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joel hoffman

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  1. DFARS Business Systems

    Here is a link to the final rule published on 24 Feb 2012 that Joan appears to be referring to: https://www.federalregister.gov/documents/2012/02/24/2012-4045/defense-federal-acquisition-regulation-supplement-business-systems-definition-and-administration
  2. Whose requirement is this & how do I resolve?

    ...and it doesn't appear that "major system configuration change desired by the USMC" would fall under the descriptions of a "commercial off the shelf item" or a "non-developmental item" at: http://www.dsp.dla.mil/Policy-Guidance/FAQs/Commercial-and-Nondevelopmental-Items/ So, are you mixing apples and oranges by combining Army and Marine Corps product requirements in one acquisition vehicle?
  3. IDIQ Decision

    You really don't know a darned thing about that acquisition or about that person. The man was known to be a straight shooter. Tough but truthful. We asked him why the price for the current dorm project was so much higher than the previous years' prices for the same design. He told us why the contract, as designed, was not affordable. It was a cut and paste of earlier projects and didn't fit the market conditions at the time. He had built the last dorm project using the same design. There weren't any local mason labor force or masonry subcontractors available due to recent hurricanes. The structural framing and cladding design was very inefficient. He asked us what really mattered to the Air Force. We learned that their objective was that the new dorm must match the appearance of the other dorms. He told us how we could meet their underlying objective and committed to do that and to meet the budget. The man doesn't deserve your degradation. Feel free to stop now. I didnt say the Air Force personnel were stupid. I said that they made a wasteful and stupid decision. That decision needlessly cost the taxpayers 23% more than the programmed amount for the project - a $1.5 million dollar bust. 25% over the PA is the statutory limit for gosh sakes. There were seven bidders. His firm was local and he did lots of work at the bases in Florida. He was the low bidder and the only one who really knew the problem. He was the only one willing to work with the government and the taxpayers to find a solution. The customer chose to meet a self imposed deadline for award to make their metric for timeliness of award look better, regardless of cost. The project had a duration of about 18 months and could have been awarded within 12-13 months into the 60 month period of availability of the funds for obligation. Believe it or not, some of us actually believe in serving both the mission and the taxpayers.
  4. IDIQ Decision

    I wasn't involved in the attempted persuasion. Our PM's were the POC's and handled those communications with the customer's PMs . The contractor also told me later how wasteful and stupid he thought the customer's decision was.
  5. IDIQ Decision

    Obviously, you haven't worked Air Force MILCON programs (5 year money) in a long time. One of their goals was to award all Current year MILCON projects by the end of the fiscal year. Even when Congress delayed authorization and appropriations til mid FY. Everything would get backed up for September award along with the O&M funded projects. Which kicks in the supply and demand factors. The seller is well aware of time pressures to award and the slew of solicitations. Which kicks in haste and stupid decisions. We could have made an award within two weeks. Why the heck would we convert the IFB to an RFP (FAR 14.404-1) , ask the bidders for price proposals and hold price discussions with them if we couldn't follow through with an amendment, revised price proposals and award? Our District was doing lots of negotiated design-build and construction acquisitions for both Air Force and Army then. We could have easily done it within three to four weeks with an award one to two weeks into the next FY - to save $1.5 million? But we could also have squeezed it in within two weeks with some concentrated effort and overtime. In addition to handling the source selection and negotiation process, as a professional engineer, I could have written the revised technical requirements myself or could have suprervised Engineering Division's efforts. I often came up with design fixes during source selections. Our negotiated acquisitions didn't take longer than WWII.
  6. IDIQ Decision

    Vern , i was responding to H2H's opinion. There was no legal requirement to award the AF MILCON project by 30 September. However, the biggest lesson learned was not to prescribe the structural system or specific exterior architectural materials. The Air Force was in the process of making D-B their default method at that time. D-B wasn't the issue. I suspect that the metrics for the personnel performance ratings of the individual decision makers were the underlying issues and motivation to make an award at any price within the Statutory limits by 30 September.
  7. IDIQ Decision

    Vern, I don't really care what you think about my example or who I offend with that story . I know that we would have saved the taxpayers a million and 1/2 dollars and the customer were only concerned about an award by 30 September. And it has been typical of the Air Force to overprescribe every design build project that I have been involved with or reviewed since. The only design-build project that I was directly involved with that could not be awarded was a fire station at the same installation. The RFP included at least a 50 to 60% design solution in the RFP. The same customer again refused to budge an inch. Those have been very effective lessons learned that I've taught for over 20 years in our design build course and which reinforced our performance based design criteria approach in the Army Milcon Transformation Model RFP. The story gets the attention of almost every student in attendance. For the dormitory project, we could've issued a quick amendment with four pictures of the dorms to be matched, about three paragraphs of performance based structural design criteria and design references and a couple of pages of our standard design build contract requirements. Edit: I know for a fact that performance ratings for both the Air Force project managers and the Corps of Engineers project managers, at that time, were more heavily dependent upon their project award execution rate than the quality or cost of the projects that they were in charge of.
  8. IDIQ Decision

    We told the Air Force that we could make an award within the budget by 30 September but it fell on deaf ears.
  9. IDIQ Decision

    I teach one such example in my design-build class, where the Air Force consciously WASTED $1.5 million on an $8 million award for construction of a dormitory at Hurlburt AFB in Florida back in September of 1994 or 1995, so that their execution rate would look better. It was a fully designed IFB by The Army Corps of Engineers that was converted to an RFP because all bids were at least $1.5 million over the Programmed amount. After conversion and receipt of proposals from five of the seven original bidders came in, I conducted discussions with the two lowest offerors who were most competitive. The lowest price offeror, who I had great respect for, told me that the design was extremely inefficient and commercially impractical due to market conditions in Florida and the South East. After two recent hurricanes that year, the closest mason labor force and masonry subs available to team with the local prime were in North Carolina. The three story masonry framed dorm with face brick finish would require at least four masonry sub mobilizations and demobs, plus travel and perform while on site, plus inflated masonry prices, which accounted for the entire $1.5 million overrun in their price. The president of the firm said they would drop their price $1.5 million if the government would change the RFP to make the contractor responsible for the structural design with performance specs for the frame and the requirement to match the look of the adjacent dorms that the new dorm design was based on. He rattled off about four different feasible structural alternatives using matching brick veneer or even precast concrete panels using colored concrete and special brick faced form liners. The contractor and our office both were experienced with the Design-build delivery method. We went back to the Air Force, recommending that proposed solution. Since it was September 15th, the Air Force felt the risk of award later than 30 September would be unacceptable and said they would provide the additional $1.5 million for award, as designed. I was so incensed that I was able to require our District to not specify the structural solution on any design-build project for the Air Force for the next two years until I transferred to another Corps organization. After I left, the District went back to prescribing specific framing and materials for the Air Force and back to overrunning the PA on every Air Force project. It was a lesson learned that. As a part of the Army MILCON Transformation team, I was able to assure that the model RFP used for billions of dollars of army design-build construction between 2006 and 2013, was written, using performance based design criteria for structural framing and for exterior materials. I'm still pissed off over that one (just one ) example of waste by the Air Force and others who have the pre-conception that the government must prescribe every architectural or structural requirement to meet the look and feel of their design theme.
  10. Mandatory E-Payroll

    If any reader here has access to the "higher level policy for [DoD electronic payroll systems?] that has previously undergone the public comment process", would you please identify or provide a link to that policy? That might help mccmark better frame his question(s) to the soliciting agency. Thanks. This Forum method of communications and information seeking Is like texting sound/word bites vs. direct oral conversation. It is available to a wide audience but I'm still unclear about what mccmark's real, underlying concerns are. One appears to be that the NAVFAC is allegedly requiring use of a third party payroll system in addition to their own payroll system. Mccmark hints that they have some type of electronic system, thus may or may not be concerned about having to directly furnish electronic payroll information submission. Another concern is having to provide some type of remote access to their payroll system for (certain? Only designated? Any? ) government personnel. Is this a concern for third party payroll system or any electronic payroll system used? It is obvious to me that the DOL would have minimum technical requirements for determining compliance with the Labor Laws and for audit or inspection capability. Remote access might be open to debate. Such policies might have already been addressed by "higher authority" subject to public comment. Information Security? Remote vs obtaining controlled on-site access? As for access, the FAR and probably DOL and statutes already require that and/or the contractor to provide the information and mention providing access to the KO, authorized reps of the KO and DOL - for certain official purposes. Then, there is the question of authority for the "clause" (?), as written.
  11. Mandatory E-Payroll

    If mccmark's thinks that the NAVFAC solicitation requires that his/her firm use a third party payroll service in addition to whatever the company's internal payroll system is, perhaps mccmark should seek clarification or confirmation of that interpretation, then decide what to do in response.
  12. Mandatory E-Payroll

    Don, Apparently they did. Try this link and see page two, in particular the comment that the issuance of the PIL was to implement higher level policy that has previously undergone the public comment process. That policy was not available at the URL nor was the USACE request that is referred to. And to correct my earlier comment, the USACE clause does not appear to require either internal or third party electronic payroll software. It describes the requirements for such a system or payroll service, if used. http://media.swf.usace.army.mil/pubdata/ec/Payroll/PIL_2011-09_Electronic_Software_for_DBA_Payrolls.pdf The NAVFAC clause on page 74 at the below apparently requires use of a "supplemental electronic Construction Wage Rate Requirements statute payroll processing system to process and submit certified payrolls electronically to the Government that are compliant with appropriate Construction Wage Rate Requirements statute payroll provisions in the FAR. The contractor shall be responsible for obtaining and providing all access, licenses, and other services required..." I don't know what the significance of the word "supplemental" is or if it requires use of a third party payroll service that complies with the technical requirements described in the (unnumbered) "clause". http://4xstt2e0qzc1aqemd10fd9da.wpengine.netdna-cdn.com/wp-content/uploads/2017/07/RFP_WITH_WAGE_DEC.pdf Just because one can't find any evidence that the NAVFAC "clause" went through the public review process, doesn't necessarily mean that NAVFAC didn't use some similar process to that used by USACE for approval to use it.
  13. Mandatory E-Payroll

    I think that the two agencies were (are) working to implement procedures to implement paperless contracting procedures, which have been mandated at some higher level by (?) . It's a good thing to have to allow public comment and feedback concerning the particular procedures, as discussed herein. It appears that the Corps isn't mandating the use of an independent payroll service. If the contractor does use an independent payroll service, then those requirements would kick in. As mccmark indicated above, it wasn't deemed necessary to publish the SCR for public comment. The NAVFAC version appears to mandate use of an independent payroll service, even where the contractor has an internal electronic payroll process. If that is intentional, why? From my experience, NAVFAC is much more prescriptive than USACE or the Air Force in specifying construction means and methods anyway, so why should I be surprised?
  14. Mandatory E-Payroll

    It funny to me how officials from those agencies whose policies and procedures are questioned in the WIFCON Forum generally don't defend or otherwise justify or explain their procedures . I also wonder whether a contract requirement that simply implements an existing requirement of a standard contract clause, , such as a special contract requirement which adopts a uniform approach for submitting otherwise required payroll information to a paperless contracting system, or how to make information available for audit or review must be published in the Federal Register, etc., etc., etc. I suggest that such formality could be a bureaucratic crock. However, perhaps such prescribed approaches should be put to the test as Vern mentioned. Concerning payroll information, the basic contract clause requiring submission of payroll information and for providing access to the basic payroll data has been in effect for decades. What's the difference between specific procedures for already required payroll submission into a paperless contracting system system and contract specifications for contract construction schedules that implement a general contract clause requiring submission of a construction schedule? I will guarantee that technical specs for construction schedules, prescribing specific scheduling procedures for the construction schedule required by the contract clause aren't published in the Federal Register.
  15. Mandatory E-Payroll

    mccmark, aside from the issue of authorization for the special contract requirement, are the above requirements [1] & [2] your specific problems with the non-numbered Navy Special Contract Requirement? I presume that the second [2] requirement would be a problem with the USACE Special Contract Requirement S-102, correct? I can see a problem with mandating use of a supplemental, third party payroll system. However, requirement [2] might be consistent with paragraph (c) of Clause 52.222-8, which extends beyond simply submitting weekly payroll info .The clause requires the contractor to make payrolls and basic records available for inspection, copying, or transcription by specifically designated or identified government employees. I think that the contractor could restrict access to such personnel, if that is technically possible in the software. There could certainly be an issue of requiring remote access to the information. Carl, the contractor isn't required to use the last four digits of the SSN for identity numbers of its employees on the weekly submitted payrolls . That is only cited as an example.
  16. In my profile pic,  I'm sitting on the covered but open hotel restaurant at Saba Rock Island, Virgin Gorda, in the BVI's. My wife and I have both long said that "If you find (me) missing, search for me at 18.5030° N, 64.3578° W".  It is one of our favorite places on the Earth. Behind me is a view of the Bitter End Yacht Club Resort.  Hurricane Irma essentially destroyed the Bitter End and heavily damaged the Saba Rock Hotel and Restaurant. Richard Branson's Necker Island is just North of Saba Rock Island. It is widely believed (but not substantiated) in the BVI's that GOOGLE co-founder, Larry Page, owns or leases Eustatia Island, which is another Island adjacent to Saba Rock.  We saw both of their super Yacht sailboats at the Bitter End over the years. Drool...

  17. Mandatory E-Payroll

    For USACE, the government isn't requesting electronic access to or reaching into the construction contractor's internal "system". The contractor inputs the data into the government's contract admin system program, "Resident Management System (RMS)" , via the contractor module or program, called "Quality Control System (QCS)". The cost is to be included in the contract price. I don't know what software NAVFAC is using to administer construction contracts. As stated above, it has been a valid requirement for construction contractors to submit payroll info to the government for decades. Rather than asking for information in a contracting forum, I suggest that the OP address his/her questions and concerns to NAVFAC. There may be valid security concerns or questions about the NAVFAC's approach but I would address them to NAVFAC.
  18. Mandatory E-Payroll

    Government construction contracts (including NAVFAC and USACE) have required submission of construction contractor and subcontractor payroll information containing some personal information for decades. Don can feel free to look for the required approvals to collect that info but it is IAW FAR, DOL regs and the applicable Labor Laws. I don't think that the employee's SSN is part of that data input but am not going to research that here. Think that employee addresses are required. For decades, it was paper based copies. The USACE maintained the paper copies as part of the official contract file, which weren't as secure, in my opinion, as the current electronic files are. We had drawers and boxes full of payrolls, which we had to review and use for employee labor interviews, verification of compliance with the DB minimum wage decisions. They were used for other CAB purposes - such as tracking overall labor hours for safety , and for verifying or estimating expended labor amounts and costs for changes, REAs or claims, evaluating self-performed labor, etc. The USACE is moving to or has moved to fully electronic contracting. The USACE contracts require the contractor to submit electronic payroll data to the USACE RMS (Resident Engineer Management System) software, using the Contractor "Quality Control System (QCS)"module/program. The contractor can use commercially available payroll software or their own developed payroll software as long as it can feed an Excel spreadsheet format, in the CQS module. The contract says, naturally, for the Contractor to include the cost in the contract price. RMS is a DoD and Army approved contracting software system for security purposes. As far as I know, only those USACE Contract Admin personnel with approved access to the contract in RMS can physically access or view the payroll information. However, it remains a part of the official contract file for whatever the prescribed retention period is. I'm not familiar with NAVFAC's electronic contract admin system and have not recently used the USACE RMS software.
  19. page limitations on proposals

    Vern's and Nash and Cibinic 1994 era articles were spot on and probably served as catalyst's for the "Streamling" efforts and for the 1996-1997 FAR 15 rewrite. If you think FAR 15 is bad now, you should have seen it before that. Unfortunately, many of those acquisition personnel either didn't understand the intent or the distinctions because they taught newer personnel certain pre-1997 FAR approaches and limitations that are misunderstood and passed on to this date. Frustrating.
  20. page limitations on proposals

    I didn't need to use page limitations in my solicitations for construction, services or design build. In the interest of brevity, consistency between proposals and to focus on the specific information that we wanted to evaluate, I developed forms for relevant experience and related past performance owner rating and contact reference, if necessary to verify (not pp questionnaires for them to get owner's references to fill out and return) for prime, designer and specific key trade subs; for prime's and D-B designer's (only specifically identified positions ) key personnel; for identifying prime's work to be self performed. We included an outline price breakdown (not cost breakdown) and reserved the right to ask for it in the event that we needed it for price analysis or confirmation of their understanding of the work. For D-B, we focused on certain specific concept design information and on the level of quality of certain proposed equipment and materials. For D-B drawings, we limited the info to some specific preliminary information. I asked for certain organizational and management approach info but not detailed plans or detailed planned approaches. Did not have a problem with excessively long or wordy proposals, or typical lists of every project that they had ever completed. The competing firms liked seeing the same forms and similar format for every construction and D-B solicitation.
  21. J&A Requirement

    Ok, then 6.302-1 appears to discuss your situation. Is a J&A a big deal?
  22. J&A Requirement

    Does the solicitation limit the 20 items to the OEM?
  23. I need to find a fixed price incentive contract or similar cost incentive contract type that is allowable under the existing FAR for federal Design-Build contracting that provides for reimbursement of allowable costs, not to exceed a ceiling price or "Guaranteed Maximum Price" (GMP). The contract will provide for shared savings on the project if the actual costs are less than the ceiling price/GMP, through contract provisions for sharing of savings. In this scenario, the goal is to control costs within the target cost that is established at the price ceiling (GMP). The Question: Is there enough flexibility under the FAR in Parts 16.2 and 16.4, to use a fixed price incentive with Firm Target (FPIF) or similar contract type for a federal design-build construction project but with the "target price" plus the "target profit" in an FPI with "Firm Target" (FPIF) equal to the ceiling price? In other words, does the FAR specifically require separate "target" (cost plus profit) and "ceiling" (where ceiling price = cost plus profit)? Background : I'm presently working to develop guidance for federal agencies to use design-build with a “Guaranteed Maximum Price”, similar to the industry model described below. My goal is to be able to find a way to implement it consistent with the current federal statutes and the current FAR, without having to change either to implement it. D-B Industry Application: The Design-Build industry, e.g., Design-Build Institute of America (DBIA), Associated General Contractors (AGC), and the Engineers Joint Contracts Committee (EJCDC), have contract formats appropriate for design-build contracting. Their formats include, in addition to firm fixed price (the D-B industry term is "lump sum"), a form of "Cost-Plus with Guaranteed Maximum Price (Cost-Plus/GMP). This is a hybrid, combining the cost reimbursement features of a cost-plus contract with the cost certainty of a lump sum contract. The owner benefits by paying only the actual reimbursable costs of the work for the design-builder's performance and by knowing that its project will not exceed a pre-established price (adjusted, of course, for changes made by the owner or for other authorized adjustments under the contract). The GMP also offers both the owner and the design-builder the opportunity to realize savings on the project if the actual costs are less than the GMP, through contract provisions for sharing of savings. In commercial industry design-build practice, the use of a GMP contract structure is often used where the owner’s program is not defined well enough in scope and/or functional or technical requirements to be able to develop a budget or for the owner and industry to agree to a firm fixed price (FFP) for the project. Industry refers to FFP as “lump sum” pricing. The design-build contractor might be selected through some type of competitive best value process or through a qualifications-based selection (“QBS”) process. The owner and design-builder might work together to define the program more completely. The initial effort might be priced on a lump sum or cost-plus basis. The parties should establish a GMP for the project when the program is sufficiently established to make the GMP number realistic and meaningful. Federal Application: For federal design-build acquisition, design-build acquisition processes generally do not allow the use of QBS of the design-build contractor. The design-build contractor is normally selected using a competitively negotiated, best-value selection procedure, considering qualifications, usually design excellence, and price. Generally, federal government design-build build contracts are awarded as FFP contracts. In some instances, federal design-build with GMP contract approach may be more appropriate than the FFP pricing method, when there is already a defined programmatic scope and programmed amount of funding, but with only nominal design development and it is too early to be able to establish a firm fixed-price (FFP) without having to include considerable contingencies or risk in the FFP. It may be well suited for projects that are complex and difficult to adequately define a FFP at the outset and/or for projects that involve unusually high contingencies due to risks or unknown conditions, prior to considerable design development. Rather than paying a FFP for the full estimated contingencies, the GMP method can result in the government paying only for those actually encountered. Plus it incentivizes the design-builder to minimize, manage or avoid costs for such contingencies. Compressed time schedules available for RFP development, awarding and executing design-build contracts for large, complex projects are also a consideration for using design-build with GMP in lieu of FFP award. To be able to negotiate and establish a realistic GMP at the outset, the government must define its performance requirements for scope and quality up front, using a parametric/conceptual cost estimate. The design-build teams would also have to be able to conceptually estimate costs within that performance based requirements RFP format to develop their proposals. Is There an Applicable FAR Contract Type(s)? I have found that the federal “Fixed Price Incentive” contract types under FAR 16.403 (FPIF and FPIS) most closely resemble the industry Cost-Plus/GMP approach. The industry model is described in the DBIA Manual of Practice, in Document Number 510, Design- Build Contracting Guide, Chapter 5, “Lump Sum versus Cost-Plus/Guaranteed Maximum Price”. Both the industry Cost-Plus/GMP and the Federal design-build with GMP using the FPI approach require the design-builder to perform and complete the contracted scope within the contractually agreed maximum price, within the agreed time. Both provide for reimbursement of certain, allowable costs. The Challenge: The current challenge in adapting the FPI for federal design-build with GMP is to be able to use a single target cost/profit and ceiling price – not a lower target within a HIGHER ceiling. I think so, but need some advice or definitive support for my position. The classic FPIF with a lower target doesn't align with the industry model. It encourages a lower quality target design and construction level and may penalize the contractor for encountering unknowns or other non-controllable contingencies, rather than providing positive incentives to the contractor for mitigating, managing or avoiding risks and NOT consuming the contingency allowance. It is also much more cumbersome to manage and administer than a simple GMP ceiling. The industry has already demonstrated a willingness to accept the risk for exceeding the GMP/ceiling, using its existing GMP contract type. The design-builder is the single point of responsibility for design and construction. When D-B is properly used with government furnished performance criteria for means, methods, functional and technical design requirements, the D-B contractor has more ability to control the cost of work in design-build to meet the owner's quality, scope and functional requirements. The classic FPI model with separate target and ceiling price may be appropriate for complex, dynamic government developmental manufacturing programs (like developing and initial production or prototype production of airplanes, ships, missiles, etc.). It may also be appropriate for hiring a construction contractor during development of government furnished design for a complex facility, such as a hospital, etc. It isn't necessarily appropriate for Design-Build construction with a single source for both design and construction. Applicable FAR coverage: I found several pertinent FAR references for FPI contracts under: 16.201(a ); 16.204 (Fixed-price incentive contracts); 16.401 (General), 16.402, 16.403, 16.403-1, "Fixed-price contracts providing for an adjustable price may include a ceiling price, a target price (including target cost), or both.": A fixed price incentive with a single target/price ceiling (GMP) is consistent with the following: With a target equaling the ceiling price (the GMP), the profit is automatically affected when the contractor's actual cost exceeds the target: When the target and ceiling are the same (the GMP), they are within the constraints of the ceiling price. The government doesn't pay any more than what it bargained for and the contractor absorbs any cost overrun, affecting its profit: The GMP method meets this: The GMP method meets this : Paragraph d. (2) (ii) is the only paragraph in contract clause 52.216-16 Incentive Price Revision—Firm Target that would require some tailoring for the GMP with the target cost plus target profit equal to the ceiling GMP. Inasmuch as the paragraph provides for KO fill in anyway, it would be relatively simple to say something like "No adjustment - the target cost plus target profit equals the price ceiling." ______________________________________________________________________________________________ Note: [FAR Cost Reimbursement Incentive Type is not the Same as Industry Cost-Plus/GMP As a matter of semantics, the cost reimbursement incentive contract types under the Federal Acquisition Regulations have a different meaning than an industry “Cost-Plus/GMP” contract. The federal cost-plus (referred to as “cost reimbursement”) FAR contract types also provide for reimbursement of contractually allowable costs. However, the cost ceiling limitation is initially established as an estimate to complete the contract scope of work effort. The contractor is expected to make its best effort to complete the work within the cost ceiling. The government will not reimburse allowable costs that exceed the cost ceiling limitation. If the contractor cannot or does not complete the work within the cost ceiling limitation, the government would have to decide whether to provide additional funding to proceed beyond the cost limitation There are also legal and regulatory restrictions or prohibitions against the use of a federal Cost-Plus contract type for DoD Military construction and for some other Federal construction contracts.]
  24. ji, sorry- that wasn't necessarily directed at you. What is your opinion about whether or not an FPI contract necessarily must have separate target and ceiling for the application addressed above? If yes, why? What costs must be absorbed by the D-B contractor within the ceiling price?