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About jwomack

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  1. Sounds reasonable. Thank you.
  2. That would certainly be a change from our norm. The non-SAP protocols have apparently crept into the SAP acquisitions and just became the way it’s done for all contracts. Thank you. To take this a step further, do you think less formal closeouts could apply to GSA orders as well? I know they’re not Part 13 “SAP” nor do they meet the Part 2 definition, but GSA orders are, all things considered, pretty simplified acquisitions.
  3. A contract uses Part 13 procedures, FAR 4.804-1(a)(1) is applicable, and there are no agency specific regulations. As part of closing out a contract file, FAR 4.804-5(b)(8) requires the contract completion statement to contain “Voucher number and date, if final payment has been made”. What if there are multiple vouchers? Are all vouchers and dates required to be listed, or at least cross-referenced, on the contract completion statement? If so, why doesn’t (b)(8) read “Voucher number(s) and date(s), if final payment has been made”? Or, is only the final voucher and date required? If so, why doesn’t (b)(8) instead read “Final voucher number and date”?
  4. Be careful. No one wants to do business with someone who comes across as difficult or manipulative. That's a good way to make the naughty list.
  5. Shouldn’t that have been asked during the solicitation phase? Also, the only reason a probably-busy-KO may need to entertain your request in greater depth is if you had offered the lowest price but the offer was rejected for not having met the technical requirements.
  6. Another thing to consider is how much benefit the contractor will receive because of the change itself.
  7. See 31 USC 6303 and 31 USC 6304 to help determine if a contract or grant may be appropriate.
  8. Disagree, assuming a renewal option was part of the original agreement. Agree.
  9. Drabkin, but slightly different. Drabkin’s rationale - “…it only prohibits adding elected officials to the lease after it was signed…” I think the prohibition is more restrictive and also includes an individual’s status at the time the lease is signed.
  10. Probably not, but I may and I wouldn’t be prohibited by FAR from doing so assuming it provided benefit to the Government, etc.
  11. FAR 1.102(d). “In exercising initiative, Government members of the Acquisition Team may assume if a specific strategy, practice, policy or procedure is in the best interests of the Government and is not addressed in the FAR, nor prohibited by law (statute or case law), Executive order or other regulation, that the strategy, practice, policy or procedure is a permissible exercise of authority.”
  12. If it’s within SAP a Part 6 citation wouldn’t be necessary. Part 13 Procedures could be followed.
  13. I may be wrong, but the simple answer seems to be for the program office to submit a PR with funds for services rendered. The KO makes the award. Note to file as to why it’s not a UC and doesn’t require ratification. Contractor gets paid. Unless you’re trying to punish the program office or contractor for some reason, why make it any more difficult than that?
  14. What basis are you saying an Agency couldn’t execute a new contract based on its own determination, i.e., without a Court Order? What Part(s) of the FAR would be violated? 1.602-3, nonratifiable commitments, implies there was a commitment.