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  1. Did you consider redoing your sole source justification to address DCMA's objections?
  2. In addition, no further consideration may be required for a modification because the modification may be supported by previous consideration. Think exercise of an option or the issuance of a unilateral change order.
  3. Is the award for a single IDIQ or a multiple award IDIQ?
  4. For what purpose is the table incorporated into the order? Is compliance with the table a requirement of the order or is the table included for informational purposes?
  5. I don't think anyone here can answer that question without seeing the contract.
  6. I think the reference is to the notice from the contractor required by 52.232-22(c).
  7. This is how FAR 42.701 defines billing rate. Billing rate, as used in this subpart, means an indirect cost rate- (1) Established temporarily for interim reimbursement of incurred indirect costs; and (2) Adjusted as necessary pending establishment of final indirect cost rates. This same definition applies to "billing rate" as used in FAR 52.216-7. In light of this definition, why do you say the billing rate usually includes the cost of direct labor?
  8. This conflates two separate concepts - whether the cost proposed for the labor proposed is realistic and whether the labor proposed is realistic for the work to be performed. In regard to the former, payroll data can form a good baseline for realism, but need not necessarily be dispositive. For example, if the contractor's workforce is covered by a CBA, the CBA may provide for future wage increases that would need to be considered in a cost realism analysis. This analysis does not answer the question of whether the labor proposed (for example labor categories and hours) is realistic for the work proposed.
  9. Audit risk of what? Are you concerned about your costs being audited or are you concerned about the government being audited?
  10. Need, can you reconcile these two statements?
  11. What do you mean by "billing rate"? It seems you are using this term other than it is defined in FAR 42.701.
  12. You still have not told us why you need this information. Is it to price an action or are you asking to determine what to bill the government on an interim voucher or is it for some other reason?
  13. Protest assertion "the decision not to set aside the procurement for small business concerns was an abuse of discretion."
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