Beverly

I'm trying to convince my corporate office that we can make this change because they keep saying we can't but won't give me any authoritative reason why not. Our contract is suffering under this burden but my corporate office is holding hard and fast. My direct manager asked me to put some research together with quotes/citations to substantiate why we can or why we cannot make this change. We all here seem to agree that the Prime can chose whatever type it feels reasonable, but I can't find anything from an authoritative source to substantiate that one way or another...other than what I found in the CAM. I'm not looking to incorporate the CAM, I just need something from a quotable source. Do you have something other sources I can use?

We have that covered. We require the team sub employees to enter time into our timekeeping system which has charge codes for task orders and other work that we have, then they invoice based on a weekly download of the entries through a preprocessor file. They are not allowed to invoice for any labor other than what they put into our timekeeping system. Since we have their hours and we have their fully burdened labor rates we are able to accrue their costs real time. EACs, budgeting, tracking, etc. is all done at the Prime level. LOF is also at the Prime level. Since we know every week what the team sub charges are, when we hit a certain point on the funding on a task order we shut off the charge codes and redirect the employees to other work until the government customer comes through with more funding. We are truly a blended team. Can you think of any other authority that says the Prime can pick the type or an authority that would require us to keep our subs as task order? Thanks for your help! P.S. We have had over 250 task orders this first year of the contract....and we have to have so many subs so we can meet a 33% small business goal that breaks down into further socio-economic goals.

Cajuncharlie, Thank you for your quick response. We are very committed to our team subs so no worries there. The problem is maintaining task orders on 12 team subs in a seamless environment has become beyond an administrative burden that the government is paying for. We are considering changing to level-of-effort and removing all task ordering language from the team subcontracts. We would manage by total hours for the workforce on the subcontract and not by task order. Our contract team is so seamless that we have managers and directors in our org structure that are team sub employees. Almost all of our subs have the same labor categories and workshare is based on percentage of work received from the government. Its an unusual situation that our government customer liked because then we weren't married to one indvidual company that controlled a portion of the work on the contract, its all intermixed with the Prime being the overall controlling entity. There is no requirement in our contract on type for team subs. The only authority I have been able to find that says the Prime can chose the type is the DCAA CAM 5-611 Subcontract Award and Administration . Do you have another authority I could reference?

If the Prime Contract is an IDIQ task order contract, is there any authority that would require that the team subcontracts also have to be IDIQ task order? Our team subcontractors were proposed IAW FAR 9.601(2).