In this episode, Stephanie Wilson, Agreements Officer with the Army Contracting Command (ACC) Rock Island, joins Bonnie Evangelista to explore and demystify the complexities of the contracting process. They talk about how to eliminate unnecessary complications, the importance of statutes and guidebooks, and how industry and non-traditional contractors can more easily navigate this world. Tune in to nerd out on all things OTAs and get a crash course on how to stop pounding the round peg in the square hole.
TIMESTAMPS:
(2:35) Why creativity is stifled in contracting
(4:51) How to simplify contracts
(7:04) Why creating a similar language among branches is key
(12:58) Decentralizing decision-making
(16:06) Seeking ROI through nontraditional contracting
(21:39) How to find your place and fight for it
LINKS:
Follow Stephanie: https://www.linkedin.com/in/stephanie-wilson-790902237/
Follow Bonnie: https://www.linkedin.com/in/bonnie-evangelista-520747231/
CDAO: https://www.ai.mil/
Tradewinds AI: https://www.tradewindai.com/
Bonnie Evangelista [00:00:19]:
Stephanie Wilson.
Stephanie Wilson [00:00:20]:
Bonnie Evangelista.
Bonnie Evangelista [00:00:21]:
So I'm bonnie. I'm with the chief digital and AI office. I'm with Stephanie Me. Can you introduce yourself?
Stephanie Wilson [00:00:26]:
I'm Stephanie Wilson. I am an agreements officer with ACC.
Bonnie Evangelista [00:00:30]:
Rock island army contracting command, rock island.
Stephanie Wilson [00:00:32]:
Army contracting command, rock island.
Bonnie Evangelista [00:00:34]:
All right, Stephanie. I'm excited to talk to you.
Stephanie Wilson [00:00:38]:
Me too to you.
Bonnie Evangelista [00:00:41]:
Are you ready to nerd out? Are you comfortable?
Stephanie Wilson [00:00:43]:
I am. I'm comfortable.
Bonnie Evangelista [00:00:44]:
These chairs are insane.
Stephanie Wilson [00:00:45]:
I know. I mean, look at this thing. It's great. It's like a throne.
Bonnie Evangelista [00:00:49]:
Yeah. I feel like we're getting ready to do a slumber party.
Stephanie Wilson [00:00:51]:
I know, right? And we can talk, like, secrets and stuff and braid each other's hair.
Bonnie Evangelista [00:00:55]:
Yeah. No pillow fights. I'm not into that.
Stephanie Wilson [00:00:57]:
No.
Bonnie Evangelista [00:00:57]:
Okay.
Stephanie Wilson [00:00:58]:
Not down for the violence.
Bonnie Evangelista [00:00:59]:
Yeah. What do you want to talk about? Contracting.
Stephanie Wilson [00:01:02]:
Sure.
Bonnie Evangelista [00:01:03]:
Yeah, I heard you want to talk about you want to demystify the contracting world.
Stephanie Wilson [00:01:09]:
Yes.
Bonnie Evangelista [00:01:09]:
Does that resonate with you?
Stephanie Wilson [00:01:10]:
It does. Okay. It speaks.
Bonnie Evangelista [00:01:12]:
What do you want to demystify? What is so complex that we have to demystify?
Stephanie Wilson [00:01:19]:
I think, honestly, it's just the process in itself. I think that the contracting process has become such a machine that we have lost sight of the fact that this is not rocket science. This is a very, very easy thing to do. We have been given autonomy by Congress to do many different ways of contracting, many different pathways to award, and we have a tendency to just stand in our way.
Bonnie Evangelista [00:01:45]:
Can you give an example?
Stephanie Wilson [00:01:47]:
Policy in just general? So let's talk OTS. So other transaction authority.
Bonnie Evangelista [00:01:52]:
Thank you.
Stephanie Wilson [00:01:52]:
You're welcome. So, for OTS, we have a guidebook, and right now, they are looking at potentially putting more guidance on that at the local level.
Bonnie Evangelista [00:02:03]:
I mean, the local level.
Stephanie Wilson [00:02:05]:
Local level, meaning your particular command or maybe your agency, maybe your civilian agency that you work for, the people that you would interact daily with. So the policy would be the people that you would report to. So maybe your leadership has a certain way of looking at things, or maybe you have a policy branch that wants to make sure that certain things are in compliant. And so we could just layer the.
Bonnie Evangelista [00:02:29]:
Crap out of this.
Stephanie Wilson [00:02:31]:
Everybody in AI, they always talk about daisy chain.
Bonnie Evangelista [00:02:34]:
Right?
Stephanie Wilson [00:02:35]:
So anything within the It sector, you talk about daisy chain. We do that to ourselves with policy. We daisy chain our policy so that we just take away the ability for anyone to critically think and we just say, just do it this way, so shut up and color. And I think the ability to take away some of that and just let people understand, especially on the industry side, I think they are accustomed to the machine and what the contracting machine is. But you talk to anybody who's a non traditional contractor. So meaning like not your Lockheeds or your Boeings, but your mom and pop shops, small businesses that meetups yeah, startups, anybody who's new to government contracting, they don't even know where to start. And even if they do get into it, and they do start with it, they get lost. They become a cog in the machine. So there really isn't a whole lot that we do that should be that complicated and I really want to just get rid of that.
Bonnie Evangelista [00:03:38]:
Yeah. So you started with OTS, other transaction authority. How do we simplify the use practical application? Right. It's all about that. We can talk all day long, but how does someone who maybe doesn't understand or has never used it, or maybe they are using it and they're like, wait, I don't have to do it this way. What do you recommend to simplify it?
Stephanie Wilson [00:04:03]:
So one of the ways I would recommend is, first of all, read the guide and read the statute. So understand what I would clarify.
Bonnie Evangelista [00:04:10]:
I would read the statute first.
Stephanie Wilson [00:04:12]:
Well, that's true. Yeah. And then read the guide.
Bonnie Evangelista [00:04:14]:
Right, okay.
Stephanie Wilson [00:04:15]:
That makes more sense.
Bonnie Evangelista [00:04:16]:
Let's start with what is in law here's the statute.
Stephanie Wilson [00:04:19]:
Here's where your authority lies.
Bonnie Evangelista [00:04:21]:
Yes.
Stephanie Wilson [00:04:21]:
And then read the guide, which they have the new one out now. The 2023 just came out. Just came out june, I think.
Bonnie Evangelista [00:04:29]:
June or July.
Stephanie Wilson [00:04:30]:
Yeah, it was like two, three weeks ago.
Bonnie Evangelista [00:04:31]:
Yeah.
Stephanie Wilson [00:04:31]:
So came out with the new guidebook and basically they're talking about myths that we need to debunk, best practices that we have learned since the last guide came out in 2018, november of 2018. So reading those two things, you really have to read them with an open mind. You cannot have your branch chief in your head or your ses in your head or your policy department in your head. You have to read them for what they are. Just read the black and white, understand what the statute gives you permission to do, and read through the guidebook and see what other people are doing and say, okay, I could apply that. And then really what's going to happen is you're going to see that all the other junk that's been added into it, all those multiple layers that have been added on top of it, are people who are very uncomfortable with something being as simplistic and not being rocket.
Bonnie Evangelista [00:05:26]:
Science and not structured right.
Stephanie Wilson [00:05:28]:
It's an unstructured world and it's really incumbent upon the people who are using the OT to structure that unstructured environment.
Bonnie Evangelista [00:05:36]:
So how I think about the guide and we're deep diving a little bit into OTAs and we could talk about other authorities, but I think the framework still applies. You start with the statute, like, what do I absolutely have to do in this instance, for OTS, we do have a guide. The guide is not policy.
Stephanie Wilson [00:05:54]:
No, it's a guide. It's a guide.
Bonnie Evangelista [00:05:56]:
So it's giving you best practices or it's telling you how the department is thinking about OTS and it's trying to provide you possible ways to develop your strategy, like how you should be thinking. And actually it doesn't even tell you how. For me, when I read it, there's a lot of like, hey, you need to think about this. You need to think about IP, you need to think about market intelligence. And it's not meant to, I would say, give you the answer.
Stephanie Wilson [00:06:24]:
Right.
Bonnie Evangelista [00:06:25]:
It is still upon us in the community to develop the strategy. So with that in mind, that's where you were talking about. So on top of the guide, I think there's an expectation that that is also a policy document, but I won't say deviate, but that is not an absolute document, right? Yeah. And then on top of that, this is where maybe the services, they're like, oh, I'm going to write a policy for OTS that basically talks about like, this is the Air Force way of doing business when it comes to OTS and stuff like that. And that's where I think you're recommending, though we don't need to do that.
Stephanie Wilson [00:07:04]:
No, absolutely not. Because first of all, we silo ourselves so much within the service know, army does its army thing, navy does its Navy thing, air Force does its Air Force thing. And then even if you drill down, even into the service branches so for example, I'm army, even if you go down into the army, the components don't even talk to each other, let alone I don't even know what my people are doing down the hallway. I don't know all of their programs. So we're continuously siloed. So if we continuously policy on top of something that's been given to us by statute or a guidebook, a playbook, by any means, really, why would you want to continue to policy on that? Because what if we do things differently? Okay? What does that matter? We still achieved the end goal that the navy wanted or that the army wanted. Plus it makes it easier for industry to understand where everybody is coming from. So if we all use a similar language, please note that I did not say common nor standardized language, because we're not going to do that, but that we're all coming from the same basis, which means the statute and the guidebook that anybody in industry could then understand what the navy puts out for an OT. What the army puts out for an OT. That there would be similarities, that they understand what is to be expected from them. And I think that that would help a lot in demystifying what we do in contracting because of the fact that we do things so differently in each one of the service branches.
Bonnie Evangelista [00:08:36]:
Yeah, think about it. At an enterprise level, like what you're talking about. I'll just play devil's advocate. What you're talking about sounds amazing from an execution perspective. But from an enterprise level perspective, how do I manage that? I don't have standards. I don't have a standard way of doing business. So what would you say to maybe your enterprise leaders who are trying to grapple with the fact that maybe we do need to do things a little bit more unstructured? But then how do we reconcile the fact that I still have to run an enterprise organization, right?
Stephanie Wilson [00:09:11]:
And along with that, you're going to need things like metrics, you're going to need data. You're going to want to understand what is actually going on in this unstructured environment. So my big thing is that when you have something like that, then again, not only from the executioner or a practitioner standpoint, where they have to structure that environment to make it what it is for that particular action, you would do the same thing for that. Because again, you can still have information, you can still have data, you can still have metrics. But again, it doesn't need to be standardized. You can have an understanding from the enterprise level of what is actually happening and that is the structure that you would want to have for that particular enterprise. But again, it's not going to look like if another part of your command buys ammo, right, that could be very structured. It's not going to look the same. So we have to stop pounding the round peg in the square hole.
Bonnie Evangelista [00:10:09]:
Yeah, let's do another authority. Like what other authorities maybe are we overcomplicating that you would like to see more simplicity around?
Stephanie Wilson [00:10:18]:
So I think we're overcomplicating, yet underusing at the same time is 40 23 is ten USC. 40 23, which is the experimental for.
Bonnie Evangelista [00:10:27]:
Agreement purposes, procurement for experimental purposes. Talk about that. What is it?
Stephanie Wilson [00:10:31]:
So basically what that is, is it is an authority that allows us, people would argue whether it's an OT or not. It is definitely an agreement. I would say that it is at least in the same family as OTS, maybe not necessarily an OT, but in the same family.
Bonnie Evangelista [00:10:48]:
When you say same family, you mean from a practical application perspective and also.
Stephanie Wilson [00:10:53]:
Really from a USC. Standpoint as well, too, because of the similarities under 40 21, which is for applied and basic research for 40 22, which is your prototype and production OT. And then here comes along this kind of oddball at 40 23, which is for experimental purposes, it has very, very little regulation over it. And because of that, I think people get very scared because you already are scaring them enough with the unstructured environment in 40 21 and 40 22. But with experimental, there are some regulations and guidelines that you do have to follow left, right boundaries that you do have to follow. So for example, there needs to be a certain sector of the government that is going to use that experimental. I think one thing that kind of throws people off is that you don't need to use competition. There is no competitive basis for you.
Bonnie Evangelista [00:11:47]:
To there's no competition standard. Right? Yeah. You are allowed because it's an experiment, so that makes total sense. So you are allowed if you see a thing, you want to buy a thing and run an experiment, go by the thing, go buy the thing and learn. Right.
Stephanie Wilson [00:12:01]:
And I think because of that simplicity, our brains automatically overcomplicate it and we automatically say, okay, well that must mean that I have to do XYZ. We kind of start falling back into our old fact patterns, which means that I'm going to have to write a JNA or justification and authorization.
Bonnie Evangelista [00:12:19]:
Yeah, we would do that, wouldn't we? Because how we document what we're doing is important no matter what we're using. And the JNA justification and approval document has a very specific connotation, though to Far based procurements number one. But two in terms of like I can't even imagine how you would fill out that form for the Ten USC. 40 23 authority because a lot of the requirements or narratives that you would put in that form just don't apply.
Stephanie Wilson [00:12:51]:
Exactly. And once again, here we are pounding the round peg in the scoop.
Bonnie Evangelista [00:12:56]:
I've seen this movie before, by the way.
Stephanie Wilson [00:12:58]:
This all sounds very familiar, but I think that's one that can be used without complication. But again, we have a tendency to complicate that. I think that we have a tendency to just complicate anything that is not traditional. Not traditional means that we are not using the Far, which is the Federal Acquisition regulation, conventional, unconventional, just basically anything where the person who is doing the contracting has some autonomy to decide what is it that I can do to get XYZ into this person's hands? The soldier, the operator, the war fighter, whoever your end user customer is. How are you able to get from what they want? So as you say, ideation to operations? You got it. How do we do that? How do we do that in a fast, expedient manner? And when we attempt to do something like that, what is the first thing that we do? We policy all over it because of course we can't trust our people. You have to be able to trust the people that are buying, that have been warranted, that are actually in the position to do the purchase, have the trust in them, that they have the business acumen and they have the common sense, and they have the critical thinking skills to be able to structure that unstructured environment in a way that makes sense for that action.
Bonnie Evangelista [00:14:24]:
Yeah. Because if you think about it, using 40 23, every experiment is going to be different.
Stephanie Wilson [00:14:28]:
Right.
Bonnie Evangelista [00:14:29]:
So how you structure the contract might look very different depending on the experiment. Don't get me wrong, I know, in the commercial world, their contracting also has a standardization because there's things that either you are protecting your company from that you have required boilerplate language. I guess I'm just trying to highlight or footstomp kind of your point about let's not overcomplicate it. You can have two very different agreements and they can both be right. Exactly. So if you have a policy that says one is wrong, that is inherently limiting us. Right, exactly. Yeah.
Stephanie Wilson [00:15:15]:
And it strips away the ability to critically think. And I understand the frustration on industry side where they go into negotiations with us and they kind of get the same cookie cutter type of negotiation style when you are working on the traditional side. And really in the end, do we as a government really truly care how they spend their money?
Bonnie Evangelista [00:15:42]:
No, we care if we got the thing.
Stephanie Wilson [00:15:44]:
Exactly.
Bonnie Evangelista [00:15:44]:
And yeah.
Stephanie Wilson [00:15:45]:
Did we deliver or did they deliver? Did they give us what we wanted and did they make a profit off of it? Okay, great. And we fail, I think a lot in the government to understand that companies do need to survive and we try and slice and dice their profit to such a narrow margin that it makes really them bidding.
Bonnie Evangelista [00:16:04]:
You're talking about cost analysis.
Stephanie Wilson [00:16:06]:
Exactly. And we crab all the time in the government about ROI and we want to know what our return on investment is going to be. And the beauty of doing nontraditional contracting outside of the Far is that that return on investment can be specific to what you are actually doing. So that gives you the ability to work with your industry partners to say, hey, listen, this is what would work for us, what's going to work for you guys, what's going to make this worthwhile for you guys to come in and do a partnership with us so that way it's not such an us against them battle. And we get that a lot.
Bonnie Evangelista [00:16:40]:
Yeah. Just to close the loop on 40 23, because I think that's an excellent example where we're definitely underutilizing a powerful authority at our fingertips. 40 23 is not meant to be a long term solution by any means, but it can be an enabler to your long term solution and it can create quick entry points if you use them, if you're savvy and you use them correctly. You were talking earlier about having the experiment has to be aligned to certain sectors. So that's a statutory requirement. Right. There's no policy that I'm aware of.
Stephanie Wilson [00:17:19]:
No.
Bonnie Evangelista [00:17:20]:
For 40 23, which empower a ton of discretion, is at the AO level. Right. And all of the requirements under 40 23 are by statute.
Stephanie Wilson [00:17:35]:
Right. That's it.
Bonnie Evangelista [00:17:40]:
You get to define, here's my need, here's how it aligns to the sector that Congress has told me I have to align to. And this is the outcome we're targeting under the experiment and we're going to go right. Like, what else do you need?
Stephanie Wilson [00:17:57]:
And how easy is that then, for you as a contracting professional in the government sector or maybe in the fourth estate or wherever you're at, but for you to be able to have an open and honest conversation with your vendor, to be able to go to industry and talk to them like their industry partners, talk to them, talk to each other I mean how easy is that? And that I think is one of the biggest ways that we can demystify what the contract process is, is we show them all the cards because now it's a relationship. Now it's a true relationship, a true.
Bonnie Evangelista [00:18:31]:
Partnership and with that now I'm going to take it, we're going to go expert mode I suppose. Like our friend Keith would say, what if I awarded three experiments under 40 23 and then rolled the let's say that's a competition in itself, right? I need to learn something about a critical mission gap or something and then whatever comes out of one, some or all of those experiments rolls right into an OT and I can establish sorry, a prototype OT.
Stephanie Wilson [00:19:05]:
Right.
Bonnie Evangelista [00:19:05]:
And I establish competition because I ran three experiments. Right, so now we're stacking authorities. Right?
Stephanie Wilson [00:19:11]:
Exactly.
Bonnie Evangelista [00:19:12]:
This is the kind of thinking and again I hope it doesn't sound complicated because it is very simple. I think we're trying to peel the onion a little bit to explain there is simplicity here and you just have to put the puzzle pieces in play that are going to benefit whatever outcome you're looking for.
Stephanie Wilson [00:19:30]:
Well and not only are you stacking authorities but you're checkmarking the boxes of what the statute requires you to do for 40 22 which is market surveillance. That competition can also be your market surveillance. Why not?
Bonnie Evangelista [00:19:44]:
Right.
Stephanie Wilson [00:19:44]:
So not only stack your authorities but checkmark your boxes.
Bonnie Evangelista [00:19:47]:
Yeah. And in the OT guide it is definitely encouraged to do such practices. Right. I don't think the department is saying we can't do these things. There's a lot of not knowing right now that we need to level set well.
Stephanie Wilson [00:20:04]:
And if we can do that with industry, I think that they would understand a little bit better about what we do and how we try to get to the point of award. Because then they're involved with that and they understand. They understand that we can do things like stacking authority. We tell them up front, listen, we're going to do experimentals like you said. We're going to do three of them.
Bonnie Evangelista [00:20:23]:
I mean there's so many ways we can slice and dice this. I can start with a prize competition, I can start with a hackathon.
Stephanie Wilson [00:20:30]:
Literally. The contracting world can be someone's oyster. It just really depends on how you translate that to our partners or to our industry partners. And then not only that but sometimes you have to demystify the contracting process for the people inside the government who are not in the contracting circle. Right. You need to be able to explain to them you have a need. I'm going to help you get that need fulfilled by a company out in industry it's not going to be a difficult journey. It does not have to be a painful journey. So demystifying the entirety of the machine that we have for contracting goes both ways. It needs to be for our industry partner and for our other govies.
Bonnie Evangelista [00:21:10]:
Yeah I fully recognize that what we're talking about is not a common practice. Right. I think we're trying to encourage people to like hey ask some good questions. If you're not doing these things ask your leaders and your team leads can we do these things? Why aren't we doing these things? What else is resonating for you right now to kind of close the loop on this topic?
Stephanie Wilson [00:21:39]:
I think really just the last thing that I would say on this is the fact that anybody in this space anybody who is going to be working in nontraditional who is trying to figure out what is my place in this world right? Because everybody kind of has a place in there. Find your place and then fight for it. Because there is ability within this kind of sector that we've been given by Congress to actually do something good. Like you can see benefit you can see progress within days weeks if you allow the statute and the guidebooks and just basically anything that you have at your disposal if you use those things you could see immediate change. I'm not talking about like when we do something with Far part 13 and two years later I'm buying something that's completely obsolete that my operators don't need anymore. You could use these things to show immediate success. So if you're going to your leadership and being like hey it's going to sound a little crazy but I do really want to try this. Try something at a lower dollar value or a smaller low threat. Yeah exactly low threat but maybe has a good demand signal from your leadership like try and solve one of their problems.
Bonnie Evangelista [00:23:06]:
I can totally appreciate sometimes it's a bridge too far. Depending on your culture and personalities the stakes have to be low maybe just to prove out the concept. I can totally appreciate that.
Stephanie Wilson [00:23:21]:
Yeah and I think we all can because anywhere you work within the government you are going to have policy and you're going to have people that maybe don't understand what you're doing. So that is going to be part of you. Demystifying the contract process is making people comfortable with the uncomfortable.
Bonnie Evangelista [00:23:37]:
I can't close this out without you reminding everybody what not to do.
Stephanie Wilson [00:23:42]:
Okay listen up folks don't far on my Ota.
Bonnie Evangelista [00:23:46]:
She's coming after you.
Stephanie Wilson [00:23:47]:
I am.
Bonnie Evangelista [00:23:51]:
This phrase is catching on. So I just want everyone to know no matter who is telling you this, this young lady, my flower child over here she coined the term definitely don't far on our Ota. I think we're being funny about it, but there's a seriousness behind it that spurred us to even start talking about it, because we were facing that. We were in the moment. We're like, man, because I think there was a policy thing going on, and it was like a cathartic.
Stephanie Wilson [00:24:22]:
It was it was a cathartic phrase, and one that we have used often. And the reason why Bonnie and I can say things like this is because we've got the battle scars. We've been fighting the good fight now for a while, and we want others to know that they can fight the good fight, too. And there are people here who have done it before, and you can do it.
Bonnie Evangelista [00:24:44]:
Stephanie appreciate you.
Stephanie Wilson [00:24:46]:
I appreciate you.
Bonnie Evangelista [00:24:47]:
Oh, thank you. All right. Thanks.
Stephanie Wilson [00:24:49]:
You're welcome.