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  1. A couple of things I've gathered on the subject (some from WIFCON posts.) A vendor provides off-the-shelf, commercially-available goods or services. The vendor will provide these same goods or services to anyone who pays the vendor. A subcontractor is a person or organization who assists in the prime contractor in performing programmatic functions. The subcontractor is somewhat of a "partner" for the prime contractor and provides goods or services specifically tailored to meet the programmatic needs of the prime contract. Vendors Vendors sell identical or similar products to different customers as part of their regular operations. Examples include parts vendors supplying to automobile manufacturers, produce vendors supplying to grocery stores and consulting firms serving large businesses. These vendors operate in a competitive environment in which customers typically compare product characteristics before making a purchase decision. These characteristics include suitability, performance, price and guarantee. Large companies may enter into supply contracts with several vendors to ensure that problems with one supplier do not shut down the entire supply chain. Subcontractors Subcontractors may work for the prime contractors of major projects or for companies that need specific tasks completed in a limited period. Companies enter into subcontracting arrangements usually because they do not have the expertise in-house, and they need the services for a period that is not long enough to justify hiring a full-time person. For example, a residential-construction company may hire subcontractors to complete the landscaping on its houses, while the prime contractor on a defense project may hire subcontractors for writing technical manuals. Subcontractors may have their own vendors and subcontractors. Continuing with the example, the landscaping company may hire subcontractors to build an interlocking driveway and buy the sod from a local vendor of gardening supplies.
  2. Thank you for the responses. Basically the C/PA is advocating Scenario 3 that WhyNot presented above. Thinking the use of an abated G&A rate to cover only corporate flow down G&A may be appropriate.
  3. Competitively awarded contract for services with FFP CLIN (covering the majority of the work scope), a T&M CLIN for a small portion of the work, CPAF CLIN for another small portion of the work, and an IDIQ CLIN with the ability to place FFP, T&M or CPAF task orders on. (To date the IDIQ has not been utilized.) No cost detail was required in the award process for the T&M rates or cost type work. (Both CLINS were so small in relation to the FFP work. The CPAF CLIN values were provided as plug numbers for proposal purposes based on history.) Awarded contractor is an LLC partnership formed just for this procurement so this contract is the only final cost objective with only the distinct CLINS as intermediary cost objectives. Change order is issued to expand base work under the FFP CLIN. Contractor submits FAR Table II compliant proposal to support adjustment of the FFP CLIN including G&A. In support of the change order proposal, the contractor provided their G&A pool and base detail. The G&A pool is minimal including a modicum of corporate flow-down G&A from the partnerships corporate parents as well as a few contractor salaries and a few other G&A type expenses. Is the government cost price analyst correct in asserting that G&A should not be included because the increased work does not result in increased G&A pool base and under the assumption that the original competitive proposal would have been priced to absorb forecasted G&A?
  4. DCAA has a provided a memo stating what areas of the pre-award D/S are incorrect or require clarification now that we have an award. I need a CO to request the contractor to revise the D/S. Once the D/S is revised, then DCAA will perform a compliance audit of the D/S to determine if they are accumulating costs in accordance with the D/S. Used to be DCAA did an adequacy audit then compliance. DCAA no longer performs adequacy audits. They just provide informal memos listing what they find makes the D/S inadequate. (Hair splitting I know.) Thanks for your response Here 2 Help.
  5. In the absence of any other response/advice I'm going to recommend the CFA (DCMA) DACO provide a designation letter that our civ CO will be the CFAO for the CAS/DS, Accounting System, final indirect and forward pricing rates for only the FFS CAS segment executing the task order.
  6. I'm part of the civ agency....and I'm trying to coordinate the audit activity with DCAA,(accounting system, forward pricing rates, and the D/S). The D/S was received as part of the Request for Task Order process and still contains a lot of 'when we get the award language. We've done the walk through of the task order with the CAS segment and DCAA. DCAA's issued their inadequacy memo (including no CFAO on the D/S line) and now I need either our CO or the DCMA DACO to issue a memo to the contractor they have 30 days to revise the initial (pre-award) D/S. DCAA's memo was sent to both our CO and the DCMA CO and neither are acting on it and I can't seem to get a dialogue going between the two of them....
  7. Situation: IDIQ Contract awarded by civilian agency Contractor has a DCMA DACO (DCMA is Cog Fed Agency per FAR 42.003) Prime set up non legal entity CAS segment to execute task order Task Order administered at civilian agency as far as payments, task order mods, surveillance, etc. Task Order (at Task Order CAS segment level) is fully subject to CAS and requires D/S Who is responsible for the four contract admin functions set apart in FAR 42.302 for FPRA's, final indirect rates, CAS/DS, and Accounting System for the CAS segment the prime is executing the task order with? I've talked to DCAA, a couple of CO's and a DACO at another DoD location and I really don't have a firm answer. I believe it's the civilian agency CO at their contract admin office, per FAR 42.302. That CO says no it should be the DCMA DACO for the CAS. Although the civilian agency CO is taking responsibility for the accounting system. I think the civ agency CO is getting CFAO and CACO/DACO confused and is sure it will result in their taking overall all the current DCMA DACO responsibilities for the contractor above the task order CAS segment level. If it is, or can be the civ agency CO, does there have to be any formal designation from the DCMA DACO? So....whose name goes on the D/S????
  8. Answers to clarifying questions above. 1. Contract Spec. working for CO who just inherited this contract from a CO who left the agency. 2. Only mod clause is 52-243-1 Alt 1 Thanks for the answers above. The contractor is adamant they do not have to provide actuals because it is a FFP contract. They would be disclosing company sensitive data, etc. Stating that no where in FAR does it say they have to do this for FFP. They even quoted from 15.4 Sigh.
  9. FFP Service Contract contains FAR 52,243-1 Alt I . Contract originally awarded competitively. Contract mod issued to extend period of performance for specific task activities within the overall contract period of performance. (not an extension of the contract period of performance.) Requires certified cost pricing data. Contractor submitted proposal 6 months ago with not to exceed amount. Due to reasons which are not clear to me, the mod / propopsal was not acted upon so six months of performance has now been incurred. Requested cost anlaysis and the analyst insists since 6 months of performance has ensued that the contractor must submit actual costs for the work already performed under the change order. Is this correct if it is a FFP contract? I see FAR 43.204 requires CO to make sure cost analysis is performed if required under FAR 15.404-1© and while the various cost anlaysis techniques refer to verifying projected costs based on historical trend and comparison of costs proposed with actual cost previously incurred, is there no difference when it's a FFP contract? Does the contractor have to provide the requested actual costs for the first six months performance of the undeifinitzed contract mod proposal?
  10. Situation: FFP competitive contract for services including options for demolition services in the 4th and 5th year for of the contract performance period. Small business set aside. Tasked with putting in a last minute Econmic Price Adjustment clause to protect small businesses on three items one of which is fuel. Our team has no experience with FFP EPA clauses. Making progress on the research for being able to use an EPA and what the clause has to include but the question I can't answer is how do we determine the base price for the items we are providing an EPA clause for when we are requiring the contractor's only provide a bottom line FFP dollar value? Right now the option is to have them provide a basic table detailing their unit rates and estimated quanties for these items as part of the technical volume and not the pricing volume. We are only performing price reasonableness and not price realism.
  11. Working on solicitation under a multiple award IDIQ contract. The overall scope is to provide facility support type services. Initial Acq Plan was to award CPFF task order. Now we have management directive to consider pulling some scope out as FFP CLINs. The majority of the award will still be CPFF CLINs based on the significant uncertainties related to task order performance . Questions: 1. Can you have multiple contract type CLINS on a single IDIQ task order? I don't see that the main IDIQ contract specifically allows or prohibits this. 2. What are the risks associated with mixing FFP and Cost type CLINS in the same contract action? Initial concern is that some scope such as program/project management is going to cross over into both FFP and CPFF CLINS. Currently we have planned on the offerors bidding such costs to the specific PWS activity to which they would apply versus a single PWS encompassing all program/project management activities. My first thought is that is still the best pricing strategy with the mixed CLIN types. What pricing strategies, cost instructions, etc, need to be considered to mitigate identified risks for mixing contract types in same award action? This change in direction, per the voices from the heavens, has happened vitrually overnight and the acquisition team is now scrambling to react ....
  12. Thanks to everyone who responded. As I'm replying here it's with total frustration over this acquistion because our IPT (of low level peon personnel) initially did not want to go with this approach but we were 'forced' to by the mid level management team. Now after a presentation to the Ivory Tower, the Ivory Tower is expressing the concerns we had over use of an IDIQ task order which were dismissed by the mid level approvers. Ack! BTW - I've learned more reading the WIFCON forum in the past 6 months (since I stumbled upon it) than in all the 1102 training classes in the past 3 years.
  13. Is anyone aware that Don was correct 2 years ago? Is anyone aware of any protests, decisions, etc with using a multiple award IDIQ contract and then issuing a single IDIQ task order? After researching the practice here and through other sources, I'm not convinced its the way to go on a current solicitation. If anyone has used this FAR 1.102-4(e) 'not prohibited and therefore deemed innovative' practice and has any words of wisdom or advice please respond.
  14. With 20+ years of service, I've completed many a survey, including the recent FAI 2012 survey. Admittedly I ignored the first couple of survey notifications emails because I've never felt a survey asks the right questions to get the response I want communicated and I just didn't feel like "doing stupid today". It generally feels the surveys are designed to produce the responses desired. But after a prompt from our head of contracting, I did my civic acquistion community duty. <Salute>
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