So we noticed that the National Aeronautics and Space Administration (NASA) recently announced it has adopted the now-ubiquitous "Proposal Adequacy Checklist" under the guise of "reducing transaction costs in NASA procurements."

How lovely for the space agency that once led the vanguard with respect to technical innovation and derring-do, an agency that is now pretty much known as much for bureaucratic bungling as its technical successes (which largely derive from the dreams of crazy young scientists who succeed in spite of the constraints placed upon them by the bureaucrats). NASA's strategic mission has evolved from its October, 1958, founding focus on exoatmospheric space flight to … what? (Nobody knows for sure.) Since the agency has insufficient funding and few champions in Congress and no national mandate for its mission, it has cannily chosen to emulate the most efficient of all Executive Branch Departments: the Department of Defense.

They say imitation is the sincerest form of flattery.

NASA has adopted the Proposal Adequacy Checklist in spite of public input that opined-

… the proposed rule passed the administrative burden and shifted the associated costs directly onto the contractor which was inappropriate. Respondent suggested, as an alternative, that solicitations require standardized table of contents with a proposal.

The NASA rule-makers reviewed that comment, mulled it over, discussed it amongst themselves in a frank and thoughtful exchange of views, and responded as follows-

This rule does not impose additional requirements over what is already required under the conditions when certified cost or pricing data is required. This provision is a single uniform tool that is applicable across NASA to promote consistency in compliance with FAR Table 15-2.

Well, there you go. The rule does not impose any additional requirements. So shut up and follow it.

Which begs the question, of course, as to why the heck a rule-any rule-which "does not impose additional requirements," would even be necessary. One might reasonably think that a rule which does not impose additional requirements would not be necessary in the first place, and would be seen as a complete waste of the rule-makers' time. Promulgating a rule that does not add any additional requirements would seem to be the equivalent of gilding a lily, or shipping coals to Newcastle, or extolling the virtues of ice to Eskimos.

But of course the truth is the rule does impose additional requirements: it just imposes them on contractors and not on Federal officials. It requires contractors submitting certain proposals to NASA to fill out an onerous checklist that adds no value to anybody. At best, the Proposal Adequacy Checklist creates the illusion of the imposition of quality, because anybody can fill out that checklist and say anything, while in reality their proposals may still omit lots of required cost or pricing information. The simple truth is that a completed Proposal Adequacy Checklist is no guarantee of the underlying quality of the proposal accompanying it.

It's the Potemkin Village of proposal quality control.

Yet NASA thinks requiring such an illusion is going to somehow reduce agency costs associated with evaluating proposals. Does anybody reading this blog expect that to be the outcome?

And despite protestations to the contrary, NASA is adopting a Checklist that's also demonstrably redundant and unnecessarily burdensome. The DAR Council admitted as much when it recently revised the Proposal Adequacy Checklist "to remove a redundant item." Here's what the rule-makers said about their regulatory action-

Item 19 [of the Checklist] required price analysis for all commercial items offered that are not available to the general public. Through further research and discussion, DOD has determined that item 19 … is duplicative in nature. DoD has concluded that items proposed with a commercial basis under subcontracts in the proposal require price analysis by the offeror. Furthermore, DoD has also concluded that question 14 under the Material and Service section and question 17 under the Subcontracts section on the Proposal Adequacy Checklist currently address the requirement for price analysis of the proposed commercial item that is produced or performed by others.

Thus, after "research and discussion" the rule-makers finally concluded what the public told them nearly a year ago: the rule was hastily written and poorly thought-out. It imposed additional requirements of little or no value, and was going to lead to increased costs on the contractor side without any cost reductions on the Government side.

Accordingly, it's more than a little ironic that those Pentagon paper-pushers who ignored public input and essentially adopted DCAA's policy position(s) lock, stock and barrel have now requested public input into their review of "requirements which impact the efficiency of the acquisition process." This initiative is so important to DOD that it just published a Federal Register Notice to extend the public input period from 30 days to 70 days. While the DPAP folks point to statute as the basis for rules that impede efficiency, we ourselves would point to DPAP, DCAA and the DAR Council as significant contributors to the current moribund state of defense acquisition.

Hey, we're just sayin'.

And we're just sayin' that the asinine Proposal Adequacy Checklist is a great example of the imposition of illusory controls that add no value, and simply act to give DCAA a reason not to provide Contracting Officers with "field pricing assistance". And we're just sayin' that the FAR Case 2008-020, implemented in FAC 2005-52 is another great example of the imposition of burdensome rules that limited Contracting Officers' ability to close-out contracts rather than speed contract close-outs (which was the guise under which the rule was originally perpetrated).

What the two rules have in common is they act to shift DCAA's audit burden to contractors. They both give DCAA a checklist which guides auditors into concluding that the proposals are adequate for audit, or not. And if the auditors conclude that the proposal they are looking at is not adequate (as defined by the checklist rather than the exercise of professional judgment), then those auditors have a wonderful regulatory-based excuse for not auditing it.

This is the paragon of procurement efficiency that NASA has chosen to emulate.

Great job, NASA! We're sure that your auditors (which tend to be DCAA auditors, naturally) will be thrilled that they have another checklist to use.

The next step, of course, is for NASA to announce a thorough review of all regulatory requirements that drive up costs and impede efficiency. Unless they decide to wait for DOD to complete its review, which they can they adopt wholesale without any critical analysis whatsoever.