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Everything posted by awayforward

  1. Thanks. I agree and think this one needs to be kicked up to our HR /compensation staff.
  2. I am asking if we can charge the Govt for HOLA and COLA & DBA for someone who is on disability (S/T and L/T)? Can the employee remain overseas in his/her housing, etc. while on disability and who pays for it?
  3. We have an employee who lives overseas in country A but also works in country A under our DOD prime contract and is eligible to receive HOLA, COLA & DBA under our CPFF contract. The employee has gone on short term disability and will soon go on long term disability. Can the Govt. still be invoiced for HOLA and COLA & DBA during both short and long term disability absences? or should we, as the prime contractor, pay these costs directly (and not expect reimbursement from the govt?). How should these allowances be handled and is there any specific guidance for these circumstances ?
  4. 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.
  5. 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?
  6. 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.
  7. 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
  8. 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?
  9. 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?
  10. 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.
  11. I agree with advising the Contracting Officer of the scenario. At a minimum, some notice is required.
  12. 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 pr
  13. 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?
  14. 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?
  15. 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
  16. 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?
  17. If Government Agency ABC is going to fulfill its IT requirements by using/soliciting small business GSA Schedule holders only, and my company is large business partner in a Joint Venture with a small 8a company, and the joint venture is considered small by the SBA, - does the JV have to have a GSA Schedule in order to participate in a GSA solicitation issued by Agency ABC? I don't think a JV can obtain a GSA schedule, can it ? -Does the small business partner in the JV have to have a GSA schedule in order for the JV to parcipate in the soliciation Agency ABC? -Can we as the large business
  18. Can a exempt employee, work on an SCA -covered contract (in a WD labor category)? and what are the implications of them doing so ? Isn't it less complicated (cleaner) from an accounting standpoint if non-exempt workers/employees work on SCA covered contracts in the the appropriate WD labor categories ? (in other words, having company classifed non-exempt hourly workers only charge to the WD labor categories?)
  19. The schedule rates are discounted for the particular sub in question, as the sub's rate structure is below the schedule rates. Note-This is not the first time I see this particular situation around the beltway. Small business goes to large business/schedule holder stating we really would like to pursue this GSA schedule opportunity but don't have an xyz Schedule, can we use your schedule (prime) as a pass through. It doesn't really seem appropriate but it is done. In this present case, we didn't hide the fact that it was a pass through.
  20. Okay. Understood. I did check and didn't see the limitations on pass through clauses in the FSS or the solicitation so the next move would be to ask the schedule ACO. Thank you again for the food for thought.
  21. It appears these clauses apply to cost reimbursement type contracts. The procurement is off GSA Schedule and T&M is contemplated. T&M is technically a cost reimbursement type contract so the pass through limitations would still apply. Too bad that more thought did not go into the proposal process instead of knee jerk effort to assist a company that didn't have a GSA schedule.Lesson learned.
  22. Can a GSA schedule holder allow a subcontrator that doesn't have a GSA schedule to use its GSA schedule and only charge the subcontact a "pass through" charge. Is this allowable ? The prime has little or no involvement in the proposed work. Are schedule holders around the beltway doing this more often than they should, and not realizing that it is bascially unacceptable and frowned upon? In a nutshell, we allowed a subcontractor who we know well and teamed with many times (and is the incumbent doing the work at an agency) an opportunity to use our GSA schedule for a specifc procurement desi
  23. Our prime IDIQ contract has clause 52.244-2 including alt I, requiring consent for T&M subs exceeding simplied threshold. We (prime) do not have an approved puchasings system. The sub. we want to add at the task order level, will require consent. The sub has an approved purchasing system, so will we have to obtain consent for the subcontractors 2nd tier sub at the same time?
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