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CDBurner

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  1. I know this is far from universal, but there’s a tradition in many organizations I’ve been a part of to build paper contract files with the actual contract document/modifications on the left-side of the file, and all other supporting documents on the right. I’ve searched high and low, but can’t seem to find the genesis of this tradition in the regulations, defunct or current. I get the practical reasoning behind it since it allows quick and easy access to the actual contract, but as with many other best practices we’ve found some PCOs have adopted this as holy gospel without knowing where it
  2. Thanks, so in practice it sounds like definitzation schedules are just built with the end goal to have definitzation happen 180 days after qualifying proposal with the only constraint upon timelines for receipt of the proposal being the 217.7404-3(b ) of "timely", which I guess is left to the PCO's/Contractor's discretion. Is that how you read it? I've been looking through the Federal Register notices to see if I can see why this changed. Anyone aware of reasoning here? (besides busy and effective industry lobbyists) Weird that DFARS 243.204-70-3 retained the "after issuance of t
  3. I'm a little confused on UCA timelines, and was hoping someone could help set me straight. Background: FAR 16.603-2 (c) states in regard to Letter Contracts, "The schedule will provide for definitization of the contract within 180 days after the date of the letter contract..." DFARS 217.7404-3 (a) "UCAs shall contain definitization schedules that provide for definitization by the earlier of— (1) The date that is 180 days after the contractor submits a qualifying proposal...." Questions: 1. I'm assuming the DFARS "further restricts" (although I'm not sure how that'
  4. Ha! "inadvertently inserted", that's funny. Refreshing to see someone breech (if only for a moment) the sanctimonious self-serious tone that usually pervades these things to have a little fun. Too bad the stiffs got to it. Or maybe I'm being too harsh, maybe the "stiffs" knew about this all along and just agreed to leave the link up for a day or so. I just hope whoever "inadvertently inserted" this doesn't get in any trouble.
  5. I've had similar thoughts, hopefully that's how GAO would see it too (if it came to that). I realize I've necessarily been a little light on the details, perhaps even a little willful obfuscation. Suffice it to say I've discussed with KO, and the KO is looking for suggestions too. Just reaching out to a lot of different resources, just appreciate the insight and opinions of those who have been around longer than I. Thanks Vern. The insight on the fine differences on prices is appreciated. I've been told of a legal doctrine of "substantially identical" when prices ge
  6. Let's say there is a tradeoff source selection where the Evaluation Team is having a really hard time coming up with discriminators to recommend to the SSA. Prices are within fractions of a percent of each other, technical evaluations are very similar, having a hard time coming up with any sort of objective valuation of strengths. Past Performance is essentially identical. I'm sure this isn't the first time this has come up, what have others done in this situation, and how did it work out? Just go ahead and recommend a decision on small differences no matter how fine? Continue evaluating
  7. I have some friends who want to send in their own designs for the wall through the FBO posting (you know crayons, glitter, crate paper, etc.) as some minor civil disobedience. I've warned them that this probably won't have any effect besides making those DHS contracting folks' life miserable. Thoughts? Also, I'm not aware of any laws against making "frivolous proposals", but there still may be some. Anyone aware of anything like that?
  8. Scenario: Competitive cost-type solcitation, two offerors received. We are performing cost realism analysis as required by FAR 15.404 and have evaluated some areas of the offerors proposal as low in comparison to what we feel is their probable cost. We will be entering discussions to hopefully cure these concerns with the offerors via evaluation notices ; however, there are some in our approval chain who believe that all concerns that effect evaluation criteria (realism in this case) should be classified as deficiencies. If after discussions these concerns are still not resolved to our sa
  9. Perhaps I wasn't as clear as I could have been. I didn't mean to imply you had to get a sole source justification to make any single award IDIQ >$103M, I was complaining about the requirement in FAR 16.504 ( c )( 3 ) The requirement for a determination for a single-award contract greater than $103 million:( i ) Is in addition to any applicable requirements of Subpart 6.3 So any single award IDIQ >$103M that is also sole source not only has to get a sole source justification, they also have to get the single-ward waiver. (Department of Redundancy Department) In this case I’d like to fin
  10. “FAR 16.503( b )(2): No requirements contract in an amount estimated to exceed $103 million (including all options) may be awarded to a single source unless a determination is executed in accordance with 16.504( c)(1)(ii)(D).” First off I don’t like this rule. I believe I understand its intention, but I think it ill-conceived and if followed in-letter, it is constantly violated in-spirit (at least in my organization). I also see it somewhat silly making this a requirement in addition to other sole-source regulations (at least 6.302-1) since why would we want to approve a single award, when w
  11. Just curious, what's keeping you from looking into alternatives? I know we have preference for commercial products, but if the only product out there isn't be sold at a reasonable price, it seems like you'd have a fair case to look into paying someone to develop or alter a product that would meet our needs that we would have rights to effect further competition and hopefully drive down price in the long term. I'm sure you've considered this, but just wanted to put this issue into context .
  12. We encountering similar pressure to increase the use of cost incentives, and while exploring some similar Navy requirements encountered CPIF LOE type contracts. We're looking into it, but was curious if you have learned anything additional since it's been more than a year since you posted this.
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