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Everything posted by Retreadfed

  1. applicability of TINA with small business

    I don't know what is happening with my last post, but the citation should be 16.505((3).
  2. applicability of TINA with small business

    It's not clear what your situation really is, but FAR 16.505((3) might help you.
  3. I think it will be interesting to see how this provision would be applied in regard to orders under FSS contracts or other existing multiple award contracts.
  4. As a follow-on, how would this policy work in regard to situations like Blackwater not having its contract renewed?
  5. If presidents are permitted to mandate substantive procedures like this, it would appear to make a sham of the requirement for public comment in regard to procurement rule making, which is intended to have the rule maker get and consider the views of those who would be affected by the rule. See. http://www.law.cornell.edu/uscode/html/usc...18---b000-.html
  6. What is your concern in regard to this? Are you with the government or prime contractor? What type of contract is the prime contract?
  7. Not Charging

    There are two issues here. One is proper allocation of costs and the other is what is billed against the contract. When you say "working on a government contract," I assume you are referring to work that directly benefits that contract and no other. If that is the case, the cost of the employee's time should be allocated to the benefitted contract and no other. Of course this does not mean that the contractor has to bill the government for the cost of that time. There is no requirement that a contractor charge the government for all costs incurred in regard to a contract. However, from the government's perspective, there is a prohibition against acceptance of voluntary services.
  8. In regard to G&A, does the contractor have approved billing rates for its indirect costs? If so, do you have some information that indicates that those billing rates are not reflective of what the final rates for the year will be? If the answer to the latter question is "no," the G&A rate sould be considered reasonable because the costs that are in the G&A pool must be allowable, which includes being reasonable.
  9. Blitz, why wouldn't the government pay fee on premium pays made by the contractor? The only cost that FAR 15.404-4 requires to be excluded from the government's profit or fee objective is facilities capital cost of money.
  10. Competitive contract award

    Phillygal, if you intend to award a cost reimbursement contract, what type of solicitation other than an RFP would you use?
  11. Vicki, check the requirements for a subcontracting plan by subcontractors. While primes are required to develop a plan when the prime contract offers subcontracting opportunities, there is no such qualification for subcontractors. They must develop a plan whenever the subcontract meets the size standard and the subcontractor is not a small business. Sounds dumb, but the statute and regs require a subcontracting plan when there will be no further subcontracting by the subcontractor.
  12. Federal Contracting Myths

    Civ, I presume Don's point in starting this discussion was to demonstrate the many points of ignorance (not stupidity) that exist in the procurement world. While not a "myth," you have identified another. I might add that what is an adequate accounting system can vary with the contract type involved and that one size does not fit all in this regard. For example, what is adequate for a T&M contract for commercial items would be quite different from an accounting system for a contractor performing a cost reimbursement contract subject to the CAS.
  13. Federal Contracting Myths

    A contractor must have a DCAA certified accounting system as a prerequisite to receiving a cost reimbursement contract.