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  1. awayforward


    Thanks for the response. No, we are the prime and folks in our HR dept. and maybe "compliance" are indicating that we would have to issue sub mods to make them (the subs) aware of this EEO-1 reporting responsibility;However, I don't feel that Contracts has to be involved in this. The subs should be aware of the EEO responsibilities.
  2. awayforward


    Are prime contractors obligated to inform its subcontractors (via subcontract mods for example) to file their EEO-1 reports? Should we expect Agencies to modify prime contracts to address EEO-1 reporting requirements?
  3. awayforward

    Service Contract Act

    Ji, Sorry about dropping off. Yes, you are correct. the clause 52-204-15 was added via mod to the IDIQ. I now understand this reporting has nothing to do with the Service Contract Act 52.222-41 and the lack of Wage Determinations. Thank you for the clarification and insight.
  4. awayforward

    Service Contract Act

    For the first time, my company has recently been requested in accordance with FAIR (FAR 4.1703) to report labor value in SAM.gov under various contracts that contain the Services Contract Act FAR clause. One IDIQ in particular contains the Services Contract Far clause, but there was never any Wage Determinations included in the IDIQ or task orders. The legacy administration of this contract does not reveal that anyone ever questioned why there were no WD's. The contract is for the provision of IT professional services, and there have been some high dollar task orders over the years under this IDIQ. I am inclined to make the CO aware that no WD's were ever included in the contract, to question him/her whether it was appropriate to have the SCA Far clause in the contract (almost 10 years ago) considering the nature of the services provided, and perhaps do a mod to remove the SCA. It seems odd that report our labor dollars in the system if no WD's were included or likely flowed down to any subs.? Again, this is a legacy contract with quite a bit of history, and we are trying to figure out the best path forward.
  5. awayforward

    Past Performance

    If a solicitation states "Past performance information will not be considered for predecessor companies, proposed subcontractors or key personnel", does this mean if a proposing prime acquired company A and company B, the proposing prime cannot use company A &B's past performance? Why would the government exclude the past performance of subs. including newly acquired entities if it is relevant?
  6. We are a sub to a prime under a IDIQ prime. We were proposed as a sub. on a delivery order by the prime. We proposed T&M rates. We are working under a letter subcontract and are about sign the IDIQ sub and task order once the sub package is finalized. The prime is insisting on us completing a certificate of current cost and pricing data. Our Pricing manager is insisting we don't need to sign a certificate for a T&M task order. Who is correct?
  7. Retreadfed- You have everything wrong. The scenario is about to small business subs. under a prime, and what notification is required by the me regarding the assignment or novation of contracts of the 1 small business sub to another small business sub. I think the solid advice is to inform the CO as a courtesy even though it is not a requirement.
  8. I agree with advising the Contracting Officer of the scenario. At a minimum, some notice is required.
  9. Perhaps, I need to elaborate on this less than ideal situation. The change in ownership will likely involve a change in identity. Small company A performing under the IDIQ prime is a staffing company that only wants to concentrate on certain types of business (state and commercial). Company A would like to sell its federal side of the business to a separate and distinct small women owned company B that also has been approved to work under the same IDIQ prime. The principals of both companies are related but I don't think this matters, or does it (a rather typical SBA scenario?) Is the prime contractor obligated to inform the Govt that Company A sold its federal business to Company B (already approved as a subcontractor under the prime also?). Company A will remain as a corporate entity but not pursuing federal work. Clear as mud?
  10. Sounds like we would have to get consent for the new owner. Related question: what if a subcontractor requests the prime to consent to assign its sub to a 3rd party. Would we have to seek approval from the Govt to assign a sub?
  11. When a subcontractor notifies a prime of a change in ownership. What steps are required of the prime to the Govt? Is notice required? novation? or can we simply modified the approved sub to reflect the change in ownership? Do we have to get consent for the new owner/company?
  12. awayforward

    Subcontractor Protesting an RFP?

    Okay, thanks. I think complained to the SBA also.
  13. I never experienced this scenario before so I thought it I would run by the experts. Current Prime Contractor has a relative new IDIQ under which task orders are competed, Prime has a team of subcontractors (mainly small businesses). One of the small business team members has a prime contract also performing similar work (their prime was awarded as 8a set aside & is about to end). A task order RFP is issued under the current Prime contract, and it is for the work currently being performed by the small business sub. (i.e. the incumbent whose prime is ending in the near future). The small business logs a protest the with Government that their prime work shouldn't be competed under another prime vehicle (regardless, of whether they can potentially compete for it as a sub.). However, the subcontractor submits a bid as a sub to current prime while simultaneously protesting the RFP. Question: Doesn't it look bad for a prime if a subcontractor (team member) logs a protest? and submits a bid simultaneously ?. Does the sub have to do submit a protest through a prime or not? My thinking is if it is the small business' incumbency work, then they should have a pretty good chance of winning again as a sub. anyway. It seems like the Government contracts shop wouldn't hold this prime and sub in a very good light moving forward. Any thoughts?
  14. My company was small (SDB) when their GSA schedule was awarded and now, for option period 3, they are a large busines. Does size at time of award continue to rule ?, and therefore, no subplan is required for Option 3 renewal?