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general_correspondence

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About general_correspondence

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  1. Thanks to what Bob Antonio uploaded to the Forum today, I was informed the CASB meeting today in DC is addressing the very issue I came up against.
  2. If you're in good health, it wouldn't be a bad thing to contract this virus, it's the only way humans build immunity to them when they come around again.
  3. I'm a subcontracts manager for a prime contractor. As a Prime Contractor, we have several task orders issued from IDIQ's. Many of the task order are multi year. For example, one of the task orders has a 3 year period base term. Another one has a 24 month base period, with three (3) one year options. etc...
  4. Don't feel as though you are confusing things, it's hard to be crystal clear writing back and forth in chat rooms, the fact its regarding FAR and contracts makes it even more cloudy 😄 so here's the thing, As I mentioned, I work in Subcontracts, and although I'm fairly certain subcontractors (large business) we outsource to under the aforementioned conditions will be CAS covered if the $ exceeds 750K, the contract documents and review documents at the contract level, indicate NO CAS, and that is exactly correct because when awarded an IDIQ with ceiling of $10,000, CAS is not applicable. However IDIQ's are the vehicle for task orders, and so here we are. Is the large business I subcontract under a task order where the dollar value is >750K, be a CAS covered subcontract? I can't get answers from our own compliance or contracts people to these questions, I am good with the answers you an several others gave me regarding the small business that was acquired by a large business scenario, so I'm down to this final question of CAS applicability to the prime's subcontractor under a task order under an IDIQ that was awarded w/ $10,000 ceiling, and documented by the Primes internal team as "NO CAS" required.
  5. taking out the small/large business aspects of this original post, would the IDIQ award we received from the government that has a $10,000 minimum IDIQ Value, determine all or any subcontracts awarded under the Prime contractors task orders be exempt from CAS coverage? Said another way, assume we get a task order and we included a large business in our Bid, - would this large business be subjected to CAS?
  6. Thank you Jacques, I think that makes sense, but are you implying that when its time to renew their annual representations and certifications to us, this subcontract suddenly switches to a CAS covered contract, requiring a notice to both supplier and contracting officer?
  7. Retread, I trust your right, BUT - they were only small because of the NAICS code of the work? All other NAICS they operate under they were a large business. (I should have mentioned that in the OP) Also, the research Jacques did with the Cibinic & Nash, seems reasonable not to continue to keep documenting this large business as a small business forever? No?
  8. Retread the small business was acquired by a large business 6 months ago, shortly after we awarded them their subcontract ?
  9. the minimum value of the IDIQ ceiling is $10K. As stated, this is minimum ceilings at this IDIQ. We were awarded a 24M task order a few months after the base IDIQ was awarded. FAR 52.230-2 is in the IDIQ contract, and the task order release states the parent IDIQ clauses apply. I am the subcontracts manager. I issued a subcontract a little over 2M. The subcontractors 2M order is part of our overall 24M task order contract. We will increase the subcontractors order by 100K, CAS was not applicable at the time of the subcontractors award, but they are no longer a small business, Do I notify the contracting officer we have a CAS covered contract once I modify the subcontractors contract?
  10. you are correct, but task orders would have to be new work, would they not? It's not as though dozens of task orders are in the multi millions of dollars with several large DoD prime contractors and none of them are CAS covered due to the ceiling minimum value of the IDIQ?
  11. We are a prime contractor with a multiple award IDIQ from the government. (DoD) The Department of Defense awarded an IDIQ to multiple Primes/ FAR 52.230-2 is in the IDIQ contract. We were awarded a task order, and we have a subcontract included with our task order work. The subcontract at the time of award, was a small business, and the value of this subcontract at the time of award was >2M. We have a modification coming to the contract where will add 100K to this subcontract. Since the time of award to the Sub, they were acquired and are now a large business. Will the modification to the subcontract of 100K, effectively making the total subcontract value $2,100,000 be a CAS covered subcontract?
  12. Thanks Jay but I used the NAICS - I think it's appropriate for NDA, not teaming agreements
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