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A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS

A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS. PIP Level 1 Raymond Jones. OBJECTIVES. Address issues with Justifications Discuss why Justifications are important Discuss when Justifications are necessary

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A GUIDE TO WRITING EFFECTIVE JUSTIFICATIONS

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

  2. OBJECTIVES • Address issues with Justifications • Discuss why Justifications are important • 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)

  3. DILEMMAS • Inadequate Regulatory Guidance • No adequate written guidance • Causes variation between Contracting Officers (CO’s) • 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. DILEMMAS cont’d • Inadequate justification of product or service • Poor planning • Lack of market research • No justifying reason to preclude competition

  5. WHY ARE JUSTIFICATIONS IMPORTANT? • Needless competition

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

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

  8. Definition • Justificationfor Sole Source SmallPurchases– 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. What Makes A Good Justification for Sole Source Simplified Acquisition?

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

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

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

  13. Definition • 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. What Makes a Good Justification for Specific Make and Model?

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

  16. What is a JOFOC?

  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.

  18. What are JOFOC requirements?

  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 • Be compliant with GSFC Procurement Circular 97-4 (available at: http://gsfc-artemis.gsfc.nasa.gov/210/flalpha.htm)

  20. JOFOC Requirements cont’d. • Facts and Rationale • Identification of Agency • Description of Item or Service • Description of supplies or service required • Statutory Authority • Contractor’s Qualifications

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

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

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

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

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

  26. SUMMARY • Addressed issues with Justifications • Discussed why Justifications are important • 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)

  27. Questions

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