HHS's Acquisition Planning Policy: A Waste of Time?

In recent years, HHSAR has been implementing a policy that requires all acquisitions over $250K to have a written acquisition plan (AP) that covers everything in FAR 7.105. However, many individuals involved in the acquisition planning process are beginning to question the effectiveness and relevance of this policy.

The main issue with HHS's policy is that it does not explicitly state what needs to be covered in the AP. This lack of clarity has led to a situation where acquisition planners are forced to include unnecessary information, which can be time-consuming and wasteful. For example, an acquisition plan for purchasing $500K Dell Computers from NASA SEWP would require a 20+ page document.

Furthermore, HHS's policy is not tailored to the specific needs of OPDIVs like mine. We rarely use FAR 15 procedures or award contracts. Instead, we mostly do commercial fixed-price contracts using existing government-wide vehicles such as GSA, NITAAC, and Best-In-Class. This means that the vast majority of our acquisition plans are unnecessary and a waste of time.

In addition to being wasteful, HHS's policy can also be counter-productive. By requiring unnecessary information in the AP, it can lead to a lack of focus on what is truly important. For instance, actual acquisition projects and programs that cover multiple contract actions do not have acquisition plans at all. This means that the most critical aspects of the project are being ignored.

It seems that HHS or anyone involved has failed to consider the potential consequences of their policy. By ignoring the needs of OPDIVs like mine, they are creating unnecessary work for us and potentially harming our ability to fulfill our mission effectively.

In conclusion, HHS's acquisition planning policy is in dire need of reform. It is time-consuming, wasteful, and counter-productive. We need a more tailored approach that takes into account the specific needs of OPDIVs like mine.

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