliant with GSFC Procurement Circular 97-4 (available at: http://gsfc- artemis.gsfc.nasa.gov/210/flalpha.htm) Be compliant with GSFC Procurement Circular 97-4 (available at: http://gsfc- artemis.gsfc.nasa.gov/210/flalpha.htm)

20 20 JOFOC Requirements contd. Facts and Rationale Facts and Rationale Identification of Agency Identification of Agency Description of Item or Service Description of Item or Service Description of supplies or service required Description of supplies or service required Statutory Authority Statutory Authority Contractors Qualifications Contractors Qualifications

21 21 JOFOC Requirements contd. Synopsis details Synopsis details Market Research Market Research Other Relating facts Other Relating facts Potential Sources Potential Sources Actions by agency Actions by agency Signature Signature Varies by dollar value Varies by dollar value Supporting Documentation Supporting Documentation

22 22 Around NASA Nothing is being done differently except: Nothing is being done differently except: - More centers are using the VPO templates to give to customers.

23 23 Recommendation Since there is no real requirements in writing a justification I recommend Since there is no real requirements in writing a justification I recommend NASA Consider Formalizing These Requirements (e.g. Procurement Circular) NASA Consider Formalizing These Requirements (e.g. Procurement Circular) Templates Templates - Customers Adhere to Laws and Templates - Employees would have more time to focus on work.

24 24 Sources Simplified Acquisition Specialists within Code 210.M Simplified Acquisition Specialists within Code 210.M Small Purchase Acquisition Team (SPAT) Small Purchase Acquisition Team (SPAT) Marcus Orr, Kennedy Space Center (Marcus.C.Orr@nasa.gov) Marcus Orr, Kennedy Space Center (Marcus.C.Orr@nasa.gov)Marcus.C.Orr@nasa.gov

25 25 Sources contd. Robin Strohacker, Glenn Research Center (Robin.H.Strohacker@nasa.gov) Robin Strohacker, Glenn Research Center (Robin.H.Strohacker@nasa.gov)Robin.H.Strohacker@nasa.gov Susan McClain, Langley Research Center (Susan.E.Mcclain@nasa.gov) Susan McClain, Langley Research Center (Susan.E.Mcclain@nasa.gov)Susan.E.Mcclain@nasa.gov Marlo Krisberg, Kennedy Space Center Marlo Krisberg, Kennedy Space Center (Marlo.F.Krisberg@nasa.gov) (Marlo.F.Krisberg@nasa.gov)Marlo.F.Krisberg@nasa.gov

26 26 SUMMARY Addressed issues with Justifications Addressed issues with Justifications Discussed why Justifications are important Discussed why Justifications are important Discussed when Justifications are necessary Discussed when Justifications are necessary Discussed what is needed for an approved Justification for Sole Source Simplified Acquisitions (JSSA), Justification for Specific Make and Model (JSMM), and a Justification for other than Full and Open Competition (JOFOC) Discussed what is needed for an approved Justification for Sole Source Simplified Acquisitions (JSSA), Justification for Specific Make and Model (JSMM), and a Justification for other than Full and Open Competition (JOFOC)

27 27 Questions


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