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How To Ask A Question
By Vern Edwards"A question. Since before your sun burned hot in space and before your race was born, I have awaited a question." Star Trek, the Guardian in "The City on the Edge of Forever." Early on in college I realized that questions were the gateway to learning. I didn't put questions to my professors very often. I asked them mainly of myself, then learned by looking for answers. It took time, which was murder under the quarter system of the University of California. (I swear, I don't think they were trying to teach us anything, just move us through the process.) I learned that I had to ask good questions. Dumb questions (and there is such a thing as a dumb question) were the gateway to nowhere. But what's a good question? I have long believed that the ability to ask good questions is one of the most important skills that a contract specialist must master. The ability to ask good questions is essential to learning the various facets of the work and to doing the work well. Suppose you are planning to negotiate a sole source contract price and you have received a price proposal and certified cost or pricing data. You've conducted a preliminary cost analysis and developed a list of questions. The time has come for face-to-face fact-finding. Your philosophy is that cost analysis is just reverse cost estimating. In order to develop a pre-negotiation objective you intend to disassemble the contractor's cost estimate and profit objective, understand them, assess their reasonableness, put them back together and see what you get, then develop your negotiation plan. You're sitting in the contractor's facility, across from their lead negotiator and the other members of its team. They are waiting for you. The intend to be honest. They will answer you truthfully, but they are not going to help you ask and they are not going to be forthcoming. If you want information, you are going to have to ask for precisely what you want. So, what's your first question? * * * Wifcon Forum long ago transitioned from a true discussion forum into a Q&A website, and much like someone passing through Elizabeth Kubler Ross's stages of grief at the prospect of death, I have transitioned from shock, through anger and annoyance, to disappointment and depression, and finally to acceptance of what seem to me to be a lot of poor quality questions. I'm not the only one who thinks so. Some of us discuss the problem often, but behind the scenes. What do I mean by "poor quality"? The best way to answer that is to show you some examples, all asked by persons who posted anonymously, without any user name, more than a decade ago. Here's one from early 2003: Here is another, from December, 2000: Here is another, also from 2000: All punctuation as in originals. I wish I could say that those are rare examples, but they are all too common. I could have used a few from last week, but I didn't want to hurt anyone's feelings. I'm sure that those questions made perfectly good sense to those who asked them. They might make good sense to some of you who are reading this blog post. But not to me. Okay, so what makes a question "good"? As it turns out, that is not as easy a question to answer as you might think. I wanted to write a well-reasoned answer to my own question, which itself might be a dumb question, so over the course of the past several months I have read extensively and sometimes deeply in the theory of questions. (The theory has a name: erotetics) and the practice of questioning. It is an important part of logic, science, rhetoric, law, and semantics, and works range from the highly technical, such as Belnap, The Logic of Questions and Answers (Yale, 1976) and Harrah, "A Logic of Questions and Answers," Philosophy of Science, Vol. 28 (1961) pp. 267-273, to those that are more readily accessible to nonspecialists, such as the entry, "Questions," at the Stanford Encyclopedia of Philosophy, http://plato.stanford.edu., the entry "Questions," in The Encyclopedia of Philosophy, Vol. 7 – 8, and in The Theory of Questions: Erotetics through the Prism of its Philosophical Background and Practical Applications, by Anna Brożek (Rodopi, 2011). A search of the internet led me to a lot of advice about how to ask a good question. You can find an example of such advice (a pretty decent one) at this site: http://faculty.gvc.edu/ssnyder/121/Goodquestions.html You can find another example here: http://www.dummies.com/how-to/content/ten-tips-for-asking-good-questions.html The advice strikes me as sound, though not entirely satisfying. Recently, however, I came across something that stopped me in my tracks -- a short article by Wendell Johnson (1906 – 65), "How to Ask a Question," published in Journal of General Education in April, 1947, republished in ETC: A Review of General Semantics (Winter 1948), and published again in a retrospective in ETC: A Review of General Semantics (Fall 1983). You can find it here: http://www.jstor.org/stable/42576616?seq=1#page_scan_tab_contents, but you need a subscription or access through a university or public library. It's very short, only five pages, but dense. The author packed a lot of thinking into those pages. You have to read deeply. I have added it to my list of essential reading for contracting practitioners. Because it may not be readily accessible by all, here are a few quotes to give you the flavor of the thing: But my favorite quote in the piece, and one of my all-time favorite quotes, is this: Yep, my question, "What is a good question?", was a fool's question. So I'm going to refine it. That might take me a while. In the meantime, give Wendell Johnson's article a read. It will be well worth your time and thought.
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The SBA has finalized its "universal" mentor-protege program for all small businesses.
In a final rule scheduled to be published in the Federal Register on July 25, 2016, the SBA provides the framework for what may be one of the most important small business programs of the last decade–one that will allow all small businesses to obtain developmental assistance from larger mentors, and form joint ventures with those mentors to pursue set-aside contracts.
First things first: while I've been using the term "universal" mentor-protege program for the last year and a half, the SBA apparently has had a change of heart when it comes to terminology. The SBA now calls its new program the "small business mentor-protege program," so that's what I'll call it, too, from now on.
The SBA's final rule creates a new regulation, 13 C.F.R. 125.9, entitled "What are the rules governing SBA's small business mentor-protege program?" The new regulation sets forth the framework of the small business mentor-protege program.
Program Purpose
The SBA broadly explains the purpose of the new program in this way:
The small business mentor-protege program is designed to enhance the capabilities of protege firms by requiring approved mentors to provide business development assistance to protege firms and to improve the protege firms' ability to successfully compete for federal contracts. This assistance may include technical and/or management assistance; financial assistance in the form of equity investments and/or loans; subcontracts (either from the mentor to the protege or from the protege to the mentor); trade education; and/or assistance in performing prime contracts with the Government through joint venture arrangements. Mentors are encouraged to provide assistance relating to the performance of contracts set aside or reserved for small business so that protege firms may more fully develop their capabilities.
Just like the longstanding and popular 8(a) mentor-protege program, the new small business mentor-protege program creates a framework under which mentor firms will provide a wide variety of potential benefits to their proteges.
Qualification as Mentor
As a general matter, "[a]ny concern that demonstrates a commitment and the ability to assist small business concerns may act as a mentor and receive benefits " from the mentor-protege program. Mentors may be large or small businesses.
In order to qualify, a prospective mentor must demonstrate that it is capable of meeting its commitments to the protege. The SBA will evaluate a prospective mentor's financial health, such as by reviewing the mentor's tax returns, audited financial statements, and/or SEC filings (for publicly traded companies). A mentor must "[p]ossess good character" and cannot appear on the government's list of debarred or suspended contractors. Once approved, a mentor must "annually certify that it continues to possess good character and a favorable financial position."
A mentor "generally" will have only one protege at a time. However, "SBA may authorize a concern to mentor more than one protege at a time where it can demonstrate that the additional mentor-protege relationship will not adversely affect the development of either protege (e.g., the second firm may not be a competitor of the first firm). While mentors may, with SBA permission, have more than one protege, "Under no circumstances will a mentor be permitted to have more than three proteges at one time . . .." In its commentary, the SBA explains:
SBA continues to believe that there must be a limit on the number of firms that one business, particularly one that is other than small, can mentor. Although SBA believes that the small business mentor-protege program will certainly afford business development to many small businesses, SBA remains concerned about large businesses benefiting disproportionately. If one firm could be a mentor for an unlimited number (or even a larger number) of proteges, that firm would receive benefits from the mentor-protege program through joint ventures and possible stock ownership far beyond the benefits to be derived by any individual protege.
Importantly, the "three-protege limit" is an aggregate of proteges under the small business mentor-protege program and the separate 8(a) mentor-protege program. In other words, if a mentor already has two proteges under the 8(a) mentor-protege program, the mentor would be limited to a single additional protege under the small business mentor-protege program.
If control of a mentor changes (such as through a stock sale), the mentor-protege agreement can continue under the new ownership. However, after the change in control, the mentor must "express[] in writing to SBA that it acknowledges the mentor-protege agreement and [certify] that it will continue to abide by its terms."
Finally, in its proposed rule, the SBA suggested that a firm could not be both a mentor and a protege at the same time. In my public speaking on the mentor-protege program, I questioned this proposal, noting that a firm may be well-established in one line of work, but require mentoring in a secondary line of work. For instance, a company may be a longstanding, well-established plumbing contractor, and well-positioned to mentor a firm in that industry–while at the same time requiring mentoring to break into electrical work.
Perhaps the SBA was listening, because the final rule deletes that restriction. The final rule provides that "SBA may authorize a small business to be both a protege and a mentor at the same time where the firm can demonstrate that the second relationship will not compete with or otherwise conflict with the first mentor-protege relationship."
Qualification as Protege
To qualify as a protege, a company "must qualify as small for the size standard corresponding to its primary NAICS code or identify that it is seeking business development assistance with respect to a secondary NAICS code and qualify as small for the size standard corresponding to that NAICS code." However, if the prospective protege is not a small business in its primary NAICS code, "the firm must demonstrate how the mentor-protege relationship is a logical business progression for the firm and will further develop or expand current capabilities." Further, "SBA will not approve a mentor-protege relationship in a secondary NAICS code in which the firm has no prior experience."
The portion of the final regulation involving secondary NAICS codes is an important change from the SBA's proposed rule. The SBA initially proposed that a protege would be required to qualify as small in its primary NAICS code, and could not obtain a mentor if that standard wasn't met. The final rule appropriately recognizes that a small business may desire mentorship to develop in a new or secondary line of work carrying a larger NAICS code (think of a plumbing contractor that wants to expand to general contracting, for example).
A protege ordinarily will have no more than one mentor at a time, although the SBA may approve a second mentor where certain conditions are met. In no case will the SBA approve more than two concurrent mentors for any single protege.
Written Mentor-Protege Agreement Required
In order to participate in the mentor-protege program, "[t]he mentor and protege firms must enter into a written agreement setting forth an assessment of the protege's needs and providing a detailed description and timeline for the delivery of the assistance the mentor commits to provide to address those needs . . .."
Interestingly, as in the 8(a) program, the parties must "[a]ddress how the assistance to be provided through the agreement will help the protege firm meet its goals as defined in its business plan." I say "interestingly" because 8(a) program participants are required to submit 8(a)-specific business plans to the SBA; other small businesses are not. It's unclear, then, whether this regulation implicitly requires prospective proteges to have written business plans (which of course is a best practice, and often required for various types of financing–but still, not all small businesses have written business plans).
The mentor-protege agreement must provide that the mentor will provide assistance to the protege for at least one year. However, the agreement must also provide "that either the protege or the mentor may terminate the agreement with 30 days advance notice to the other party . . . and to SBA."
The written mentor-protege agreement must be approved by the SBA before it takes effect. Additionally, the SBA "must approve all changes to a mentor-protege agreement in advance, and any changes made to the agreement must be provided in writing." If changes are made to the mentor-protege agreement without the SBA's permission "SBA shall terminate the mentor-protege relationship and may also propose suspension or debarment of one or both firms . . .."
The SBA states that it will "establish a separate unit within the Office of Business Development whose sole function would be to process mentor-protege applications and review MPAs and the assistance provided under them once approved." If this office becomes overwhelmed with applications (a concern a number of commenters raised in response to the proposed rule), SBA could consider using "open enrollment periods" in which mentor-protege applications would be accepted. The final rule does not establish any open enrollment periods at this time, however.
Term of Mentor-Protege Agreement
A single mentor-protege agreement "may not exceed three years, but may be extended for a second three years." The SBA's apparent intent is to cap, at six years, the length of time that two companies can be involved in a small business mentor-protege relationship.
In its commentary, the SBA explains:
The mentor-protege program should be a boost to a small business's development that enables the small business to independently perform larger and more complex contracts in the future. It should not be a crutch that prevents small businesses from seeking and performing those larger and more complex contracts on their own.
Annual Reporting
Small business proteges must make annual reports to the SBA. Within 30 days of the anniversary of the SBA's approval of the mentor-protege agreement, the protege must make a report concerning the previous year, including a detailed list of assistance provided by the mentor, federal contracts awarded to the mentor-protege as joint venturers, and so on. The protege must also submit a narrative "describing the success each assistance has had in addressing the developmental needs of the protege and addressing any problems encountered."
The SBA will review the protege's annual report to determine whether to reauthorize the mentor-protege agreement (provided that it has not expired). However, no news is good news: "nless rescinded in writing as a result of the review, the mentor-protege relationship will automatically renew without additional written notice or continuation or extension to the protege firm."
If the SBA determines that the mentor has not provided the promised assistance, the SBA will give the mentor the opportunity to respond. If the SBA is unconvinced by that explanation (or if the mentor offers no explanation), the SBA will terminate the mentor-protege agreement and bar the mentor from acting as a mentor for two years. The SBA may also take other actions to penalize the mentor.
After the mentor-protege relationship has concluded, the SBA will require the protege to submit a final report to the SBA about "whether it believed the mentor-protege relationship was beneficial and describe any lasting benefits to the protege." If the protege fails to submit the report, the SBA will not approve a second mentor-protege relationship, either under the small business mentor-protege program or the 8(a) mentor-protege program.
Joint Venturing
The small business mentor-protege program allows the mentor and protege to form joint ventures and compete for set-aside contracts based solely on the protege's size:
A mentor and protege may joint venture as a small business for any government prime contract or subcontract, provided the protege qualifies as small for the procurement. Such a joint venture may seek any type of small business contract (i.e., small business set-aside, 8(a), HUBZone, SDVOS, or WOSB) for which the protege firm qualifies (e.g., a protege firm that qualifies as a WOSB could seek a WOSB set-aside as a joint venture with its SBA-approved mentor).
The SBA must approve the joint venture agreement before a mentor-protege joint venture may avail itself of the special exception from affiliation provided by the small business mentor-protege program. The joint venture agreement, in turn, must satisfy the requirements of another new regulation the SBA has finalized, which will be codified at 13 C.F.R. 125.8. And because this blog post is already approaching "War and Peace" length, we'll discuss those new joint venturing requirements in a separate post.
According to the final regulation, "[o]nce a protege firm no longer qualifies as a small business for the size standard corresponding to its primary NAICS code, it will not be eligible for any further contracting benefits from its mentor-protege relationship." In my mind, though, this prohibition is inconsistent with the SBA's decision to allow proteges to qualify for the small business mentor-protege program based on secondary NAICS codes. If outgrowing the primary NAICS code precludes joint venturing for set-aside contracts carrying NAICS codes with higher size standards, the value of mentorship in a secondary NAICS code is greatly diminished. Perhaps the SBA will clarify this piece of the rule moving forward.
The final rule provides that "a change in the protege's size status generally does not affect contracts previously awarded to a joint venture between the protege and its mentor." The SBA specifies that "[e]xcept for contracts with durations of more than five years (including options), a contract awarded to a joint venture between a protege and mentor as a small business continues to qualify as an award to small business for the life of that contract and the joint venture remains obligated to continue performance on that contract." For contracts with durations of more than five years, recertification will be required as provided for in 13 C.F.R. 124.404(g)(3)
Affiliation Exception
As is the case under the 8(a) mentor-protege program, the small business mentor-protege program provides a broad "shield" from affiliation. The SBA's new regulation states that "[n]o determination of affiliation or control may be found between a protege firm and its mentor based solely on the mentor-protege agreement or any assistance provided pursuant to the agreement." The affiliation exception is not unlimited, however. The new regulation provides that "affiliation may be found for other reasons set forth" in the SBA's affiliation regulation, 13 C.F.R. 121.103.
Transfer of 8(a) Mentor-Protege Agreements
The final rule provides that when a protege graduates or otherwise leaves the 8(a) Program, but continue to qualify as small, that protege "may transfer its 8(a) mentor-protege relationship to a small business mentor-protege relationship." The mentor-and protege do not need to reapply, but must "merely inform SBA" of the intent to transfer the mentor-protege relationship to the small business mentor-protege program.
The Road Ahead
The SBA's new small business mentor-protege program will become effective 30 days after the final rule is officially published on July 25. Whether the SBA will begin accepting applications in late August, however, remains to be seen.
The small business mentor-protege program will be a game-changer in the world of small business contracting. For small and large contractors alike, now is the time to get working to take advantage of this extraordinary new opportunity.
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If you have been working on GSA Schedules for the past few years, you may remember that in May 2012, GSA's initiative was the end of the Schedule Input Program (SIP) and the mandatory use of the new Formatted Price List (FPL) for the Financial and Business Solutions (FABS) Schedule. There was much excitement generated by this news as we were all ready for the end of SIP. In January 2014, GSA announced that FABS would no longer utilize the FPL and all vendors were to return to SIP. As we look into the years ahead, I am optimistic that eventually the Formatted Product Tool (FPT) will truly be the end of SIP.
What is the FPT?
FPT is a systems upgrade that will be activated within the existing eOffer and eMod platforms and NOT in a separate application. There will be an automatic upload of products and prices to GSA Advantage!
The General Services Administration (GSA) Federal Acquisition Service (FAS) is planning to implement the FPT across the Multiple Award Schedules (MAS) program beginning with select pilot Schedules in late July 2016.
The order of the FPT rollout, with approximately two week intervals, is as follows:
- Schedule 58 I – Professional Audio/Video
- Schedule 72 – Furnishings & Floor Coverings (to be released with Schedule 58 I)
- Schedule 75 – Office Products/Supplies
- Schedule 73 – Food Service, Hospitality & Cleaning Equipment
- Schedule 51 V – Hardware Superstore
- Schedule 70 – Information Technology Products, Software & Services
What Do I Have to Do?
If you accept the FPT, you will be required to complete the one-time "rebaselining" of price list data as well as other data fields for proper display of these items. GSA can then ensure all of your currently awarded products are uploaded to GSA Advantage! For baselining, the contractor will utilize a provided template in eMod to submit all awarded products and associated product data, to include Manufacturer Part Number (MPN) and Universal Product Code Type A data, when applicable. All descriptive information required by SIP will be captured in one submission via eMod and uploaded to GSA Advantage!. This will become your FSS Price List upon execution of the modification.
If you accept the FPT bilateral modification, you will have 60 days to complete the rebaseline process. Please note that with the FPT, Contracting Officers will now have additional data analytics and transparency in helping them determine that pricing is fair and reasonable. Phase I of FPT is focused on collecting standard part numbers for items on Schedule.
Is Participation Mandatory?
No. At this time, acceptance of the upcoming Schedule Refresh/Mass Modification is optional if you are on one of the pilot Schedules. However, FPT will soon be mandatory for all new offers on product Schedules.
Does FPT Include Products and Services?
No. Phase 1 of this pilot program only includes products. If you have both products and services on the pilot schedule (such as IT 70), you are to enter the product information in the FPT pricing template and enter the services information in a text file. Both documents are to be uploaded via FPT, but in different file formats.
My recommendation is to completely understand the FPT process prior to accepting the upcoming Refresh Solicitation/Mass Modification for one of the pilot schedules. Continue to follow GSA Interact for updates on the Formatted Product Tool and for notice of the Refresh Solicitation/Mass Mod release.
I highly recommend attending the next GSA FPT training by registering for the next webinar on July 27, 2016 from 1:00pm – 3:00pm ET.
About the Author:
Maureen Jamieson
Executive Director of Contracts and Consulting
Maureen Jamieson has more than twenty-five years of experience managing federal contracts. She is highly experienced in solving client pricing problems and implementing effective pricing strategies for placing products and services on GSA Schedule contracts.
The post The Exit of SIP and Entrance of the Formatted Product Tool appeared first on Centre Law & Consulting.
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In January 1944, the Office of Strategic Services, a wartime intelligence agency and predecessor to the modern Central Intelligence Agency (CIA), issued Strategic Services Field Manual No.3 (Simple Sabotage Field Manual) to its agents to aid the Allied war effort in Europe. The purpose of the classified document was to explain the technique of simple sabotage, outline its possible effects, and present suggestions for inciting and executing it. It introduced the concept of simple sabotage as follows:Quote
Sabotage varies from highly technical coup de main acts that require detailed planning and the use of specially trained operatives, to innumerable simple acts which the ordinary individual citizen-saboteur can perform. This paper is primarily concerned with the latter type. Simple sabotage does not require specially prepared tools or equipment; it is executed by an ordinary citizen who may or may not act individually and without the necessity for active connection with an organized group; and it is carried out in such a way as to involve minimum danger of injury, detection, and reprisal.
The manual goes on to describe two types of simple sabotage: destructive and nondestructive. Regarding the latter type, the manual explains that—Quote
"It is based on universal opportunities to make faulty decisions, to adopt a non-cooperative attitude, and to induce others to follow suit. Making a faulty decision may be simply a matter of placing tools in one spot instead of another. A non-cooperative attitude may involve nothing more than creating an unpleasant situation among one's fellow workers, engaging in bickerings, or displaying surliness and stupidity.
This type of activity, sometimes referred to as the 'human element,' is frequently responsible for accidents, delays, and general obstruction even under normal conditions. The potential saboteur should discover what types of faulty decisions and non-cooperation are normally found in his kind of work and should then devise his sabotage so as to enlarge that 'margin for error.'"
The manual has a section titled "Specific Suggestions for Simple Sabotage" that provides suggestions for how to execute simple sabotage for different targets. There are suggestions on how to innocently start fires in buildings, set off automatic sprinklers to ruin warehouse stock, change sign posts at intersections and forks, dilute gasoline with water, wine, or urine so it won't combust, and other Dennis the Menace type hijinks. What seemed most familiar were the suggestions under "General Interference with Organizations and Production." Here are a few:Quote
(a) Organizations and Conferences
(1) Insist on doing everything through "channels." Never permit short-cuts to be taken in order to expedite decisions.
(2) Make "speeches." Talk as frequently as possible and at great length. Illustrate your "points" by long anecdotes and accounts of personal experiences. Never hesitate to make a few appropriate "patriotic" comments.
(3) When possible, refer all matters to committees, for "further study and consideration." Attempt to make committees as large as possible—never less than five.
(4) Bring up irrelevant issues as frequently as possible.
(5) Haggle over precise wordings of communications, minutes, resolutions.
(6) Refer back to matters decided upon at the last meeting and attempt to re-open the question of the advisability of that decision.
(7) Advocate "caution." Be "reasonable" and urge your fellow conferees to be "reasonable" and avoid haste which might result in embarrassments or difficulties later on.
(8) Be worried about the propriety of any decision—raise the question of whether such action as is contemplated lies within the jurisdiction of the group or whether it might conflict with the policy of some higher echelon.
(b) Managers and Supervisors
(9) When training new workers, give incomplete or misleading instructions.
(10) To lower morale and with it, production, be pleasant to inefficient workers; give them undeserved promotions. Discriminate against efficient workers; complain unjustly about their work.
(11) Hold conferences when there is more critical work to be done.
(12) Multiply paper work in plausible ways. Start duplicate files.
(13) Multiply the procedures and clearances involved in issuing instructions, pay checks, and so on. See that three people have to approve everything where one would do.
(14) Apply regulations to the last letter.
(c) Office Workers
(7) Spread disturbing rumors that sound like inside dope
(d) Employees
(4) Pretend that instructions are hard to understand, and ask to have them repeated more than once. Or pretend that you are particularly anxious about your work, and pester the foreman with unnecessary questions."
The manual was declassified in 2008, but I suspect it fell in to enemy hands long before that. The question is, though, why is the enemy targeting Federal contracting offices?
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"A question. Since before your sun burned hot in space and before your race was born, I have awaited a question."
Star Trek, the Guardian in "The City on the Edge of Forever."
Early on in college I realized that questions were the gateway to learning. I didn't put questions to my professors very often. I asked them mainly of myself, then learned by looking for answers. It took time, which was murder under the quarter system of the University of California. (I swear, I don't think they were trying to teach us anything, just move us through the process.)
I learned that I had to ask good questions. Dumb questions (and there is such a thing as a dumb question) were the gateway to nowhere.
But what's a good question?
I have long believed that the ability to ask good questions is one of the most important skills that a contract specialist must master. The ability to ask good questions is essential to learning the various facets of the work and to doing the work well.
Suppose you are planning to negotiate a sole source contract price and you have received a price proposal and certified cost or pricing data. You've conducted a preliminary cost analysis and developed a list of questions. The time has come for face-to-face fact-finding.
Your philosophy is that cost analysis is just reverse cost estimating. In order to develop a pre-negotiation objective you intend to disassemble the contractor's cost estimate and profit objective, understand them, assess their reasonableness, put them back together and see what you get, then develop your negotiation plan.
You're sitting in the contractor's facility, across from their lead negotiator and the other members of its team. They are waiting for you. The intend to be honest. They will answer you truthfully, but they are not going to help you ask and they are not going to be forthcoming. If you want information, you are going to have to ask for precisely what you want.
So, what's your first question?
* * *
Wifcon Forum long ago transitioned from a true discussion forum into a Q&A website, and much like someone passing through Elizabeth Kubler Ross's stages of grief at the prospect of death, I have transitioned from shock, through anger and annoyance, to disappointment and depression, and finally to acceptance of what seem to me to be a lot of poor quality questions. I'm not the only one who thinks so. Some of us discuss the problem often, but behind the scenes.
What do I mean by "poor quality"? The best way to answer that is to show you some examples, all asked by persons who posted anonymously, without any user name, more than a decade ago. Here's one from early 2003:Quote
We had a FP purchase order for support services that ended 9/30/02. We did not use all of the funds on the PO. We sent a final invoice to the gov't for the remaining money not spent.
I don't have experience with a FP Purchase Order so I hope you can clarify this for me.
The invoice references FAR Part 16.202-1 which states:
A firm-fixed-price contract provides for a price that is not subject to any adjustment on the basis of the contractor's cost experience in performing the contract. This contract type places upon the contractor maximum risk and full responsibility for all costs and resulting profit or loss. It provides maximum incentive for the contractor to control costs and perform effectively and imposes a minimum administrative burden upon the contracting parties.
Is there another FAR part that allows for us to bill for the remaining funds? Thanks. I appreciate your help[.]
Here is another, from December, 2000:Quote
What is the standard to apply when calculating an equitable adjustment for a deductive change?
We have a situation where a change was made to a construction contract that reduced the quantity of an estimated quantity CLIN by approximately 50%. The contractor submitted a REA for the change. The REA was for a share of the cost savings that resulted from the deleted work. Essentially, the contractor is saying that he is entitled to share in the cost savings because he found a way to do the work more efficiently than originally planned.
I've never seen an approach to a deductive change like this. Is it proper?
Here is another, also from 2000:Quote
What paragraphs of FAR 52.212-4 can be used for modification authority in block C of the SF 30 when modifying a delivery order written against a commercial contract? If the Government does not accept nonconforming services, why would it not be appropriate for the CO to use 52.212-4(a), Inspection/Acceptance, to deobligate what now are excess funds. Second part to this question. When can the modification authority for a delivery order ride on the modification authority used for the basic contract when the revisions to a contract have to be carried over to the delivery order.
All punctuation as in originals.
I wish I could say that those are rare examples, but they are all too common. I could have used a few from last week, but I didn't want to hurt anyone's feelings.
I'm sure that those questions made perfectly good sense to those who asked them. They might make good sense to some of you who are reading this blog post. But not to me.
Okay, so what makes a question "good"? As it turns out, that is not as easy a question to answer as you might think.
I wanted to write a well-reasoned answer to my own question, which itself might be a dumb question, so over the course of the past several months I have read extensively and sometimes deeply in the theory of questions. (The theory has a name: erotetics) and the practice of questioning. It is an important part of logic, science, rhetoric, law, and semantics, and works range from the highly technical, such as Belnap, The Logic of Questions and Answers (Yale, 1976) and Harrah, "A Logic of Questions and Answers," Philosophy of Science, Vol. 28 (1961) pp. 267-273, to those that are more readily accessible to nonspecialists, such as the entry, "Questions," at the Stanford Encyclopedia of Philosophy, http://plato.stanford.edu., the entry "Questions," in The Encyclopedia of Philosophy, Vol. 7 – 8, and in The Theory of Questions: Erotetics through the Prism of its Philosophical Background and Practical Applications, by Anna Brożek (Rodopi, 2011).
A search of the internet led me to a lot of advice about how to ask a good question. You can find an example of such advice (a pretty decent one) at this site:
You can find another example here:
The advice strikes me as sound, though not entirely satisfying.
Recently, however, I came across something that stopped me in my tracks -- a short article by Wendell Johnson (1906 – 65), "How to Ask a Question," published in Journal of General Education in April, 1947, republished in ETC: A Review of General Semantics (Winter 1948), and published again in a retrospective in ETC: A Review of General Semantics (Fall 1983). You can find it here: http://www.jstor.org/stable/42576616?seq=1#page_scan_tab_contents, but you need a subscription or access through a university or public library.
It's very short, only five pages, but dense. The author packed a lot of thinking into those pages. You have to read deeply. I have added it to my list of essential reading for contracting practitioners.
Because it may not be readily accessible by all, here are a few quotes to give you the flavor of the thing:Quote
Even among college upper classmen and graduate students one finds in varying degrees a naive belief that there are knowers -- that the way to get the answer to a question is simply to ask the man who knows it.
* * *
[T]he techniques of fruitful inquiry necessarily involve certain ways of using language, particularly in the framing of questions. Just any old string of words, arranged grammatically and with an interrogation mark at the end, won't do.
* * *
[A]n answerable question is one that implies the observations, or reliably reported observations, needed to answer it. Any question that does not meet this test -- any question, that is, for which no specifications are supplied as to the particular observational procedures to be used in answering it -- is to be classified as meaningless for purposes of fruitful inquiry, as nonsense from an investigative point of view. From a psychiatric point of view it may be richly meaningful, of course. This is to say that anyone who can analyze and interpret such a question in a way that clarifies the confusion of the one who asks it qualifies, to this extent, as a psychiatrist . Anyone who unhesitatingly answers the question, without recognizing its meaningless character, qualifies as surely as a fool . One may, with benefit, regard this as one of the more important items in that vast category known as useful but seldom used information.
* * *
The fundamental skill to be taught is that of specifying the procedures to be used in making the observations needed to answer any questions one asks -- and in specifying the terms in which the observations are to be reported . Except as the questioner provides these specifications, he can hardly expect anyone else to divine what he is asking, nor can he be depended upon to recognize the answer himself if by some odd chance it should appear.
But my favorite quote in the piece, and one of my all-time favorite quotes, is this:Quote
It is known almost as widely as it is disregarded that a fool is one who knows the answers to the questions that only a fool would ask. It follows that effective insurance against becoming a fool oneself lies in knowing what sorts of questions and answers these might be. It would appear reasonable to assume, on this basis, that a major responsibility of our schools and colleges is that of providing adequate instruction in the techniques of fruitful inquiry.
Yep, my question, "What is a good question?", was a fool's question. So I'm going to refine it. That might take me a while. In the meantime, give Wendell Johnson's article a read. It will be well worth your time and thought.
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Had you ever speculated on why April Fools' Day seems to be such an important day for federal acquisition? After all, consider some of the regulatory and policy issuances on that day:
The Federal Acquisition Regulation (FAR) became effective on April Fools' Day (1984).
The Federal Aviation Administration became exempt from the FAR on April Fools' Day (1996).
The Office of Federal Procurement Policy (OFPP) memorandum on "Protests, Claims, and Alternative Dispute Resolution (ADR) as Factors in Past Performance and Source Selection Decisions" was issued on April Fools' Day (2002).
Army Federal Acquisition Regulation Supplement (AFARS) Revision #25 was issued on April Fools' Day (2010).
FAR Case 2010-015 on the Women-Owned Small Business (WOSB) Program was published in the Federal Register on April Fools' Day (2011).
No doubt a little research would provide a number of additional examples.
Frankly, if it were me, April Fools' Day would probably be the last day that I would pick for issuing important regulations or policy statements. That is one day that I would avoid like the plague. [Note: The last statement is not technically correct, I would go to greater extremes to avoid the plague than to publish an acquisition policy or procedure on April Fools' Day.] Why not just wait a day, and avoid all the innuendo and snickering? After all, consider, April has 29 other days that are perfectly suitable for issuing regulations, policies, procedures, guidance and information.
Comparison of Major Contract Types
For example, on Monday, April 25, 2016, the Defense Acquisition University/Defense Systems Management College updated the Acquisition Community Connection with a revised version of its Comparison of Major Contract Types (i.e., Comparison of Major Contract Types - April 2016). [For those who would like a direct link: https://acc.dau.mil/CommunityBrowser.aspx?id=214513.] The new version better aligns with the terminology in the Contract Pricing Reference Guides, updates the charts on the reverse, and adds a chart on "Achieving a Reasonably Challenging but Achievable (RCA) Target Cost," one of topics discussed extensively in the new Guidance on Using Incentive and Other Contract Types.
Over the years, various versions of the "Comparison" have been fairly popular (i.e., 94,863 Page Views and 80,840 Attachments Downloaded. Although, given the number of personnel in the Defense Statutory Acquisition Workforce Contracting Career Field, 29,690 as of the 2nd quarter of 2015, those Lifetime Activity numbers may not be all that high, relatively speaking.
The April Fools' Day Announcements for 2016
So, it can be done. However, this April Fools' Day (2016) Defense Procurement and Acquisition Policy (DPAP) elected to issue two important pieces of procedures/guidance to the Defense Statutory Acquisition Workforce:
Guidance on Using Incentive and Other Contract Types (April 1, 1016).
Department of Defense Source Selection Procedures (SSP) (April 1, 1016).
The Guidance
Both documents have their warts. For instance, the Guidance incorrectly identifies one of the two statutory references for limitations on negotiation of price or fee. The good news is that thee one applicable to the DoD was identified correctly. Running the Spelling and Grammar checker one last time would not have been amiss.
Warts aside, the results of this Better Buying Power (BBP) are somewhat disappointing. The Specific Action in the USD(AT&L) memorandum "Implementation Directive for Better Buying Power 2.0 - Achieving Greater Efficiency and Productivity in Defense Spending" was, "Director, DP will provide a draft policy guidance document on the use of incentives in contracting to the BSIG for review by July 1, 2013. The starting point for this document will be the DoD and NASA Guide, "Incentive Training (sic) Guide," originally published in 1969."
For those of you unfamiliar with the Incentive Contracting Guide, it was the last of a number of such guides published in the 1960s. That particular version of the Guide was 252 pages. By comparison, the new Guidance is 41 pages. About 40 % of the Guidance is devoted to negotiation of fixed-price incentive (firm target) (FPIF) contracts in a sole-source environment a discussion of Reasonably Challenging but Achievable Target Cost (RCA), which go hand-in-hand. The coverage for Time and Materials/Labor Hour (T&M/LH) Contracts amounts to a paltry nine (9) lines. Ask yourself these two questions, "How many sole-source FPIF contracts does the Department award? If 'T&M is the least preferable contract type,' where should the emphasis have been placed?"
For those of you who need guidance on structuring multiple incentive contracts the DOD and NASA Guide: Incentive Contracting Guide 1969 may be a better bet than the new Guidance. The good news is that it is still available on the Defense Acquisition University's Acquisition Community Connection. [For those who would like a direct link: https://acc.dau.mil/CommunityBrowser.aspx?id=189615.]
The Procedures
The updated Source Selection Procedures are more than 505 longer than the previous version. The Procedures would have benefited from fact checking, copy editing and proof reading. Another warts issue.
Warts aside, for those of you who will be involved in DoD source selections that meet the thresholds in the Procedures, you will want to give it a thorough read. Among other things, you will see some new descriptions of adjectival ratings and a new source selection procedure in APPENDIX B, "TRADEOFF SOURCE SELECTION PROCESS: SUBJECTIVE TRADEOFF AND VALUE ADJUSTED TOTAL EVALUATED PRICE (VATEP) TRADEOFF." The latter came about as the result of USD(AT&L) memorandum "Implementation Directive for Better Buying Power 2.0 - Achieving Greater Efficiency and Productivity in Defense Spending." Under the heading of Better define value in "best value" competitions there was a Specific Action, "Director, DP will review the 'Process Manual' developed by the joint Service team led by the Air Force and present a recommendation for adoption with any recommended changes to the BSIG by July 1, 2013." You need to read the entire section to understand the direction. No doubt you will see a good deal of discussion about VATEP percolating up.
Understand that although the Guidance and Procedures were issued on April Fools' Day, they are no joke. Read them carefully, and implement them wisely.
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All of us can probably agree that each year seems to go by faster than the year before. The older we become, the rate at which we age seems to increase. So now, with 2016 upon us, (and without providing a comprehensive listing of new contracting laws, statutes, regulations, personnel changes, or best practices during 2015), perhaps it's best to simply summarize and reflect on what 2015 might signify regarding acquisition success. Let's also not use the "R" word even though talking about acquisition reform keeps us blog writers and consultants busy.
Some initiatives that began with great fanfare are no longer around. The government almost "closed" again, although the list of program exceptions to shutdowns is now so large that many don't notice. Those programs with greater lobbying power are essential, while many very worthy programs are used as pawns. Probably the greatest damage to government contracting, dwarfing any new legislative improvement, is the indecisive nature and short-term environment under which government programs must operate.
GSA launched initiatives in category management, including its acquisition gateway, eBuy Open and other initiatives intended to improve contracting officer market knowledge and vehicles available to meet specific needs and better leverage government buying power.
The Department of Defense says it's at a 35-year best in controlling costs for major acquisition programs and bestowed a variety of 15 individual and five organization awards for the past year. Heidi Shyu stepped down as the Army's acquisition executive and off of the acquisition "bus," where she coined the analogy that all acquisition program "passengers" have a brake and steering wheel, but no gas pedal.
Legislation intended to improve the current process within information technology is underway and new legislation within DoD was passed. It will be sometime before it is clear how well these latest changes have performed.
Discussion with today's acquisition leaders reveals a determination to do the right thing as best as possible despite the peripheral (beyond acquisition) system challenges at each step. This past year may best be remembered for cyber security breaches; new and enhanced multiple-crises emanating from the Middle East; successful space probes and retrieval; cyclones, earthquakes, and changing climates; gun violence from Tunis to California; and a never-ending political campaign.
For contracting managers, the faster nature of societal change and news cycles may mask the great strides being made to respond more effectively to ever-changing government requirements and outsourcing needs. Ineffective conference, education, and industry communication restrictions appear to be abating. However, lengthy debate over government salary, bonuses, or predetermined solutions to unresearched acquisition problems continues.
From a contracting standpoint, 2015 may not be momentous in terms of single legislation or headlines. However, the complexities and challenges of successfully navigating today's acquisition environment—from reduced spending to cyber security to Federal Reserve policy to the sheer complicated nature of the business enterprise itself—continues to grow. The requirements are harder, and the solutions harder still. Contractors supporting the government (and indeed the government itself) have a more difficult time understanding how to prepare, respond, and execute to these ever-evolving challenges. From workforce to technology, uncertainty is increasing and proven solutions decreasing. A new workforce is growing up in an environment of more employment uncertainty, from challenges to the education they've received to the manner of training and on-the-job experience they need.
However, we should all be impressed by the professionals working within this environment and what they accomplish. They don't have time to publicly write or promote their efforts, but they are there and are noble. The year 2016 promises to be no easier than 2015. Our contracting leaders and managers are up to the challenge, but let's understand for ourselves the causes and concerns, offer our advice and support, and be part of the solution.
Michael P. Fischetti
Executive Director
National Contract Management Association
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The Competition in Contracting Act of 1984 requires the Government Accountability Office (GA0) to report to the U. S. Congress annually when government agencies fail to fully implement its bid protest recommendations. GAO has posted these reports on its website since fiscal year (FY) 1995. Initially, these reports provided little information but by FY 2004, GAO published its "Bid Protest Statistics" covering FY 2004 through 2001. I have added every one of these reports to the fiscal year numbers at the top of the bid protest statistics.
Beginning in its report for FY 2013, GAO began listing its "most prevalent reasons for sustaining protests" during the FY. This has continued for FY 2014 and FY 2015. Although the information provided does not include cases where an agency took corrective action before a formal sustained decision was reached, it does provided information on 227 sustained decisions. In that sense, it may provide some help whether you are trying to prevent a protest or whether you may protest a procurement.
Below is my ranking of the most prevalent reasons for sustained protests listed by GAO for FY 2015 through FY 2013:
- failure to follow the evaluation criteria (listed 3rd in FY 2015 and 1st in FYs 2014 and 2013).
- unreasonable cost or price evaluation (listed 1st in FY 2015 and 4th in FY 2013) and
- inadequate documentation of the record (listed 4th in FY 2015 and 2nd in FY 2013)
- unequal treatment of offerors (listed 4th in FY 2014 and 3rd in FY 2013)
- unreasonable technical evaluation (listed 5th in FY 2015 and 3rd in FY 2014)
This ranking also requires a caveat because the number of sustained protests varied significantly for FY 2015 (68), FY 2014 (72), and FY 2013 (87).
Other reasons for sustained protests GAO listed include
- unreasonable past performance evaluation (listed 2nd in FY 2015)
- flawed selection decision (listed 2nd in FY 2014)
In addition to listing the most prevalent reasons, GAO also gives 1 example decision for each of the most prevalent reasons it lists in a FY. For example, under unreasonable cost or price evaluation which GAO placed first in FY 2015, GAO lists Computer Sciences Corp.; HP Enterprise Servs., LLC; Harris IT Servs. Corp.; Booz Allen Hamilton, Inc., B-408694.7 et al., Nov. 3, 2014, 2014 CPD ¶ 331.
My listing of each decision that GAO provided as a most prevalent reason with a link to the decision is here.
To me, the most striking reason for GAO sustaining a protest is inadequate documentation. That can be prevented by a thorough review of what documents are provided in the evaluation and selection decision. If there is something missing, identify it and correct it. You can get more information on the documentation issue by looking at the Wifcon.com protest page FAR 15.305 (a)(3): Technical Evaluation - Documentation.
Another striking reason for sustained protests is the first that I list--failure to follow the evaluation criteria. One time a friend of mine was sitting on an evaluation panel for a GAO procurement that I had no involvement in at all. He had something extra he wanted to include in his evaluation of proposals and he asked me about it. Although I was stunned at the question, I simply told him that he must follow the evaluation criteria in the solicitation and if he had any questions he should ask the contracting officer--not me.
Before ending this entry, I will once again remind you that the information provided by GAO only includes sustained protests. These are decisions in which the agency digs in its heels and fights the protest to a final decision. As GAO explains, "agencies need not, and do not, report any of the myriad reasons they decide to take voluntary corrective action." What you see here may be the tip of the iceberg.
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The long-standing principle that the federal government had the same implied duty of good faith and fair dealing as any commercial buyer was put in jeopardy by a 2010 decision of the U.S. Court of Appeals for the Federal Circuit, Precision Pine & Timber, Inc. v. U.S., 596 F.3d 817 (Fed. Cir. 2010). There a panel of the court adopted a narrow rule seemingly limiting application of the principle to situations where a government action was "specifically targeted" at the contractor or had the effect of taking away one of the benefits that had been promised to the contractor. Although the decision concerned a timber sales contract not a procurement contract, when I wrote it up in the May 2010 Nash & Cibinic Report (24 N&CR ¶ 22), I expressed the fear that the reasoning would be subsequently applied to procurement contracts.
My fear was realized in a construction contract case, Metcalf Construction Co. v. U. S., 102 Fed. Cl. 334 (2011). In that decision, the judge described eggregious conduct on the part of the government officials that would have been held to be a breach of the implied duty of good faith and fair dealing under many earlier cases. However, the judge held that under the Precision Pine standard, the contractor had not proved that the actions were specifically targeted at the contractor. In the February 2012 Nash & Cibinic Report (26 N&CR ¶ 9), I criticized this decision but stated that I believed that even if the decision was affirmed on appeal, most contracting officers would not take this as a signal that the proper way to administer contracts was to abuse the contractor.
Fortunately, a panel of the Federal Circuit has reversed the decision, Metcalf Construction Co. v. U. S., 2014 WL 519596, 2014 U.S. App. LEXIS 2515 (Fed. Cir. Feb. 11, 2014). The court held that the lower court had read Precision Pine too narrowly and that "specific targeting" was only one example of the type of conduct that could constitute a breach of the implied duty of good faith and fair dealing. Importantly, the court also rejected the government's argument that this "implied duty" only could be found when it was footed in some express provision of the contract. The court concluded that the correct rule was only that the express provisions of a contract had to be examined to ensure that they had not dealt with the conduct of the government; for if they had, they would override the implied duty.
This leaves us in a tenuous position with regard to the views of the Federal Circuit. We have one panel in Precision Pine stating a narrow rule, another panel in Metcalf Construction stating the traditional rule, and a third panel in Bell/Heery A Joint Venture v. U.S., 739 F.3d 1324 (Fed. Cir. 2014), ruling in favor of the government because the contractor had not alleged facts showing that the government had "engaged in conduct that reappropriated benefits promised under the contract" (which is part of the Precision Pine reasoning). Thus, it is difficult to state where the judges of the Federal Circuit stand. Hopefully, the court will agree to take either Metcalf Construction or Bell/Heery to the full court for an en banc review of the issue.
I've never been sure why the Department of Justice has so vigorously argued that the government should not be held to the same standards of conduct as a commercial buyer. Of course, persuading the courts and boards that a narrower standard should be applied to the government is a way to win litigated cases. But, in my view, encouraging abusive or non-cooperative conduct hurts the government as much as it hurts its contractors. I have taught for many years that in the long run the government benefits from actions that show industry that it is a fair contracting partner. A line of published judicial decisions that demonstrates that the government is not such a partner is one more of the many messages that tell companies they should sell to the government only when they can find no other customer. Surely, this is not the message that government agencies in need of products and services on the commercial marketplace want to convey to companies that can provide those products and services.
Many years ago when I came to Washington to work in the field of government contracting, I concluded that there was one major advantage to being on the government side of the negotiating table. That advantage was that I was under no pressure to extract money from the contractor by unfair bargaining or unfair contract administration. To me fairness was an integral part of the job of a government employee. I still believe it and teach it. Thus, no matter what the outcome of the good faith and fair dealing litigation, I will continue to urge government employees that fair treatment of contractors is the only way to go.
Ralph C. Nash
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When I get older, losing my hair
Many years from now . . . .
When I'm Sixty-Four
John Lennon, Paul McCartney
Shortly after we celebrate our country's independence on July 4, 2013, Wifcon.com will end its 15th year on the internet. With much help from the Wifcon.com community, I've raised a growing teenager. When I started, I was 49 and my hair was so thick that I often shouted ouch or some obscenity when I combed it. Wifcon.com has existed in 3 decades and parts of 2 centuries. During that period, I've updated this site for every work day--except for the week or so when I called it quits. I remember the feeling of relief. I thought it was over. However, many of you convinced me to bring it back. Yes, just when I thought I was out, many of you pulled me back in.
As I mentioned in an earlier post, someone once told me that Wifcon.com was my legacy. I once had great hopes for a legacy. Perhaps, a great saxophone player belting out a solo in front of thousands of fans and seeing them enjoying themselves. Instead, here I sit in my solitude looking for news, decisions, etc., to post to the home page. For many years, my dog Ambrose kept me company. Now, my dogs Blue Jay and Lily stare at me and look for attention. With my sights now set realistically, I accept that Wifcon.com is my legacy. It's the best I could do.
Every now and then, I receive an e-mail from someone thanking me for Wifcon.com. They tell me how it helped their careers. These e-mails keep me and Wifcon.com going.
Send me a postcard, drop me a line,
Stating point of view
Indicate precisely what you mean to say
Yours sincerely, wasting away
Give me your answer, fill in a form
When I'm Sixty-Four
John Lennon, Paul McCartney
The thoughts in these e-mails won't let me quit. I still search each night for something to add to the site in hopes that it will increase your knowledge. If I find something new, I still get excited. Often, it feels like a self-imposed weight around my neck. What started as a release for my imagination has evolved into a continuing and daily addition to the contracting community. In the evenings, it is as if I'm Maillardet's automaton. I head over to my office, sit before the computer, and update. Then I send the updated pages to Virginia where it is accessed from around the world. Maybe I'm addicted to Wifcon.com; maybe I was born with the Wifcon.com gene.
If you haven't added the numbers, I'm 64 now. Wifcon.com and I are showing our age. I can comb the top of my head with my fingers. The ouches and other obscenities caused by my once thick hair are gone. A recent upgrade to the discussion forum requires that I turn the "compatibility mode" off on my browser. In that mode, I realized that Wifcon.com is ugly. I have current software for the needed future redo of this site.
I am Wifcon.com; Wifcon.com is me. It is my legacy and my albatross. As always, thank you for your support.
You'll be older too,
And if you say the word,
I could stay with you.
When I'm Sixty-Four
John Lennon, Paul McCartney
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text:
In This Section
Journal Forum
A Meta-Analysis of High Resolution Audio Perceptual Evaluation - June 2016
2 comments
Synthetic Reverberator - January 1960
3 comments
Sound Board: High-Resolution Audio - October 2015
4 comments
AES E-Library
Clavichord Amplification
Some of the limitations of electroacoustic amplification for a small clavichord have been studied. The conclusions are that a vibration pickup properly coupled to the soundboard or strings can provide more than a factor of 100 improvement in sound power output, thus making the clavichord somewhat competitive in this respect with a small piano.
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subset: commoncrawl


text:
When WP runs in debug mode (
define('WP_DEBUG', true); in wp-config.php) WordPress.com stats produces the following errors:
Notice: Undefined index: height in /mnt/web7/41/15/.../htdocs/opajaap/test/wordpress/wp-content/plugins/stats/stats.php on line 1013
and 3 times:
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Activating thr first time in debug mode is not possible because of "headers already sent".
Reactivating produces:
The plugin generated 376 characters of unexpected output during activation. If you notice "headers already sent" messages, problems with syndication feeds or other issues, try deactivating or removing this plugin.


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BRUSSELS — Betting that price concerns will stay with shoppers long after the economy improves, Delhaize said last week that it would continue making price investments in its Food Lion chain during 2011. More price investments were among a number of "concrete initiatives" slated for Food Lion this year, which officials said would capitalize on improving sales trends at the chain during the second half of the 2010 fiscal year. Although officials declined to provide specific details, they ...
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Anyone in Chico, CA ready to start moving??? Yesterday was a great day to start! (Did you get outside and enjoy the weather we had yesterday?)
Hello. My name is Sharon. I'm 28 years old and not exactly a beginner. I live in Chico and am always looking for a walking/jogging buddy. I had to search all 19 pages of California listings to find someone from Chico.
Also from Chico. You're right Sharon, not much in the way of Chicoan's on Active.com
I'm a new runner, still in the walk/run phase of things. I'm 25 years old and I may be a tad too slow for you, but it's better then nothing!
Make every step count. Poop before running. Follow my blog or on twitter @rachael_taylor if you want a good laugh at my sorry attempt to be "active"
ACTIVE is the leader in online event registrations from 5k running races and marathons to softball leagues and local events. ACTIVE also makes it easy to learn and prepare for all the things you love to do with expert resources, training plans and fitness calculators.


text:
Web posted Monday, November 23, 1998 2:00 p.m. CT
Debate on alcohol likely to continue
From wire reports
More research:
The debate about the health benefits of alcohol will undoubtedly continue. A recent study of 427 patients with heart disease in France found that alcohol increased total cholesterol and other heart risks, especially with a Western-type diet (compared with a Mediterranean diet, which emphasizes fruit, vegetables, fish and olive oil). Those researchers discouraged even moderate alcohol consumption by recent heart-attack patients.
Golf prep: If you've heard using those stretchy bands can help your golf game but aren't quite sure what to do with them, here's a possibility: The Thera-Band Exercise System for Golfers is a handy zippered nylon tube (smaller than a can of tennis balls) stuffed with two Thera-Band strips, a door anchor, two handles and an exercise guide with 20 exercises specifically for golfers.
What's new? The popular CRUNCH gyms in Manhattan have a new workout class that makes participants really feel the burn. Firefighter Training is a 75-minute session that simulates firefighter duties, from climbing stairs with a hose to hoisting equipment and carrying trapped victims to safety.
Epilepsy treatments:For 600,000 children in the United States, there is good news: a new wave of treatments for epilepsy has substantially improved the chances that medical care can prevent or reduce the effects of their seizures.
These new treatments include a new generation of drugs that can reduce unpleasant side effects and surgical procedures that can effectively control forms of epilepsy for which previous treatments were limited.
Until recently, epilepsy could only be treated with drugs that lowered electrical activity in the brain but risked problematic side effects, such as hyperactivity or tiredness. In cases where epilepsy did not respond to drugs - known as uncontrolled epilepsy - abnormal brain tissue in the area where seizures originated could be surgically removed, but only if the tissue was not in a part of the brain that controls vital functions, such as language or motor skills.
Now the arsenal for fighting epilepsy has expanded significantly. The first new weapons are more effective drugs, such as gabapentin, lamotrigine, topirimate and tiagabine. Each can prevent or greatly lower the frequency of partial and general seizures by reducing electrical activity in the central nervous system (CNS) and decreasing excitement in the brain. Unlike the older drugs, the new drugs often have fewer side effects, but some children may not tolerate certain newer drugs.
For children who cannot tolerate medication, or for whom pharmacological treatment is inappropriate, a new surgical procedure, multiple subpial transsection, treats uncontrolled epilepsy in areas of the brain that control vital functions. During the procedure, a series of stripped cuts are made in the cells surrounding the abnormal brain tissue where the electrical discharge begins, preventing the seizure from spreading and becoming more severe.
The vagal nerve stimulator is another new treatment that controls both partial and general seizures. The stimulator is a pocketwatch-sized device that works similarly to a pacemaker, but for the brain. Implanted in the upper left chest wall, it stimulates a nerve in the neck that modifies electrical discharges in the brain. The stimulator has been approved by the Food and Drug Administration for children 12 years or older, but physicians have found the treatment effective for children as young as 6 years old.
_uacct = "UA-2472207-1";
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text:
Italian fashion fabrics, I saw some prints from Just Cavalli, Robert Cavalli's lower prized line.
Shirtings and some intriguing double faced fabric.
A great geometric print that is apparently from Prada.
The selection was pretty good this year, though at least two regular fabric vendors were missing and the organizers still insist on letting room for things like mass made jeans (?) and weird cleaning devices like the ones you see on the TV-shopping channels. But the fabric selection just get better and better I think, with more high quality, unique fabrics. For instance I spotted some wonderful and rare linen/lycra knits that I now regret that I didn't buy. But I did buy a beautiful sherbet color embroidered cotton voile.
Can't wait for summer!
, by Johanna


text:
By Official Release
Posted May 3 2012 7:20PM
NEW YORK -- The 2012 NBA Draft Lottery will be held at the Disney/ABC's Times Square Studios in New York on Wednesday, May 30, and will be televised on ESPN at 8 p.m. EDT.
This year will mark the ninth time in the event's 28-year history that it is conducted in New York City and first since May 23, 1993, when the drawing was held at the Sheraton New York. The inaugural lottery was held on May 12, 1985 at the Waldorf Astoria Hotel, but since 1994, the event had been held at the NBA Entertainment Studios in Secaucus, N.J. however the league's facilities in New Jersey no longer house a television studio.
The NBA Draft Lottery's origins trace back to June 1984, when at an NBA Board of Governors meeting in Salt Lake City, the league voted to adopt a lottery system among the non playoff teams to determine the order of selection in the first round of the NBA Draft beginning in 1985.
Attached is the order of selection for the 2012 NBA Draft, as well as the number of chances for the teams in the 2012 NBA Draft Lottery.
* This pick may be conveyed to Portland.
# This pick may be conveyed to Utah via New Jersey.
The order for the the remainder of the first-round picks is as follows:
15. Philadelphia 35-31
16. New York (To Houston) 36-30
17. Dallas 36-30
18. Utah (To Minnesota) 36-30
19. Orlando 37-29
20. Denver 38-28
21. Boston 39-27
22. LA Clippers (To Boston via OKC) 40-26
23. Atlanta 40-26
24. LA Lakers (To Cleveland) 41-25
25. Memphis 41-25
26. Indiana 42-24
27. Miami 46-20
28. Oklahoma City 47-19
29. Chicago 50-16
30. San Antonio (To Golden State) 50-16
31. Charlotte
32. Washington
33/34. New Orleans (To Cleveland via Miami)
33/34. Cleveland
35/36. New Jersey (To Golden State)
35/36. Sacramento
37/38. Toronto
37/38. Golden State (To Denver via New York)
39. Detroit
40. Minnesota (To Portland via Houston)
41. Portland
42. Milwaukee
43. Phoenix (To Atlanta)
44. Houston (To Detroit)
45. Philadelphia
46. Dallas (To Washington)
47. Utah
48. New York
49. Orlando
50. Denver
51. Boston
52. Atlanta (To Golden State)
53. LA Clippers
54. Memphis (To Philadelphia)
55. LA Lakers (To Dallas)
56. Indiana (To Toronto)
57. Miami (To New Jersey)
58. Oklahoma City (To Minnesota)
59. San Antonio
60. Chicago (To New Jersey via Milwaukee or to LA Lakers via New Jersey and Milwaukee)
*Please note that teams that finished the regular season with identical records will select in the second round in the reverse of the order in which they select in the first round, provided, that if more than two teams are tied, then, as among the tied teams, each tied team will select one position earlier than it selected in the first round, except that the tied team that selected earliest in the first round shall, among the tied teams, select latest in the second round. With respect to the ties between Cleveland and New Orleans (21 and 45); New Jersey and Sacramento (22 and 44); and Golden State and Toronto (23 and 43): since the order of selection in the first round for this set of teams may change based on the results of the Draft Lottery, the order of selection in the second round cannot be determined until after the Draft Lottery is conducted.
|USAB: Carmelo Anthony
Watch this feature on Carmelo Anthony as he leads the U.S. Men's National team to the 2016 Olympics.
|Postgame: Paul George
Paul George speaks with NBA TV's Jared Greenberg following the USA's victory over Argentina.
|USA vs. Argentina
Kevin Durant scores 23 points, Paul George adds 18 with Carmelo Anthony putting in 17 as USA tops Argentina 111-74.
|Steal And Slam
Jimmy Butler gets the steal and feeds Paul George for the reverse slam in transition.
DeMarcus Cousins gets the steal after turning it over and Jimmy Butler converts down low, plus the foul.


text: home > thyroid center > thyroid a-z list > thyroiditis index Thyroiditis ThyroiditisRelated Medications « Back to Thyroiditis Index Sorted Alphabetically A-Z Sort by popularity dexamethasone levothyroxine sodium, Synthroid, Levoxyl, Levothroid, Unithroid, Tirosint, Levo-T liothyronine sodium, Cytomel, Triostat methimazole, Tapazole, Northyx prednisolone (Flo-Pred, Pediapred, Orapred, Orapred ODT) propylthiouracil Thyroid Replacement Hormones Sorted by Popularity (as on MedicineNet) Sort alphabetically Thyroid Replacement Hormones levothyroxine sodium, Synthroid, Levoxyl, Levothroid, Unithroid, Tirosint, Levo-T dexamethasone propylthiouracil liothyronine sodium, Cytomel, Triostat methimazole, Tapazole, Northyx prednisolone (Flo-Pred, Pediapred, Orapred, Orapred ODT) Suggested Reading on Thyroiditis by Our Doctors Related Diseases & Conditions 7 articles Hashimoto's Thyroiditis Hashimoto's thyroiditis is the most common cause of hypothyroidism in the US. This conditions is caused by inflammation of the thyroid gland. Symptoms Hypothyroidism Hypothyroidism is any state in which thyroid hormone production is below normal. Normally, the rate of thyroid hormone production is controlled by Hyperthyroidism Hyperthyroidism is an excess of Thyroid Disorders There are several types of thyroid disorders including hypothyroidism, hyperthyroidism, goiters, thyroid nodules, and thyroid cancer. Symptoms vary by Hypothyroidism During Pregnancy Hypothyroidism during pregnancy can be treated with synthetic thyroid hormones to maintain the proper thyroid hormone balance. Hypothyroidism symptoms Primary Biliary Cirrhosis (PBC) Primary Biliary Cirrhosis (PBS) Stiff-Person Syndrome Stiff-Person syndrome is a neurological disorder associated with features of an autoimmune disease. Signs and symptoms of Stiff-Person syndrome include Medications 7 articles Procedures & Tests 5 articles Pictures, Images & Quizzes 4 articles Doctor's & Expert's Views 5 articles Health News 2 articles Health Features 2 articles STAY INFORMED Get the latest health and medical information delivered direct to your inbox! From WebMD Healthy Resources Top Causes of Hearing Loss Help for Headache Pain Are Generics Just As Good? Featured Centers Feeling Short of Breath? What to Eat When You Have Cancer Top 3 Anaphylaxis Triggers Health Solutions From Our Sponsors Frequent Constipation? Greater Food Accessibility Exclusives What Does Psoriasis Look Like? How to Prevent Muscle Cramps Blood Clot? Know the Signs and Symptoms Allergy Triggers: Do You Know Yours?


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text:
IMDb > Lemur (Character)
Top Linksmain detailsbiographyby votesphoto galleryquotes
Filmographiesby yearby typeby ratingsby votesby TV seriesby genreby keyword
Did You Know?photo galleryquotes
Lemur (Character)
from Madagascar (2005)
The content of this page was created by users. It has not been screened or verified by IMDb staff.
|Related Videos (see all 6)
There may be more photos available for this character. To select more photos to be displayed in this character's gallery, click the Edit Photos link.
Alternate Names:
Lemur #1 / Lemur #2
FilmographyEdit Credits
There may be more credits available for this character. To edit the credits displayed or to add more credits to this character's filmography, click the Edit Credits link.
Jump to filmography: Video-game
- Madagascar: Escape 2 Africa (2008) Played by Tom McGrath / David Soren
... aka "Madagascar: Escape 2 Africa - The IMAX Experience" - USA (IMAX version)
... aka "Madagascar 2" - Japan (English title)
- Madagascar (2005) Played by Eric Darnell (as Lemur #1) / David P. Smith (as Lemur #2)
- Madagascar (2005) (VG) Played by John Kassir / Quinton Flynn / Kat Cressida
Additional Details
Plot Keywords:
You may correct errors and omissions on this page directly. Clicking the 'Update' button will take you through a step-by-step process.


text:
Communities (6)
Top Network Posts
- 29Is it bad to cook frozen meat without waiting it to be unfrozen?
- 27What is the following cooking utensil used for?
- 18How can I keep a cheesecake from cracking?
- 14Why are baking measurements such nice round numbers?
- 13How to make hot dog buns or sandwich rolls with a soft crust?
- 12Can I still eat this fish?
- 12How to store homemade pasta
- View more network posts →
Keeping a low profile.
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text:
Tried on multiple sites and hosts, never got it to work. So there's obviously a conflict somewhere.
Support is minimal so moving on
Tried on multiple sites and hosts, never got it to work. So there's obviously a conflict somewhere.
Support is minimal so moving on
Hi Dave, it is very strange that you never got the plugin to work. So many have had a great success including myself on different servers with different Host.
It would be interesting to find out where is the conflict coming from within your website and server.
I trying to understand this part...
Support is minimal so moving on
From what I read in your support thread which you posted 3 days ago, you received plenty of support. So I am not sure what you mean by your comment above. Do you think that you should have received more support?
Kind regards
Support is minimal so moving on
Is referring to the email I got. Not to this particular thread. The point is the dev asked me to email him. I did. And from that point the support fell apart.
Yes, I understand free support etc. But a one line email without referring to the question I asked is lacklustre when I was asked to by the dev to send the email in the first place.
Yes, I agree it's very strange I cannot get this plugin to work. Hence I asked the dev if there were known plugin conflicts which would explain the across the host issue of not getting it to work.
I understand that this is plugin has been a success for many according to the stats here. This is why I wanted it to work. And this is why I initial wrote here and did not give up on it.
Hi Dave, I understand your point and appreciate your patience.
The developer Emre Vona is doing as much as he can to get his plugin in the current state it is. It is receiving great reviews and praise from many users. He will work out your issue if you give him enough time.
From all the support threads here Emre Vona has replied very fast and fixed most problems instantly. However situations like yours, might take a bit more time.
If you are willing to give this plugin another go, I am sure Emre Vona will fix your issue.
My humble opinion.
Kind regards
By the way I am in no way affiliated with the plugin or the developer.
but it is written on the FAQ page.
Does Wpfc work with WPMU (WordPress Multisite) properly?
No. Wpfc does not support WordPress Multisite yet.
Why didn't you read before voting?
Hi Dave, did you read my lat post?
I do not use WPMU
ok. Can you explain your problem shortly please?
The same as
I emailed you and you said to just try another plugin, have things changed?
Do you use BP security plugin?
can you send me your theme please? email@example.com
Dave, I wanna solve this problem as soon as possible
Just, sent. First mail bounced
I couldn't find it. can you send me please again?
Sent again
I couldn't get it.
Well, post another email address if yours is not working
I wrote cm instead of com :)
I've sent again
your mailbox has a problem. I cannot send email.
Hi, I'm still getting mail.
Just sent a new one to you with my htaccess, could you try again please
ok I wrote you
Didn't get anything. And, I'm getting regular mail
I wrote again now
we need to talk with skype
I don't have the internet for skype
Delivery to the following recipient failed permanently:
Technical details of permanent failure:
Google tried to deliver your message, but it was rejected by the server for the recipient domain gmail.com by gmail-smtp-in.l.google.com. [2607:f8b0:4001:c05::1b].
The error that the other server returned was:
552-5.2.2 The email account that you tried to reach is over quota. Please direct
552-5.2.2 the recipient to
552 5.2.2 http://support.google.com/mail/bin/answer.py?answer=6558 um8si301286icb.69 - gsmtp
smtp is an outgoing server. Sounds like it might be your mailbox? I'm receiving and sending mail here no problems.
This topic has been closed to new replies.


text:
0 ReviewsWrite a Review
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text: Posted October 29, 2012 Mid-season head coach firings generally only serve to turn already bad seasons into even worse ones. Not a huge stretch to think Rivera gets fired at the end of the year (though I still dont know if it's settled yet) but mid-season would be a mess. 1 person likes this Share this post Link to post Share on other sites


text:
The British Fireworks Championships take place each year at the Hoe in Plymouth. This year's event takes place between the 18-19 August.
This is a two-day event where some of the country's top fireworks display organisers compete against each other to be crowned the best.
The event this year includes a display from the Royal Air Force's Red Arrows as it celebrates its 19th showdown.
Organisers will be hoping for dry, clear, windless evenings to ensure preparations go to plan. The hundreds of thousands of spectators will be hoping for clear skies so they get to enjoy the full spectacle of the event.
Check the Plymouth weather forecast before heading to see the firework competition.
Back to the events calendar.
18-19 August - Check the Plymouth weather forecast before going to the British Firework Championships.
For more information on the event, visit the British Firework Championships official website.
You can check the weather forecast for other events through the events calendar.
If you're looking for content for your own website, take a look at our weather widget.


text:
All posts by Srirachana
Our 5 unique takes (with photos) looking back on the better weekend of Coachella — the last one.
Kygo, Galantis, and us… We were there! Here's a rundown.
A$AP Rocky appeared + we tried on their new game-changing VR headsets. (Photos!)
Watch for the multiple zombie mating dance breaks. Does he win the girl?
Get to know the newest opening artist for the Drake vs. Lil Wayne Tour.
Surprise set list, surprise wardrobe malfunction, surprise all-new encore freestyle… (listen) #GWHHReview
They did not come out to just play crowd pleasers. #GWHHReview
Eminem, Outkast, Childish Gambino, Chance the Rapper, and many more!
Srirachana attends the hottest ticket party in SXSW, the famed ILLMORE.
Watch video and read our in-depth review of Gambino's tour in Chicago last night. "That was deep." — Childish Gambino
@Srirachana reports with the best shows, parties, and new artists we saw at SXSW!


text:
Royal Matcha Green Tea (240g)
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Customer Reviews Write a Review
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Product Overview
Enjoy the splendor, color and intoxicating smell of Royal Matcha green tea. Let its beautiful hue and lovely scent invigorate your senses. This really is a royal tea of green tea leaves ground by granite to make a fine powder for your enjoyment and is easily prepared. Its stone ground preparation also affords it all the nutrition it naturally possesses without compromise making it one of the highest quality teas available. Royal Matcha is the greenest of all green teas and has a lovely jade hue. It is used for tea ceremonies which date back to twelfth century Japan, where it has been an integral part of the Japanese culture and lifestyle. This royal tea will wow you with its subtle sweetness, easy preparation and nutrient richness. The nutritional benefits of Royal Matcha tea are many, which is why the Japanese people have such a long life expectancy. It offers the health benefits of L-theanine which increases energy without caffeine jitters, improves mental alertness, reduces stress and increases calmness. It's super antioxidant richness provides you with the natural anti-aging activity, boosts metabolic rate and lowers cholesterol and blood pressure. Not only that, Royal Matcha tea contains cancer-fighting and cancer-preventative nutrients (polyphenols and catechins). Due to high levels of dietary fiber which are easily absorbed by the body, it minimizes the symptoms of PMS and relieves constipation.And that is not all! Royal Matcha stabilizes blood sugar levels, has anti-biotic and anti-viral qualities, as well as the ability to detoxify blood. With all these amazing benefits, all you need is to drink a cup of Red Leaf Tea's Royal Matcha tea everyday.
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NewsDemon Newsgroups Review
Newsdemon is at the top of its class offering a suite of plans to accommodate almost any budget. Plans start from $7.00 to $19.95 and
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text:
Capitol Hill Critics Second-Guess Agencies Using...
Co-Sourcing Improves Pharmaceutical Laboratory Productivity
Loss of Lives in Clinical Trials...
Keep the Opportunities, Lose the Opportunists
Boehringer Ingelheim today responded to an earlier FDA warning letter faulting the company for not sufficiently investigating and correcting "significant violations" of current good manufacturing practice (cGMP) for active pharmaceutical ingredients (APIs) and finished pharmaceuticals found during an inspection last year at BI's Rhine, Germany plant.
"Boehringer Ingelheim is taking this issue very seriously and is fully committed to working with the FDA on a comprehensive action plan that addresses the FDA's concerns, ensuring that it implements corrective and preventive actions to optimize its quality systems," Gerhard Koeller, Ph.D., BI's head of corporate division quality, promised in a statement.
Dr. Koeller added: "We are committed to compliance with current Good Manufacturing Practices requirements. We will invest all our energy to remedy the situation in order to meet all FDA requests, building on the experience gained from all 22 inspections successfully passed at the Ingelheim site in the last five years by different authorities around the world, other than the latest FDA inspection in November."
That inspection turned up instances of foreign particles in batches of APIs in 2008 and 2009, resulting in "adulterated" APIs and finished drug products in violation of cGMP, FDA said in its May 6 warning letter.
FDA chided BI for failing to thoroughly investigate critical deviations in API manufacturing to determine the source of the particles, and failing to implement "timely and appropriate corrective and preventive actions." The company responded to a 2010 complaint about a contaminated batch manufactured a year earlier by declaring the complaint "not confirmed," then ending the investigation without finding the contamination's root cause.
A year later, however, BI closed another complaint by confirming that similar contamination in one drum of an API lot was manufacturing-related.
BI was also faulted for failing to reject multiple batches of capsules contaminated with foreign particles in 2010 and last year. FDA said the company failed to determine the cause of the "out-of-specification" finding for a lot of once-daily COPD treatment Spiriva HandiHaler that failed a uniformity-of-delivered-dose test specification within the required nine-month stability interval.
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MDMA (commonly known as the empathogen "ecstasy") is classified as a Schedule 1 drug, which is reserved for compounds with no accepted medical use and a high abuse potential. Two researchers from Stanford, however, call for a rigorous scientific exploration of MDMA's effects to identify precisely how the drug works, the data from which could be used to develop therapeutic compounds.Do you agree that ecstasy should be studied for its potential therapeutic benefits?
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