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About smm.0831

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  1. In this case I believe it is non-severable and PoP starts in August same FY as appropriation. 1. Services are considered severable if they can be separated into components that independently provide value to meet an agency’s needs. 2. Non-Severable Service. Services that represent a single undertaking that cannot be feasibly subdivided. If the services produce a single or unified outcome, product, or report, the services are considered non-severable. Requires the contractor to complete and deliver a specified end product. DoD Financial Management Regulation Volume 11A, Chapter 3 030404. Appropriation Policy 4. Because research and development test & evaluation (RDT&E) requirements are iterative in nature, RDT&E programs, projects and activities are not subject to full funding policies. For example, DFARS 232.703-1 permits DoD organizations to incrementally fund a fixed-price contract if the contract is funded with research and development appropriations. Similarly, DoD budgetary policy Volume 2A Chapter 1, Paragraph 010214 provides that RDT&E budget estimates are prepared on an incrementally funded basis and only those funds required for work in a given fiscal year shall be included in the RDT&E request for that fiscal year. These policies apply equally to budgeting and obligating for requirements that in execution involve placement of Economy Act.
  2. I really did not think I was doing anything wrong until a team leader said that we were violating the Anti-Deficiency Act...I documented the bona fide need, follow the 17.2, had FY11 funds and place in the CLIN for the option and did not change the PoP. I asked in WIFCON for clarification and correct guidance so I can pass down to my co-workers. Team leader is fairly new in Contracts (3 years) and so I am (5 years). I think we can get easily confused with terminologies and sometimes we follow without looking at the policies and regs. Thanks WIFCON! Have a great day!
  3. Funds were appropriated per MIPR and obligated (incrementally) in the modification (per my understanding of appropriation and obligation).
  4. Effective Date of Mod 21 June 2012 Option Two Period of Performance: 15 August 2012 through 14 November 2013
  5. Good day, We have a discussion on my workplace of whether or not we can exercise an option early only to obligates the funds. We have done it several times and now we are questionning whether or not this is a violation of the Anti-Deficiency Act. Scenario: Contracts is for R&D, Cost Reimbursable. Exercise of Option was to obligate funds but not to change the period of performance. We specify that work shall commence as stated in the period of performance not at the effective date of modification that exercised the option. Funds are FY11 with expiration date of 30 Sep 2012. Are we violating the bona fide rule and the anti-deficiency act? I do not believe we have violated the anti-deficiency act or bona fide rule as funds were appropriated in February 2011 (per MIPR), the intend to exercise the option was deemed necesary and in the best interest of the program. Your advise is appreciated.
  6. Mr. Edwards, I was refering to the maximum contract amount for the current option. Thanks for reminding me of the importance to use the right terminology...no wonder why I was so confused!
  7. I THINK I FOUND THE ANSWER ON THE FOLLOWING LINK... http://www.wifcon.com/arc/forum28.htm
  8. I made a mistake this is a FFP...the rest of the scenario still the same. The area that is creating confusion on me is that this is not an incentive fee contract, therefore on my mind I am not increasing ceiling but adding funds?if I add funds to an option year that is currently running and its close to run out of funds on a FFP, does it means I am adding more work? References: https://akss.dau.mil/askaprof-akss/qdetail2...estionID=101408 http://www.wifcon.com/discussion/index.php?showtopic=766
  9. Thanks for replying, do I also need a reviseed cost proposal? Does this constitute additional work?
  10. Situation: CPFF IDIQ contract on its third Option Year which is the last option on the contract. Option Year III was exercised on 09 June 2010 and expiring on 08 June 2011 for an estimated total of $722,571.00. Out of that amount we have only obligated $69,764.00; however COR stated that before end of FY10 an estimated $400k might be obligated on task orders leaving an approximately balance of $253k. Because we still working on the follow on contract. My recommendation is to increase the funding amount on current option; however if I do so do I need to request a new cost proposal? Or this is just a simple modification to increase funding? Please note funding will be increase only up to 25% of total contract value which is $3,495,370. This simple scenario with my limited experience have me really thinking. I appreciate if someone with experience can help point me the right direction.
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