Diane Sahakian, CBP Assistant Commissioner, Office of Acquisition, provided candid perspectives on CBP procurement developments and trends during her Border Security Expo comments on 12 March and her subsequent one-on-one discussion with DSJ.
Assistant Commissioner Sahakian advises the contracting community that she foresees the following ten developments:
- Less reliance on written proposals and greater use of oral presentations in CBP Procurements. (Ms. Sahakian would like to see 30% of CBP source selections stem from such oral presentations.)
- Greater “self-scoring” by contractors in CBP’s more complicated source selections. (Under such processes, offerors assess their own strength in categories including: relevant experience; past performance; systems, certifications, and clearances; and organizational risk.
- Post-award debriefings will be as transparent as possible. (Ms. Sahakian’s goal is that her organization provides every competitor is provided with all source selection information that is available yet not proprietary.)
- Growing limitations on DHS/CBP use of Low Price Technically Acceptable (LPTA) source selection criteria. (Ms. Sahakian believes that this stems from concerns over the resulting quality of LPTA-driven source selections.)
- CBP is seeing fewer protests of its source selection decisions and is winning nearly all of these protests when they do emerge. (Ms. Sahakian says that CBP is seeing fewer GAO protests and more Court of Federal Claims (CFC) protests. The CFC protests, she notes, result in significant delays in contract execution no matter how they are resolved.)
- CBP — and particularly the Border Patrol — is increasingly utilizing “Section 880” procedures to competitively procure innovative commercial items, technologies, and services using Commercial Solutions Opening (CSO) procedures. (Ms. Sahakian is confident that the $10 million cap on Section 880 awards will soon be raised to $25 million, which will give CBP greater flexibility.)
- CBP is establishing and advancing “Go Teams” to enable rapid procurement. (Ms. Sahakian notes that these team will be comprised of single-focused professionals to deliver mission sets more quickly (2-3 month) to operators. One areas of possible initial Go Team focus might be surveillance towers.)
- CBP has the authority to utilize Other Transactions Authority (OTAs), but Ms. Sahakian notes that CBP doesn’t do much R&D, so OTAs are not often in play.
- DHS is moving towards greater Strategic Sourcing, which will limit CBP procurement options and restrict competition in some measure.
- CBP Acquisition officials are working to improve their performance in two key areas: (a) More timely posting of business opportunities in the federal Government’s Acquisition Planning Forecast System (APFS); and (b) Catching up on its Contractor Performance Assessment Reporting System (CPARS) filings, where CBP is presently at 46% and is supposed to be at 98%.