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 (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
Justification for Sole Source Small Purchases– A document that is required for procurements valued from $2, 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
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 (a)(1)(ii) Prepare sole source justifications using the format at , 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:

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

25. Sources cont’d.
Robin Strohacker, Glenn Research Center
Susan McClain, Langley Research Center
Marlo Krisberg, Kennedy Space Center

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