Thread Subject: Re: Subpart A- Draft Document- Review and Comments Requested

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From: terry.weaver@gsa.gov
Date: Tue, Mar 20 2007 8:40 AM

My comments are integrated into Gregg's response below and prefaced by
(TW).





Hi Robert,

My concern with this new language is that it sounds very loose and open to
interpretation. Maybe I'm just not familiar with the terminology.


What does âagencyâs identified business and technical requirementsâ
mean? Is this the specs in the RFP? Or a broader âvalueâ list?
(TW) This approach seems to address the confusion many non-acquisition
TEITAC members have about how the Federal government conducts purchases -
it is incorporating the requirements definition phase of a procurement
into the Standard. From a Federal buyer perspective, I don't think it is
required but it can be useful for non-Federal buyers to understand that
incorporating Section 508 into our acquisitions means incorporating it as
one of our business and technical requirements.

Are these documented somewhere? It sounds pretty open ended. Agencies
may apply required and generally accepted procurement procedures in
accordance with governing procurement regulations to procurement
decision-making regarding such products.
(TW) Agencies have always been bound by their procurement regulations, in
most cases, that means the FAR. I think that the only reason to include
this statement here is to help non-Federal buyers understand that there
are procurement regulations that address a whole lot more than just
Section 508 and that they are also binding on the Federal buyer. I don't
see this language being incorporated into the FAR because it is redundant.



If we move to the FAR and to generally accepted practices â isn't that
less than what the old standards called for?

Thanks


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker,
Robert C.
Sent: Monday, March 19, 2007 9:21 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] Subpart A- Draft Document- Review and
Comments Requested
Recommendation:

(b) When procuring a product, each agency shall procure products, which
comply with the provisions in this part when such products are available
in the commercial marketplace, and the productâs utility and performance
meet the agencyâs identified business and technical requirements.
Agencies may apply required and generally accepted procurement procedures
in accordance with governing procurement regulations to procurement
decision-making regarding such products.
Explanation: Deleted "two or more" . This statement applies even if only
one product is available that meet's the agency's identified business and
technical requirements. Open competition does not guarantee that there
are more than one products available that address the agency's business
and technical needs - when described in conformance to FAR standards.

(c) Agencies cannot claim a product, as a whole is not commercially
available because no product in the marketplace meets all the standards.
If products are commercially available that meet some but not all of the
standards, the agency must select the product that best meets the agency's
business and technical needs as well as all the applicable Section 509
standards.

Explanation: This is the only definition that is consistent with the FAR.

Thanks,
Robert

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