This curriculum spans the breadth of a multi-workshop government procurement advisory engagement, addressing regulatory interpretation, risk management, compliance, and interagency coordination as they arise in end-to-end acquisition planning and execution.
Module 1: Navigating the Federal Acquisition Regulation (FAR) Framework
- Selecting the appropriate FAR part and subpart when structuring a services acquisition involving performance-based work statements.
- Interpreting FAR 15 vs. FAR 8.4.1 rules when choosing between negotiated competitive procurement and using the GSA Schedule.
- Applying FAR 52.212-4 clauses correctly in commercial item contracts versus non-commercial acquisitions.
- Documenting deviations from standard FAR clauses when agency-specific requirements necessitate modifications.
- Resolving conflicts between agency supplements (e.g., DFARS, AFARS) and the base FAR text during solicitation development.
- Ensuring consistency between FAR 9.1 contractor responsibility determinations and past performance evaluations in source selection.
Module 2: Contract Types and Risk Allocation Strategies
- Choosing between fixed-price incentive (FPIF) and cost-plus-award-fee (CPAF) structures based on technical uncertainty and contractor control.
- Setting objective profit fee ranges in CPAF contracts while complying with FAR 16.401(e) and avoiding constructive changes.
- Negotiating equitable adjustments when converting a time-and-materials contract to firm-fixed-price mid-performance.
- Implementing not-to-exceed (NTE) ceilings in indefinite-delivery/indefinite-quantity (IDIQ) task orders to manage budget overruns.
- Assessing performance risk in multi-year contracts and determining appropriate limitation of cost or time provisions.
- Documenting rationale for using cost-reimbursement contracts in exigent circumstances under FAR 16.301-3.
Module 3: Socioeconomic Compliance and Small Business Utilization
- Validating Small Business Administration (SBA) size standards at the NAICS code level during acquisition planning.
- Conducting a fair opportunity analysis under FAR 16.505(b) for task orders exceeding $750,000 in a multiple-award IDIQ.
- Resolving discrepancies between SBA certificates of competency and past contractor performance data.
- Allocating subcontracting goals in prime contracts exceeding $750,000 and tracking progress under FAR 52.219-9.
- Responding to protests filed by small businesses challenging socioeconomic set-aside determinations.
- Coordinating with agency small business specialists to avoid improper sole-source awards under 8(a) programs.
Module 4: Source Selection and Evaluation Methodologies
- Designing evaluation factors under FAR 15.304 that distinguish between technical approach, past performance, and price trade-offs.
- Calibrating adjectival ratings across evaluation teams to ensure consistency and defensibility in best value trade space analysis.
- Conducting discussions with offerors under FAR 15.306(d) without creating unequal access to information.
- Handling late proposals under FAR 52.215-1 while balancing fairness and regulatory deadlines.
- Documenting evaluation decisions to support debriefings and potential GAO protests.
- Using past performance information from the Contractor Performance Assessment Reporting System (CPARS) in responsibility determinations.
Module 5: Contract Modifications and Change Control
- Issuing unilateral change orders under FAR 43.202 when scope changes fall within the contract’s changes clause.
- Negotiating equitable adjustments for constructive changes caused by government delays in data delivery.
- Managing cardinal changes that may require termination for convenience and recompete under new requirements.
- Tracking cumulative modifications to ensure modifications do not constitute a new procurement under the Competition in Contracting Act (CICA).
- Documenting authorization for undefinitized contract actions (UCAs) and setting firm completion dates under FAR 16.703.
- Coordinating with legal counsel when modifications impact socioeconomic goals or small business subcontracting plans.
Module 6: Compliance with Mandatory Clauses and Reporting Requirements
- Implementing cybersecurity requirements under FAR 52.204-21 and NIST SP 800-171 for controlled unclassified information (CUI).
- Ensuring compliance with labor standards, including Davis-Bacon wage determinations, in construction contracts.
- Reporting final indirect cost rates to DCAA and negotiating forward pricing rate agreements (FPRAs).
- Managing compliance with FAR 52.222-50 (Combatting Trafficking in Persons) in overseas operations.
- Submitting accurate incurred cost submissions under FAR 52.216-7 for cost-reimbursement contracts.
- Updating the System for Award Management (SAM) with current representations and certifications to avoid debarment risks.
Module 7: Protest Defense and Oversight Engagement
- Preparing agency report submissions to GAO within the 30-day protest response window, including all relevant documentation.
- Coordinating with legal counsel during DCAA audits focused on allowability of indirect costs under FAR 31.2.
- Responding to Inspector General inquiries regarding potential organizational conflicts of interest (OCI) under FAR 9.5.
- Preserving procurement integrity by enforcing debriefing rules and avoiding post-award discussions with unsuccessful offerors.
- Managing corrective action after a protest sustain, including re-evaluation or re-competition, without compromising fairness.
- Documenting acquisition history to support decisions during congressional or OMB oversight reviews.
Module 8: Multi-Agency and Interagency Acquisitions
- Establishing an Interagency Agreement (IAA) under FAR 17.5 with a lead agency acting as the contracting authority.
- Allocating responsibility for compliance with socioeconomic goals when a requesting agency uses another agency’s contract vehicle.
- Resolving disputes over fee structures and administrative costs in government-wide acquisition contracts (GWACs).
- Ensuring the ordering activity fulfills its obligation to conduct market research under FAR 10.001 when using an existing IDIQ.
- Managing differences in agency acquisition regulations when participating in a joint procurement.
- Tracking task order performance across multiple agencies using the Federal Procurement Data System (FPDS) reporting requirements.