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About jwomack

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  1. No. If your agency has a contractual obligation to pay for services then the obligated amount has to be reserved for the future payment of the obligation. Changing a contract's method of payment (e.g., EFT vs Purchase Card) doesn't change this.
  2. It depends on how desperate the agency is and what their alternatives are.
  3. I'm not suggesting total risk avoidance. Just that risk must be considered.
  4. Ever worked in a small contracting office with limited COs who work for someone who is not a CO and doesn't understand federal contracting? Typical scenario - Office needs a CO to buy basic supplies via placing GSA orders. A GS-7 in some random career field is given minimal training so they can receive a warrant and place orders as a collateral duty. The office who needs the CO convinces the warrant-issuing office to give the newly trained person a warrant. A more competent CO in the office who normally handles more difficult acquisitions leaves. The office is now down to one CO...the one who barely knows how to place GSA orders. There's still a need to make the more complex (sometimes Part 15) acquisitions. Who do you think the CO's boss is going to assign the acquisition work to? The sole, incompetent CO in the office who has an unlimited warrant (because the warrant-issuing office didn't recognize the risk associated with giving this incompetent CO a warrant above his/her capabilities)? Or to another office with more competent COs?
  5. Minimal risk is still risk. That being said, I agree a deep bench should be a significant consideration and that most(?) agencies are too stingy. I've seen this a couple times and, in both situations, the COs' ego was the driver, not the agency's needs.
  6. What if the alternative means doesn't have the time/skillset/mission to award contracts? Maybe DCMA should close its doors?
  7. I suppose my comment could be read as a negative thing. But I meant it as there’s no need for agencies to issue something like an unlimited warrant when a $100k warrant would get the job done. Issuing warrants above what’s necessary increases risk to the agency.
  8. What’s a “real KO”? Just because someone’s warrant is low doesn’t mean they’re untrustworthy or lack judgment. Responsible agencies issue warrants on an “as needed” basis not an “as capable” basis. Who cares if a PCO of an IDIQ can’t administer their own contract? As long as the agency has alternative means, who cares? Just because it’s not customary doesn’t make it fake nor invalid.
  9. The $1 warrant was obviously for illustration purposes only.
  10. jwomack

    space cowboys, weed, safety, and NASA

    There could be security clearance requirements requiring compliance with all federal laws (for safety reasons). Maybe the contractor drives a government vehicle and local clauses prohibit drug use as a safety matter.
  11. FAR 1.602-1(a) only restricts the amount the CO may bind the Government. The FAR 2.101 definition for “contract” implies that bind means the extent the Government is obligated to pay for something. In this scenario, that would be $1. Therefore, a CO with a $1 warrant (i.e., the precise amount required to create the binding contract) would not be restricted by FAR from entering into the $100M IDIQ contract. An agency’s intent when they issue warrants may be more restrictive. If there’s any doubt, clarity should be sought from the issuers of the warrant (as ji20874 mentioned). Every agency I’ve worked for has supplemental policy to address this type of thing. Not just for IDIQs but for contracts with options, mods, task/delivery orders, etc..
  12. Article about private industry funding university research. It's a common practice. https://www.theatlantic.com/education/archive/2017/04/public-universities-get-an-education-in-private-industry/521379/
  13. You can modify a contract after its POP has expired. It’s not uncommon, nor improper, to do this for late invoices.