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About steve

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  1. Leo, I agree with Pepe that you can advertise your requirement far and wide, provided you post to the GPE which is FBO, despite the use of the word "single". However, I think for everyone perusing this thread, that while you can also post to GSA (assume e-buy), SEWP, etc as you suggest, you have to know what you are doing. I believe that market research should inform you on the method, generally I think of "open market" as triggering the FBO requirement, but if I choose to order through GSA e-buy, then that's another matter. See FAR 8.404(a). I generally teach new 1102's that market research and the requirement should inform them whether they do open market or utilize GSA schedules. If GSA, then use e-buy (and not FBO), generally speaking. Our Small Business Specialist will sometimes advise us to cast a wider net and post a GSA e-buy requirement to FBO, but we have developed specific language for those scenarios so that industry is made aware that we intend to issue an order against a GSA schedule, so any responses through FBO should include their GSA Schedule information and we also post to e-buy. Generally for MACs/GWACs, you could post to FBO, but you have to make sure you provide a fair opportunity to those contract holders (16.505(b)(1)( i )). This gets complicated if you don't know what you are doing because generally you wouldn't synopsize a requirement that could be satisfied through a MAC order. Without caveats on this, I'm not sure what you would do with an FBO response to something that was also done as a MAC fair opportunity if you didn't go through all the right steps. Of course I'm talking about posting or issuing a solicitation, and not RFI's or sources sought notices. Again, I believe for the most part, market research should inform you on the method before you get to the issuing a solicitation stage of the game, and post it in numerous places. It may tend to confuse industry more than it generates interest.
  2. No N/A The contract is with the DoD and the SBA, the paragraph says that the "SBA remains the prime contractor...", the 8(a) prime contractor is the subcontractor. When a DoD KO signs on the SBA's behalf, they are signing the subcontract with the SBA and the 8(a) "prime", who is the sub.
  3. Don, At least for services, DoD Contracting Officers could monitor/ensure compliance with 52.219-14 through eCMRA (electronic Contractor Manpower Reporting Application). My understanding is that subcontract labor must be accounted for separately. Not sure you could get the exact data you would need in terms of "cost incurred for personnel", but it would be easy to look at prime direct labor dollars and subcontract direct labor dollars and if the latter is more than 50% of the total, start asking questions. This may be after the fact, because I believe they only need to report once annually. See the memo here: http://www.acq.osd.mil/dpap/policy/policyvault/Enterprise-wide_Contractor_Manpower_Reporting_Application_memorandum.pdf It has a note in the text of the memo about the OMB data collection requirement.
  4. Rob, See FAR 32.1108. If you are paying your T.O.'s with a GPC, then you are required to check the delinquent debt flag indicator in SAM at award and at each T.O. placement. If they show a debt flag, you can't use the GPC as a payment method, but rather would have to insert one of the applicable EFT clauses. You wouldn't terminate. See FAR 32.1108( b ) (2)(iii). There are no controls in place to offset a payment that the contracting office would make with a GPC. However, if paying by "conventional" means (EFT), contract payments due the contractor would be "offset" and used to pay down their debt. I don't know the specific of any appropriations act that may have additional restrictions.
  5. Try this: https://www.fbo.gov/utils/view?id=94a8abc4401e19bf2821937146161791 If that doesn't work, try an FBO search for SPM4A2-13-R-0005 in the keyword/solicitation number field (without the dashes).
  6. New, I don't know how much research you've done, but from my experience, the current contracting environment does not make it more difficult to get Class J&A's approved. Sometimes it just makes good business sense to do it on a class basis. I just did a quick search on FBO, and although you can't search specifically for "class" J&A's, they are easy to find if you know what you are looking for. From my experience, they are done to justify procuring from a peculiar manufacturer for weapon systems spare parts/components where the Government lacks sufficient data to break out any of the items. I believe you will find a preponderance of them from what I would term "inventory control point" buying activities. Typically each military service has one or two and the Defense Logistics Agency has three or four large buying activities that predominately procure spare parts. My experience is only DoD. Here's a link to one for 9 years and 1400+ parts....... https://www.fbo.gov/index?tab=documents&tabmode=form&subtab=core&tabid=2645eba1a57e7e0f8c29d10da8f1a0c1
  7. Navy. I've considered 13.104(, but it still does not address the "public display" requirement. It seems unusual that between $15K &$25K I would have to comply with the requirement to post for at least 10 days, but above $25K up to the micro-purchase threshold of $30K I don't have to comply (and below $15K). You would think this would not be applicable to micro-purchases. We're not using the GCPC either as a procurement method or a payment method because it is rarely, if at all, accepted by the vendors in the AOR.
  8. I have a different question in regards to synopsis and public display requirements in 5.101. Scenario: Deployed (DoD) Contingency Contracting Officer OCONUS (not in U.S. outlying areas) making an open market (local sources) micro-purchase. The micro-purchase threshold in this scenario is $30K. 5.101(a)(1) requires synopsis for actions >$25K unless an exception at 5.202 applies. In this example, a trade agreement doesn't apply, so the exception at 5.202(a)(12) would allow the Contracting Officer to exempt the requirement from synopsis. My question is the requirement at 5.101(a)(2) to provide public display of proposed contract actions between $15K and $25K. Paragraph (ii) of 5.101(a)(2) specifically excludes 5.202(a)(12). I'm not using oral quotes, and even though in a contingency environment, it is not an urgent and compelling need. Is there an exception to this public display requirement if my micro-purchase requirement is between $15K and $25K?
  9. 1. Yes. Paragraph (2) of the definition of ?Simplified Acquisition Threshold? at FAR 2.101 states that the SAT is $1M for any contract to be awarded and performed, or purchase to be made, outside the United States. 2. No. Although FAR 19.000(b ) states that Part 19 is applicable in the United States and its outlying areas, the policy for automatically reserving acquisitions exclusively for small business participation at FAR 19.502-2(a) specifically excludes paragraph (2) of the Simplified Acquisition Threshold found at FAR 2.101.
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