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newanalyst

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About newanalyst

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  1. Thank you to all who responded...you have given me much to think about. Thanks again...
  2. Can a commercial service be something other than Part 12?
  3. Current facts - Overhaul of commercial engine has been determined to be a commercial service Service was not competed Due to statute/regulation, commercial = firm fixed price (FFP) Vendor who completes engine overhauls does not firm fix price to their commercial customers. Some items in an overhaul are "on condition only", meaning the item will be inspected by the vendor and if it passes the inspection, will not be changed. When an engine is received by the vendor, the vendor determines what is required to complete the overhaul but can only assess that once the engine is received. If the Government is required to FFP based on the situation above, the Government may be paying more/less than what is actually required to overhaul the engine. If more facts are needed, please let me know..... Why did the powers that be mandate that a non-competed, commercial contract be FFP?
  4. Just wondering why no one has responded....Have I posted the question in the wrong forum?
  5. Has anyone requested/obtained approval for a reporting waiver? If so, was it difficult to obtain the approval? Thank you...
  6. The effort is a service, Contractor Logistics Support to be exact. Everything is commercial. When you ask if I think I can legally have a CR CLIN - in a nutshell, that was my question to the forum. Statutes/FAR say CR "contracts" are prohibited for acquisition of commercial items. Are "contracts" and "CLINs" considered the same thing? If they are, then I have my answer...it's not legal. If they aren't, then I would deduce that CR CLINs may be allowed on the contract. I am trying to understand the FAR/statute and determine in the process what the available options are for doing the right thing. I am not in the Acquisition/Contracts field by trade, but am an analyst in a Product Office who has the task of researching solutions/identifying risks and any mitigation strategies for leadership.
  7. CR CLINs would be for labor, material, and travel of efforts that are not well-defined (for example - crash damage repair, engineering services or as-requested additional maintenance support)
  8. Situation: trying to contract for commercial services and statute/regulation says that the use of cost-reimbursement contracts is prohibited for the acquisition of commercial items, and that agencies shall use firm-fixed-price contracts or fixed price contracts with economic price adjustment for the acquisition of commercial items. The majority of the effort is FFP (~92%) and we'd like to utilize a few CR CLINs (remaining 8%) on the otherwise FFP contract. Question: Since the statute/regulation specifies "contract", does that statute/regulation also apply to "CLINs" on the "contract"? I may be overthinking this...if I am, please let me know. Thanks!
  9. Thanks ji20874. I'll run this by our Acq Center...
  10. Not sure if this is the right forum for these questions, but here it goes... Scenario: We are in the process of developing an IGE and J&A for the production of a widget, but would also like to include retrofits/modifications to said widget. Retrofits/modifications must be made by widget's OEM (from an integration perspective) as they own the Tech Data Package and it currently is not for sale. Is it possible to contract for an unknown quantity, unknown schedule, and unknown dollar amount of retrofits/modifications? In other words, can my requirement simply be for retrofit/modification services without specifically calling out each retrofit/modification? Is there specific language that must be used in the J&A for such a scenario? If this is possible to do, has anyone done this recently? Would be looking for precedence to help bolster the possibility. Thanks in advance...
  11. Is Cost and Software Data Reporting (CSDR) (specifically the cost bit of it) required for commercial Contractor Logistics Support? I've reviewed DoD Manual 5000.04-M-1, dated 4 Nov 11, but it is a bit confusing to me. In Enclosure 5, paragraph 4.b.(2) the manual states "CSDR coverage begins at milestone (MS) A or the equivalent and extends to the completion of production. It continues through the sustainment phase if contractor logistics support (CLS) meets CSDR thresholds." Then in paragraph 4.c.(1), it states "The CCDR requirement applies to program contracts and subcontracts regardless of contract type based on the dollar thresholds established in Reference ©" which is DoD Instruction 5000.02. That paragraph goes on to say "CSD reports are not required under the following conditions provided the DoD PM requests and obtains approval for a reporting waiver from the OSD DDCA: procurement of commercial systems or for non-commercial systems bought under competitively awarded, firm fixed-price contracts, as long as competitive conditions continue to exist." The effort we are contracting for does exceed the $50M referenced it 5000.02, but it has been determined commercial and we are ending full rate production/entering the operations and sustainment phase. Thank you....
  12. Are Class J&As used that much anymore? In doing a little research, it appears they are not. Wanted to confirm that observation, and if true, ask why they are not used. In the current contracting environment, is it more difficult to get a class J&A approved v. an individual J&A? Thank you...
  13. Are Class J&As used that much anymore? In doing a little research, it appears they are not. Wanted to confirm that observation, and if true, ask why they are not used. In the current contracting environment, is it more difficult to get a class J&A approved v. an individual J&A? Thank you...
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