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elf949

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About elf949

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  1. Velhammer -- yes, the SBA is telling us that unless the SB is certified in SAM under the manufacturing NAICS code for the acquisition, we cannot claim the award in our SB goals. We can buy from them, but they would have to be coded in our system as a "large" business for that procurement. We were told to have our vendors enter as many manufacturing NAICS codes as possible in SAM. We were also told that in our next SBA audit, they will be looking specifically for NAICS codes printed on the RFPs/ITQs and on the POs, and they will be matching them to SAM to ensure that the vendor is indeed cer
  2. I found this old thread and felt I should provide an update to it based on my recent experience with a bit of NAICS Code turmoil in the Prime Contractor arena. I work for a NASA prime contractor and we have our Small Business (SB) goals to meet, and we usually do a pretty good job of meeting those goals using small distributors around the country. These SBs supply the parts we need to support the Engineering & Technical services we provide. By procuring from distributors, we can claim the SB dollars associated with those buys. We have recently had to come up with new processes to acco
  3. FAR says that hourly rates in a T&M contract are fixed. FAR 16.601(c )(2). ?The contract shall specify separate fixed hourly rates that include wages, overhead, general and administrative expenses, and profit for each category of labor.? (emphasis added) This is further confirmed in the T&M payment clauses in FAR 52.232-7 and Alt I of 52.212-4 Alt I. They provide for calculating payment for labor by multiplying the hourly rate by the numbers of hours. But, as Vern points out, FAR is direction to Government contracting officers, not to a prime contractor.* A prime contractor must fol
  4. In my 30 years of working for a prime contractor, the requirement for consent has never been cumulative, but is based on the individual procurement transaction amount (& type). Also, with my company, change orders stand alone as separate transactions for consent consideration. So if the change amount does not exceed the consent threshold, the change does not require consent. In your example, there are 2 separate subcontracts issued, each of which is below the consent threshold, therefore, neither of them would require consent.
  5. A few things to ponder on this subject: The EO does not cover managerial or supervisory positions, and does not require job offers at the same level as the incumbent contractor. No indication in the EO that new contractor must keep predecessor employees "whole" -- same rate, same benefits, etc. So in order to remain competitive, you must bid minimum hours, bid minimum SCA rates and employees (new or old) may have to accept cuts in pay to support your proposal price. Perhaps not many predecessor employees would want to stay with the new contractor at a reduced rate. Guess that depends on
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