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About Nanook

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  1. Nanook

    DCMA not accepting Proposals marked 'NOFORN'???

    Could this have to do with Controlled Unclassified Information (CUI), under Executive Order 13556? 32 CFR 2002, providing guidance for implementing the CUI program, is supposed to be published next year but the EO was issued in November 2010 with a multi-year phase-in period. You can access more information at: www.archives.gov/cui/. Hope this helps.
  2. Retreadfed - Yes, and that's why I was trying to get as much supporting information in advance. Again, not that it's not permissible or that the KO/CO won't win; this is round 2 and DCAA pushed back hard on round 1.
  3. Vern - no disrespect but I'm going to end this thread. It's taken a turn to issues that had no bearing on my initial question. While I respect and appreciate everyone's input, I was just hoping that someone might have the DoL guidance I couldn't get from their SCA office and I know that the WDs are minimums which can be exceeded when justified properly. If anyone wants to continue this discussion, they are more than welcome to. P.S. Recently left the government and now work for a contractor.
  4. Retreadfed - you have it precisely. The concern is not whether it properly can be done - it's doing the advance work so that, should DCAA disagree with the KO/CO (nawwww, we've never seen that happen) and turn it over to the IG, there is DoL's own document and guidance, the keepers of SCA Wage Determinations, supporting its permissibility. Thanks
  5. ji20874, I did not very well articulate what I was hoping to locate - here it is: because DoL gave me an assurance that exceeding their WD was permissible AND they would send me their guidance supporting that position, that DoL guidance is ideally what I am looking for. The two variations of your framing of my question have both been very thoroughly answered (thanks to everyone who replied). Also, for people just jumping on this thread and preparing to hit send on their advice, akin to, 'Well, why don't you just ask DoL?' - I have repeatedly talked with their office and gotten assurances they would email me the document (they won't give out their email addresses), to no avail. Thanks all.
  6. Retreadfed - Currently paying higher than the WD because exactly that - turn over which is adversely affecting performance. CO/KO and contractor all in agreement. Issue is NOT is this in the govt's best interest OR whether it's permissible. Sole issue is whether there is any written guidance affirmatively supporting this (Note - not an absence of written guidance not otherwise prohibiting it). Thanks
  7. C Culham, Awesome! Thanks for the additional guidance. I'll post what they send me....if they ever send it to me.
  8. C Culham - thank you. Even DoL indicates this isn't necessary because: 1) there's an existing WD, and 2) we're looking to exceed the WD. I appreciate you looking out for me,
  9. All - thanks for the comments and insight. This is not a case of being on the side of right - clearly, the Contracting Officer can and will prevail but we all know how painful that can be, and how much time and effort is spent in the process. I'm still kinda hoping that some can put their fingers on the DoL-promised guidance...while I doubt it is dispositive, I'm hoping it provides some regulatory basis beyond the FAR. Retreadfed - short answer - non-competitive follow-on (all I's dotted and T's crossed). So, yes....the desire is to attract and retain people with suitable clearances in an area where demand for these employees far exceeds supply.
  10. Styrene, Thanks for the reply. I concur wholeheartedly but this is Round 2 and DCAA pushed back during Round 1. Thus, I was hoping DoL would send me their guidance and why I'm looking for something 'more.' Thanks again.
  11. Facts: 8(a) sole source Contract at a facility with clearance requirements and limited labor pool. Contracting Officer, having done required due diligence and fair and reasonable determinations, wants to exceed the DoL established SCA wage determination. Despite contacting the DoL SCA Wage Determination Office and getting their assurance that it was permissible and they would email supporting guidance, nothing has been sent (note - not being critical of them; people get busy). Looking for any written guidance or regulation, internal to DoL or otherwise, that would support exceeding the WD. Thanks in advance.