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ji20874

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About ji20874

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  1. ji20874

    Commercial FFP - why?

    RightSaidFed, see 12.207(b)(1)(I) -- T&M under FAR Part 12 has to be competitive.
  2. ji20874

    Commercial FFP - why?

    How about a two-step process? STEP 1 tear-down and quote, STEP 2 repair. You send an item to the vendor for STEP 1 at a firm-fixed-price. The vendor does a tear-down and replies back to you with a FFP quote for the repair. You negotiate the repair price and authorize the vendor to go into STEP 2 at a firm-fixed-price. In the commercial sector, there might be a pre-existing pricelist for every replacement part and procedure -- every item on the list is FFP.
  3. ji20874

    Source Selection Approaches- all of them?

    Any approach, even one yet un-named and even yet un-invented, that makes good business sense and is not somewhere proscribed can be an acceptable approach, right?
  4. ji20874

    Small Business Set-Asides Not Required Under NETCENTS-2, Says GAO

    Excellent decision, fully compliant with our rules. Outside VA, the Rule-of-Two simply does not apply to ordering processes under Schedule contracts or multiple-award contracts. That’s a fact of life. The exception is if the parent Schedule or IDIQ contracts themselves [foolishly] self-impose this requirement.
  5. ji20874

    Source Selection Approaches- all of them?

    HTRRP is a valid approach for selecting many multiple-award IDIQ contractors in some situations. But I would not use it in a single award situation. I suppose you are only talking about Part 15 buys?
  6. I'm not aware of a short-cut. Shay Assad (DPAP) is a reasonable person and he can give you an approval or disapproval in a six-minute conversation, but it might take six months (or more) for your package to work its way to his desk. Best wishes -- maybe another poster will be able to help.
  7. elsmiles, Are you a Government contracting officer? Government program manager? Why do you want to commit the rest of the federal Government to give money to your contract faster than the standard clauses allow? Has the contractor made a promise of significant consideration for the proposed change? I recommend you leave well enough alone. You already agreed to weekly invoices.
  8. ji20874

    Single Source vs. Sole Source

    If your proposed contract action is expected to be $25,000 exactly, then synopsis is not required. See FAR 5.101(a)(1), where synopsis is required for actions expect to exceed $25,000. If synopsis is required (for example, if the proposed contract action is expected to be $25,000.01 or more), then FAR 5.207(c)(15) asks you to identify the intended source for a noncompetitive (sole-source) action. FAR 13.106-1(b)(3) sends you to 5.102(a)(6), which requires the solicitation posting to include the documentation for the brand-name item, if the reason for the sole source is brand-name -- if the reason for the sole-source is not brand-name, then you do not have to include the documentation.
  9. ji20874

    Single Source vs. Sole Source

    FAR 13.106-1(b) describes the documentation requirements for a sole-source acquisition when using simplified acquisition procedures up to the simplified acquisition threshold. Follow these procedures when doing a sole-source acquisition when using simplified acquisition procedures up to the simplified acquisition threshold. FAR 13.501(a) describes the documentation requirements for a sole-source acquisition when using simplified acquisition procedures for commercial items greater than the SAT and up to $7 Million (or $13 Million for acquisitions described in 13.500(c)). Follow these procedures when doing a sole-source acquisition when using simplified acquisition procedures for commercial items greater than the SAT and up to $7 Million (or $13 Million for acquisitions described in 13.500(c)). See also FAR 13.106-1(b)(2).
  10. ji20874

    Option Year Renewal

    Has a Government official (such as the contracting officer) told you that you need to get new competitive bids from your subs?
  11. ji20874

    Option Year Renewal

    Joel asked a good question. If you want help, you really should answer it.
  12. Retreadfed, So, would you advise a small business offeror client, in its offer in response to a set-aside solicitation, to object to the standard FAR set-aside clauses and to condition its offer on the Government's acceptance of substitute set-aside clauses faithfully implementing the 13 CFR and NDAA texts? And, would you advise a small business offeror client to file a protest of the terms of a set-aside solicitation before the date for submission of offers? Personally, I don't think the GAO would rule in the protestor's favor -- I'm not so sure about COFC.
  13. The GAO decision in B-299291 did not require or recommend a FAR deviation, or any re-writing of the FAR.
  14. Certainly, and appropriately. Contracting officers prepare solicitations, not prospective offerors. Contracting officers follow the FAR. Here is a serious question: Would you advise a small business offeror client, in its offer in response to a set-aside solicitation, to object to the standard FAR set-aside clauses and to condition its offer on the Government's acceptance of substitute set-aside clauses faithfully implementing the 13 CFR and NDAA texts? Class deviations are a matter for agencies and agency heads -- individual contracting officers need not be involved. If the FAR Councils wanted agencies to issue class deviations on this matter, they could easily instruct agencies to do so (such as was done for all the class deviations being done in civilian agencies on the raising of the micro-purchase and simplified acquisition thresholds). They haven't. Really, this is a political matter and it will be handled, or not, in political ways. Anyone upset by the matter and wanting to speed resolution should contact the FAR councils and/or his or her Representative or Senators. It is unfair and unreasonable to expect individual contracting officers to solve this problem.
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