Why FAR Guiding Principles are Vital to CO/PM Effectiveness

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    Tracey Wright
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    By Kevin Drummond and Tom Kuhn

    There are many important concepts in the 53 Parts of the Federal Acquisition Regulations (FAR). I would submit that none is more important and has greater potential impact on positive outcomes than the Guiding Principles found in FAR subpart 1.102. The Guiding Principles provide a framework to set up successful acquisition team interactions, thereby leading to successful project/contract outcomes. In other words, obtaining best value for our ultimate stakeholders – the American taxpayer!

    Tom and I will discuss the Guiding Principles and two key players on the Acquisition Team – the Project/Program Managers (PMs) and the Contracting Officers (COs) – charged with turning these concepts into reality in the form of cost efficient, timely projects that accomplish the stated objective. Tom will speak to the PM perspective and I the CO perspective – all in search of common ground.

    Key Tenets of the Guiding Principles (Far 1.102)

    • Timely delivery of the best value product or service

    • Maintaining the public’s trust

    • Fulfilling public policy objectives

    • Team work (synergy)

    • Empowerment within area of responsibility

    • Satisfy the customer in terms of cost, quality, and timeliness of the delivered product or service

    Tom: The PM Perspective

    Program Managers have an overall macro level project responsibility to include cost, schedule, and scope. Due to the complexity of many Federal projects, PMs often do not have the time to “get in the weeds” and view those who do as impediments to the overall success of the project. PMs often ask Contracting Officers: Why must we compete a requirement when I know a great vendor who has a very successful track record? Why must we consider using small businesses when large companies most often have better resources and are better equipped to meet our needs?

    The PM is indeed responsible for cost, schedule, and performance when embarking on a new procurement, project, or major program. No program manager will have all three balanced. If they are lucky they may get two out of three. Think of the three pieces as a three legged chair whereby if any one leg is shorter the chair is not balanced. What do these important elements have to do with the contracting strategy, and most importantly, the relationship with the CO? The contracting strategy selected will play a big role in how the PM effectively manages the program.

    Kevin: The CO Perspective

    The Contracting Officer is charged with overall responsibility of all contractual matters related to a project or program. Historically, as Tom has stated, COs have been viewed by many PMs as impediments because COs are entrusted with ensuring adherence to competitive and social economic rules and regulations. The CO also has an implied duty of good faith and fair dealing in their interactions with contractors. The key to being a successful CO is the proper balancing of often competing objectives (bottom line price vs. small business participation for example). The FAR actually provides latitude in the absence of a policy or procedure, advising that COs “should take the lead in encouraging business process innovations and ensuring that business decisions are sound.”

    Approaching problems as an acquisition team can generate innovative ideas. I was fortunate in my career to have very productive relationships with my Air Force PMs while working several years in the construction field; these relationships worked due to constant communication and give and take with regard to the best methodology to achieve the desired result. On one project to pour concrete runways, some cracks occurred which required close coordination between me and my PM to determine the cause of the defect. I was able to work this out to the satisfaction of all parties due to our rapport.

    WHERE WE AGREE

    Tom: Relationship is Key to Outcome

    The PM and CO relationship and working processes are important when developing an acquisition package. I have found it helps to understand the CO’s strengths and weaknesses, both in experience and strategies, to better prepare the package. Some COs are very conservative and some are aggressive in their contracting approaches. Often, the policy of the particular organization (i.e. NAVAIR, DoD, FAA, etc.) drives what the CO and PM are allowed to do when using particular contracting vehicles and methods. For example, one contracting office I have dealt with has a good rapport with a particular contracting vehicle and requires all contracting to be completed through it. Sometimes this limits flexibility, but it also results in a streamlined approach as there are known set processes. It is important to understand these policies and what the “playing field” presents the PM as the procurement strategy is developed.

    Very detailed discussions with the CO should take place throughout the development of the entire acquisition package, realizing there will be potential differences of opinion on what the PM wants to do and what the CO will allow. When this occurs, the PM should ask the CO if they are simply advising the PM based on FAR policy or if it is their own opinion.

    Once when I was developing a contract to modify a line of aircraft with new defensive systems, I wanted to purchase the modification kits through another means and was advised not to. My desire was to have a multiple approach to execute the modification. I could have legally gone my own way in my approach, but ultimately I went with the CO’s recommendation. Still, the PM should be prepared to move forward with their plan if it is determined that they will not violate policy and if the strategy makes sense.

    Kevin: Find Common Ground to Meet Guiding Principles

    Cross training of COs and PMs is important to establish a mutual appreciation for the collective value they bring to the acquisition process. As a long time CO I sought the Project Management Professional (PMP) Certification via the Project Management Institute (PMI) in order to gain a PM perspective and see the macro-level acquisition process “through the PMs eyes.” The CO must be capable of explaining to PMs and the entire Acquisition Team the reasons behind the myriad of regulatory requirements within the Federal Acquisition System.

    Most importantly, the CO must be courageous enough to utilize all tools available in keeping with the spirit and intent of the FAR Guiding Principles to arrive at the best acquisition outcome. I have found this to be a great method of building bridges and creating mutual understanding and common ground!

    Article republished from Integrity Matters blog – Perspectives on acquisition and program management,

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