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  1. I wouldn't be relying on FPDS but your concerns have to be clarified with some documentation. If you have the subcontract agreement in your hands from the prime with a period of performance that extends beyond public recorded date by the USG, get something from your direct customer that clarifies this.
  2. The prime simply needs to flow down their tax exemption certificate for the subcontractors use.
  3. no definition to that word other than it is defined as: "Change Order", 'Amendment", "Modification". a formal written order describing the changes to be made, issued and signed by the prime
  4. I meant FTE, full time equivalent Joel asked the most obvious question thus far, "where is the changes" I should have the same enthusiasm as Here 2 Help to discover what carrying costs means, but I am leaning on the Redtread comment and Joels latest comment. The subcontract clause in the contract is titled: "Contract Direction/Changes" the full language the subcontractor is using to stake this claim from their agreement is as follows: "The contractor shall submit any "proposal" for adjustment under this clause within 7 days from date of the written order. However if the primes subcontract manager decides the facts justify it, the subcontract manager may act before final payment of the contract. If any changes causes an increase or decrease in the time required for performance of this contract, an equitable adjustment shall be made in the contract price, the delivery schedule, or both, and the contract shall be modified accordingly" 2 key points to that language are I never provided a change or written directive to prompt a proposal, and 2, the contract is a long way away from the final payment of the contract. we the prime never received a suspension notice from the USG, we have been working on non permit related activities.
  5. The permit is the responsibility of the USG, In addition to the FAR clauses in the subcontract, there is a "changes" clause that says: If any changes causes an increase or decrease in the time required for performance of this contract, an equitable adjustment shall be made in the contract price, the delivery schedule, or both, and the contract shall be modified accordingly" This is why I wanted to know what is the rule of thumb or FAR accounting principle anyone knows that can be used to baseline this negotiation?
  6. We are the prime contractor on a CPFF with our DoD customer. We have a FFP subcontract for construction work. Permit delays, neither party liable for damages, considered an excusable delay. The subcontractor gave us Notice of these delay impacts when required and in conformance of the contract. However the most recent Notice is a claim for carrying costs. Is there a rule of thumb, or an accounting standard that the prime should use to negotiate the costs being claimed by the subcontractor? The delay has been well beyond 6 months, The subcontractor has told me they have "diverted" most of the field labor during this delay so the costs are FE, likely OH and G&A type mostly, including Fee. (Fee may be prohibited?) Is there a process to use to baseline negotiations, in order of precedence the contract has: FAR 52.242-17 FAR 52.249-14
  7. Joel In one of your posts you said Joel, I don't know what "spread over all activities" are you saying this field person was not proposed or currently being billed as a FE? If I was the owner I wouldn't want a field supervisor PE on my project? splitting his hours and attention to any project other than mine? So the accounting system, in practice, is allocating costs spread out over several project sites but the person is at one specific construction site?
  8. I am a subcontract manager for a prime contractor. Yes, the prime contractor is responsible for documenting the NAICS after developing the SOW they contemplate issuing in a RFP to potential subcontractors. Yes, many program managers as well as subcontract managers working for prime contractors want to prequalify and create a Bidders list compatible to the SOW. In doing so, the pool of potential subcontractors may contain Firms not represented to the RFP NAICS, if after reviewing previous orders to the Firms we want to include in our bidder's list, we discover the reps & certs they have on file with the prime, do not contain a NAICS aligned to this current SOW, do we have a responsibility to not solicit these Firms? Is it a requirement for the USG contracting officer to solicit Firms represented only in the NAICS of the government's RFP?( If so, what is the Reg?) Because these Firms (subcontractors) can be in SAMS as many often are, would the NAICS need to be, or should be, represented in at least SAMS, or the annual certs we (the prime) may have on file, before we send a RFP to them? The Bidder's list contained Firms that we (the prime) knew, have not been represented to NAICS on the current reps & certs we have on file for them, however the RFP cautions that any potential award would require the awardee to represent themselves to the NAICS in the RFP, and that can only be accomplished by sending in updated reps & certs with their proposal. In order to get the award, a Firm may represent themselves to a NAICS that was not otherwise represented to the prime on other previous subcontracts we awarded to them. Is their a perceived ethical issue with suppliers turning on a dime and adding NAICS to offers in order to receive awards, or do these Firms have to involve the SBA and inform or document to the SBA they are adding NAICS codes to their offers for prime contracts? Or is it the prime contractor responsibility for these responsibility matters?
  9. Prime contractors have the responsibility to ensure not to, or document debarred and excluded subcontractors. The central contractor registry, ORCA, EPLS, etc...are defunct or consolidated down into SAM.gov. Subcontractors are not required to register in SAMS. I believe all this to be fact. Does this mean the Prime is relying on self certification from the subcontractor on debarment ?
  10. you didn't think 1.9T was actually going to fix your pot holes and bridges did you? The money is staffing diversity officers, HR compliance auditors, federal over reach on States, federal overreach on federal contractors, IRS agents. woke up.
  11. There is a difference between a subsidiary and a wholly owned subsidiary. What is the status of company A after the purchase? If they are a wholly owned subsidiary of Company B they may be able to remain the ELB.
  12. Neil I think you're right. That is a sound approach, I have seen it done before too. thank you
  13. I seem to remember if a Prime contractor uses (issues a purchase order) to a government facility to perform some qualification testing for example, that procurement is considered a competitive procurement. Is this true ? If so, where is reference for this for a file write up? The Prime has a CPFF contract and FAR 52.244-5 is included in Primes' contract.
  14. I thought as much, we do have to include option pricing but I agree option pricing should not go towards the small biz goals
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