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illzoni

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Everything posted by illzoni

  1. I would rephrase... Part 6 doesn't apply to SAP/Part 13 per 6.001(a). CICA is applied differently within Part 13. The direction in Part 6 requiring sealed bidding doesn't apply in Part 13.
  2. I haven't been in DoD for nearly 3 years, but why would DFARS 215 apply to FAR 13? FAR 13 addresses instances of receiving only one offer, and DFARS 13 doesn't address it. So proceed with FAR 13.
  3. A higher cost of living may offset any increase in salary for the period you're there. However, that higher grade may open other doors that wouldn't otherwise be available. In other words, think both near-term and long-term.
  4. I'm a retired USAF/ANG SMSgt working for a non-DoD federal agency. I don't have a degree. The degree limits me to my present grade (GS12) and was the only thing holding me back from getting my Level 3. I say 'was' because I believe the requirements have recently changed and I'd have to redo a lot. Anyway, back to the degree... I'd like to finish it. I have about 180 credit hours stacked up from nearly a dozen sources. Several years ago Charter Oak and Excelsior (formerly Regents) were known as good places to take a few courses, provide transcipts, and finish out a degree with minimal fuss. What are the best (course of least resistance) schools for folks like me? I'm more inclined to spend more money and mess with fewer classes. Anyone else in this boat? Thanks, Jon
  5. Folks with DoD experience too often assume the DAWIA applies to all federal agencies. It doesn't. Many (most?) federal agencies other than DoD can and do hire 1102s without degrees so long as they have the business classes. Non-degreed 1102s are limited to GS12 however, as GS13 requires the degree per OPM.
  6. Sometimes I read the current (internet) version of the FAR and could swear I'm reading something new. It would be outstanding if there existed a tool for seeing what the FAR previously read and when specific sections changed. I do not have a stack of old mini-FARs on my shelves, so checking previous paper versions isn't much of an option. It would be great if something like the WayBack Machine (https://archive.org/web/) existed for the FAR and supplements. Does anyone know of anything close to what I'm (poorly) describing?
  7. No. The rules in Part 8 are not too complicated. Personnel who can't grasp the simplicity of SAP and Part 8 too often feel a need to impose restrictions that aren't needed.
  8. Any forum is only as good as its contributors. This is a valuable one.
  9. DOE job offer withdrawn, and more info: http://fedscoop.com/va-official-investigated-fraud-loses-lucrative-doe-gig/
  10. I agree. The vendors quoting via FedBid are willing to sell at a particular price, to which FedBid adds their 3% and presents to the government. While the government doesn't 'see' the added price, as all we see it the bottom line price, the simple fact the vendors were willing to sell at a lower price that is hidden from the government constitutes a serious problem.
  11. VHA policy on FedBid was nearly mandatory, as not using FedBed required a document in the file explaining why not. That didn't make any sense, as FedBid's task order was not a requirements contract. I'll be very curious to see how this affects the VHA HCA, Mr. Norb Doyle. He is/was Ms. Taylor's direct supervisor.
  12. Last reliable word I'd read was that Ms. Taylor has a new job elsewhere in federal government: "I am pleased to announce the selection of Ms. Susan Taylor to the career Senior Executive Service (SES) position of Director, Office of Procurement Planning, effective October 5, 2014. <snip> Thomas Johnson, Jr. Associate Deputy Assistant Secretary for Acquisition and Project Management Office of Environmental Management U.S. Department of Energy" Rumor is that job has been rescinded.
  13. The decision to mod the existing TO or do a new contract instrument doesn't change the documentation you should include (e.g. the justification). If your justification is good enough to warrant the mod, it's good enough for the new contract.
  14. The expired status of the IDIQ doesn't affect what you can/can't do with the TO. Logical follow-on doesn't justify modifying an existing instrument to avoid preparing a new instrument. As the word "economy" from your 16.505 quote only appears once in all of Part 16, at: 16.505 ( Orders under multiple-award contracts-- (2) Exceptions to the fair opportunity process. (i) The contracting officer shall give every awardee a fair opportunity to be considered for a delivery-order or task-order exceeding $3,000 unless one of the following statutory exceptions applies: © The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order. A new TO may be justificed, but the IDIQ has expired. You want to improperly modify the existing TO instead of cutting a new TO.
  15. Hold the phone, Maude! Past performance? LPTA. Lowest Priced, Technically Acceptable. If the lowest priced offer is technically acceptable, you award.
  16. He just doesn't understand what the "S" in SAP stands for. I've seen it all to often....experienced COs telling others all these complicated things they must do. When in fact the rules are much simpler and the 'experienced CO' can't differentiate between their experiences and the current situation.
  17. Vern, Is this a generic response or specific? Jon
  18. As in IDIQ/Requirements contract, it should include a guaranteed minimum. That minimum should be negotiated to cover the costs of effort you describe. The contractor is not obligated to perform until said minimum is funded.
  19. The exercise of an option is not a new sole-source contract. It is a continuation of the current contract, within the terms originally solicited and awarded (or justified). Sole-source requirements are not applicable. Deciding to exercise an option is not contingent upon a lack of competition. Appropriate competition should've taken place prior to contract award. The government may opt to not exericse the option and resolicit/compete (see next answer). The government must document exercise of the option is in the best interests of the government. This usually involves a market survey (complexity varies) to determine if the option terms (mostly pricing) is still reasonable. If research indicates the government would be best served with a new soclicitation, document so and press forward. See first answer for description of option.
  20. Oh, but sadly it has come to mean just that... From Wikipedia (http://en.wikipedia.org/wiki/Begs_the_question): "Despite having "long been condemned by usage commentators as incorrect or sloppy",[1][6] some authorities consider the use of "begs the question" as a way of saying "raises the question" or "evades the question" to be no longer mistaken because it has attained such wide usage.[7]" ...in similar fashion to the prefixes "semi" and "bi" when used to decribe recurring events. They've become so diluted with misuse as to be useless.
  21. Here's my take on the notices required under option period contracts and proper exercise of options... As far as CICA is concerned, the entire period of performance should be competed up front, right? Therefore, if something lapses in the middle due to administrative oversight, how does that affect CICA? It doesn't. It would not be a violation of CICA to either modify/exercise the option or award a new contract to complete the term of the original. What is the intent of 52.217-9? It's to protect the government's right to unilaterally exercise the option(s). If the contractor is willing to accept bilateral exercise of an option, why would anyone believe it wasn't legal? Further, what does it really matter if the contract has expired or is 'dead'? Of course the government is at risk during this period. However, if the contractor is willing to continue performance and accept bilateral modification to exercise the option, what law is being violated?
  22. I'll chime in as a former Level IV AOPC... The applicable threshold we're discussing is the Micro-Purchase Threshold (MPT), not SAP/SAT. It's clear the recurring bill (monthly) is within the MPT, but the yearly total exceeds the MPT. While no intent exists to conduct a "split purchase" as no one is facing a lump sum exceeding the MPT and figuring a way to split it into smaller chunks, requirements are known to exceed the MPT on an annual basis. As such, some other contractual instrument should be put in place (ref FAR 13.301(bravo). [Had to use bravo instead of 'b' because it kept inserting an emoticon.] A BPA is the most likely option and would be easy enough to implement. Simply get a Contracting Officer (probably the AOPC for the GPC) to execute a BPA with E-ZPass. A copy of the BPA or at least a reference to it should be maintained by the cardholder(s) making the payments. With the BPA in place, orders can be placed monthly IAW FAR 13.301(charlie)(2) to pay the bill. Jon
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