Quick Hitter: DFARS Part 207

Just as with my Quick Hitters on the FAR and GSAR, my Quick Hitter series on the DFARS is meant to simplify contracting business with the government. This time with DoD.

DFARS 207.105 Contents Of Written Acquisition Plans

If you’re a CO (KO) at DoD, I’m sorry. These things are an absolute bear! I was first introduced to Acq Plans at the VA Acquisition Academy near the beginning of my training. They were the standard version, and even those took more time then any of us could imagine or deemed reasonable at the time. If you’re a prospective or current contractor with DoD, give your assigned CO some leeway because these things are living documents that must be updated with any changes in the project lifecycle. I distinctly remember my instructor telling us when she handed out the project, “Thank God you don’t have to do one of these for DoD, yet!” We were just using FAR 7.105 then.

This writeup will concentrate on PGI 207.105 which is a nine page digital document on the iPhone used in combination with FAR 7.105.

This is a team-wide oriented procedure with a hierarchical chain of review.

Acquisition Background & Objectives

Statement Of Need

Include a synopsis of the buy, pertinent dates and waivers obtained (if applicable), a milestone chart depicting project benchmarks and indicators of updates, various phases of the acquisition’s lifecycle and if/when the “order of procurement” and any accompanying Procurement List(s) will be used.

Lifecycle Cost

Explain the decided upon best-value continuum as derived by the CO which also applies to temporary structures as well.

Acquisition Streamlining

List viable methods that will make the purchase more administratively efficient as well as those that will create cost cutting measures (e.g. bundling, leasing, etc.).

Plan Of Action

Competition

How will the buy be competed? Read my Quick Hitter on DFARS Part 206 for more information on how DoD perpetuates perimeters of competitions through federal and agency regulations by way of their COs.

Acquisition Considerations

Is the buy going to be conducted in-house (DoD) or out (most likely GSA)? Either way, DoD acquisition guidelines must be adhered to.

Budgeting & Funding

Give a snapshot of how the buy fits into appropriated funds. Be very specific (e.g. FY appropriation, percentage of agency/department/contracting shop budget, line-item particulars, current cost & forecasted cost).

Product/Service Descriptions

Describe what the purchase is. Give detailed specifications of each line-item. Explain your market research tactics. Notify if the good or service is commercial, modified or custom.

Logistics Considerations

List the place of performance, production plan, management structure, feedback arsenal, types of analysis, corrective action & any related studies associated with the project. DoD won’t buy goods whose production is not safe, renewable and responsible. This includes weapons systems.

Data/License Rights

If purchasing goods or services (e.g. technology, weapons systems or training curriculum) determine if the government will negotiate technical data and/or license rights.

Environmental & Energy Objectives

Discuss how chemicals will be used and disposed of. Elaborate on plans to engage in recycling and waste management.

Other Considerations

National Technology & Industry Base (Major Defense Acquisition Programs)

Plan if the buy is applicable. Determine CONUS or OCONUS. Discuss the use of any raw materials, alloys, composite materials, components, tooling and/or production equipment in terms of use or maintenance. Elaborate on alternatives to purchase outside of the NTIB as well as a dissection of any vulnerability(ies) to our nation’s armed forces if such occurs. Determine how the NTIB may be effected if foreign M&As occur with US firms. Synopsize the production plan and technology used. Analyze the potential of how advanced technology can be acquired to slash cost(s). Detail performance and production requirements. Discern barriers and how they will be eliminated. Decipher commercial, modified or custom status of goods and/or services required to complete the buy.

Industrial Capability

Describe if industry will incur any transformation from peacetime to wartime to or during the production phase or post-production phase to satisfy the solicitation that was put out. Synopsize or provide the IC plan. Discuss any technology changes for the conversion from peacetime to wartime. Determine how crisis situations will be handled (e.g. essential services, inherently governmental functions, specialized military training, foreign delivery & anti-terrorism protection).

Contract Administration During Contingency Operations

Address how the contract will be administered in such a situation. Dissect how austere situations will be diverted. Address Combat Commander/Joint Force Commander protocol for delivery in part or in full. Account for quick closeout and project rollover or turnover. Discuss how SPOT will be maintained and kept current. Decipher how human trafficking will be snuffed out and eradicated if discovered.

Software & Software Maintenance

See DFARS 212.212.

Procurement Support For Theater Security Cooperation Efforts

When planning such (e.g. military training/exercises, base operations, weapons procurement, aviation fuels, construction or the POTUS’ plan for AIDS relief) COs should understand that DOS, embassies and consulates do not provide contracting support unless the buy is not complex. COs should consult DOS Cable 11 State 030953 and PGI 225.78, request guidance from the Combat Command Coordinator on past buys in similar situations, contact the embassy/consulate CO before the buy is executed (DOS mission support, local sources of supply, payment procedures, DOS payment support & determine DoD reach back) and be sure to not specify restrictive places of performance.

Component Breakout

Agencies must perform their own breakout plans in accordance with acquisition thresholds ($10M or greater for development, $50M cumulative /$25M per FY for production/services & at agency discretion). They must also earmark all future buys that require an acquisition plan. COs must write a broken out acquisition plan when applicable and specified (They will have to write one anyway even in case of pm neglect.). The PM has final review. The CO/SMEs write the breakout plan. The PMs final decision includes an assessment of risk, cost savings and technical and administration factors. The awardee assesses the in-house plan.

The acquisition team must query if an awardee is capable of future production, if a data and/or license package available for government usage if quality control is available outside of the awardee, if technical support will be provided and by whom, if multiple production sites will hamper standardization, if breakout will infringe upon corporate initiatives and how such may effect production, if breakout will endanger delivery requirements, if advanced funding is available for breakout components, if the buy is sole source, if GFP/GFE are availe, if potential financial risks are acceptable and if breakout is fiscally responsible. The answers to such questions will determine if breakout is an viable option for a DoD purchase.

Records

Files must be kept for historical purposes regarding components and breakouts. Evidence shows potential for breakout, those buys set aside for breakout and which components have previously been subject to breakout as well as those ensured of breakout. Records are signed by the PM. Records must contain any analysis, calculations tradeoffs and synopsis of the purchase.

Numerous hours were spent researching and synopsizing this document. Writing one of these acquisition plans may not be as bad as it seems (it may be, though). Because the CO can easily place “N/A” with any section that does not apply. God help you if they all do. I say this because I remind you that the CO treats their acquisition plan as a living document throughout the course of the purchase. They have to revise every time changes occur. 

Like I said, we wrote a standard version of an acquisition plan near the beginning of my training at the VA Acquisition Academy. We didn’t write one at the FSS for the VA although the value of their base contracts would warrant such. The manner of their acquisition strategy did not. I know what goes into these, and I know that the CO takes painstaking measures as to not have to revise this. Sometimes, stuff happens and you do. Life goes on.

If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation. 

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