Friday, May 6, 2011

Responsibility Determinations - Resources (non financial)

Today we continue our series on responsibility determinations. FAR (Federal Acquisition Regulations) requires that contracting officers make an affirmative determination of a prospective contractors "responsibility" prior to awarding any contract. There are seven areas that the contracting officer must address. These seven standards are listed in FAR 9.104-1. Last week we covered the first four. Today we discuss the fifth standard; organization, experience, accounting and operational controls, and technical skills.

A prospective Government contractor must have the necessary organization, experience, accounting and operational controls, and technical skills, or the ability to obtain them. This listing includes EVMS (earned value management system), production control procedures, property control systems, quality assurance measures, and safety programs when appropriate and required by the solicitation. 

The Government often uses the Preaward Survey series of forms to document its assessment. These forms (Standard Forms 1402 through 1409) cover general aspects, technical production, quality assurance, financial capability and accounting systems. We've discussed the accounting system form (SF 1408) previously on this blog. The contracting officer typically assigns these surveys to different organizations. For example, DCAA typically performs the accounting system survey, while DCMA performs the financial capability and probably some of the technical aspects.

For companies that do not have the required systems in place at the time it submits its proposal, this standard includes the provision "...ability to obtain resources". If a prospective contractor does not currently have sufficient resources in place (and is not proposing to subcontract out that work), the contracting officer will require acceptable evidence of the ability to obtain those resources. Acceptable evidence normally consists of a commitment or explicit arrangement, that will be in existence at the time of contract award, to rent, purchase, or otherwise acquire the needed facilities, equipment, other resources, or personnel. If you fall into this category, it is extremely important to prepare and submit (or have ready to submit) documentation that will satisfy this requirement.

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