Jump to content
The Wifcon Forums and Blogs


  • Content count

  • Joined

  • Last visited

Everything posted by sjanke

  1. FAR 52.204-3 Taxpayer Identification, para. (e) includes "International organization per 26 CFR 1.6049-4;". But when I check the CFR's, §1.60 is shown as [Reserved]. Am I missing something?
  2. FAR 52.204-3 Taxpayer ID

    Thanks. I did now find and check 1.6049-4, but there is no reference to "International Organization". It appears there may have been an update to the CFR. When I search for it on the internet under this link: https://www.law.cornell.edu/cfr/text/26/1.6049-4 "International Organization" shows up six times, five of which are in Example 3, Item (G). But in the CFR website (" e-CFR data is current as of December 29, 2016") a search for "International Organization", does not show up any results at all.
  3. I am working on a proposal to DOD DTRA and the BAA requires a small business subcontracting plan, but does not provide an example of the format DOD expects to be followed. I searched the internet and have been unable to find any examples. I have worked on plans for DHHS in the past and they would provide a template. The BAA simply refers to the FAR's: "Any Offeror, other than small businesses, submitting a proposal for an award with a value more than the amount listed in FAR 19.702(a)(1) and that has subcontracting possibilities, must submit a subcontracting plan in accordance with FAR 19.7" and " The narrative in the subcontract plan must address each element listed in FAR 19.704(a)(1)-(11)." Can anyone provide advice on where I might find a template or is the format up to the individual offeror? Thank-you
  4. Mandatory Flowdowns

    Perhaps a starting point would be to check the prescribing clause referenced for each of the mandatory clauses.
  5. I am just reading this topic now as a situation recently came up simliar to this. I understand a contract can have CLINs with different periods of performance and we currently have two contracts with 11 and 20 CLIN's respectively with different periods of performance. The complication arose because the end date of the latest CLIN was getting out of sync with the Section F Clause Period of Performance. What the Contracting Offcer did was set up a table summarizing the period fo performance for each CLIN in Section F. We have a third contract now with a different agency and the contracting officer is issuing a mod to exercise an optional CLIN but the performance period of this CLIN through December 2015 will take it beyond the February 2015 period of performance in the Section F clause. When we try to explain this to him, he keeps saying this mod is only for the CLIN being exercised and does not seem to understand the Section F Period of Perfornance information will be out of sync with this CLIN. In our last communication to him we laid out a table, simliar to what the other contracting officer did in an attempt to make this clear. We are still waiting a reply Are we being unreasonable in expressing our concern about the period of performance information in Section F being kept up to date?
  6. Can money from one CLIN be transferred to another CLIN on the same contract? Our first CO was doing it, but the new one on the same contract is not.
  7. Consultant Fees

    Is there a FAR that defines the maximum amount payable to consultants?
  8. Consultant Fees

    Some more background info. The total potential value of the support that might be provided by several consultants working for the large company we are attempting to contract with in support of our US gov't contract is ~$385K. The CO is challenging the hourly rate of one individual who, if we used him to the maximum hours projected for his support, would total ~$70K of that amount. The CO wants a reduction on his rate that would reduce the overall total by $3,500. It's not a significant amount and we will resolve the issue, but it just seems strange.
  9. Consultant Fees

    Just received a message from the CO on our contract referring to The Office of Federal Procurement Policy (OFPP) publishing a notice in the Federal Register announcing it has raised the cap for government reimbursement of certain contractor executive and employee compensation and the hourly rate which our consultant has proposed is too high. I found a document on the internet dated Dec. 4, 2013 which seems to be what the CO is referring to, "Determination of Benchmark Compensation Amount for Certain Executives and Employees", but am unable to attach it or include a link to it for this post. Any further comments on this are appreciated.
  10. Consultant Fees

    Thanks to everyone. I had looked at FAR 31.205-33 prior to my original post and was just checking to make sure I had not missed anything. This is a great forum by the way.
  11. Consultant Fees

    Looking for advice on whether there is any FAR that defines maximum hourly rates to pay consultants. As a prime contractor, we proposed to use consultants in support of work being done on a CPFF line item and were told the FAR's do not allow the hourly rates which the consultant quoted.
  12. I have not found any discussion on the new System for Award Management, or is this not the forum to discuss it? I have encountered all sorts of errors in the information that was migrated from CCR and ORCA and questions to the Federal Service Desk have gone unanswered for close to a week.
  13. Is anyone familiar with IDIQ contracts where under the Indefinite Quantity Clause, orders will be issued to all contractors awarded a contract under this solicitation and all awardees will be given an opportunity to compete for task orders in excess of $3,000? Each Task/Delivery Order Request issued will include a SOW, Evaluation Factors for Award of the Task/Delivery Order, Reporting Requirements and Deliverables, required components of the offer to be submitted, format for submission, and any other issues pertinent to the Task/Delivery Order, including information on whether it is anticipated that the Task/Delivery Order will be awarded with or without discussions. My previous experience with IDIQ contracts was the contractor would receive a Task/Delivery Order if the government had requirements, not have to compete again.
  14. IDIQ and Task Orders

    Thank-you. My previous experience had been as a sole source supplier, whereas the situation I am currenly inolved in has a number of potential suppliers.
  15. The Project Officer on our contract has a tendency to make unannounced visits to one of our major subcontractors. We feel we should be given adequate notice to have someone accompany the project office on the visit. I have not been able to find any FAR's which allow or disallow this. Has anyone had any experience with this?
  16. I have reviewed the FAR's referenced in previous comments(copied below) and cannot find anything that specificially states a government representative can visit the prime contractor's subcontractor without first notifying the prime contractor. Or conversely, I can find nothing that states the government representative does not have to notify the prime contractor prior to visiting the subcontractor. It seems to be an area that is not properly defined. It would just seem to be a matter of professional courtesy to inform the prime contractor. * * * FAR 53.245-1 (g)(4): 4) The Contractor shall ensure Government access to subcontractor premises, and all Government property located at subcontractor premises, for the purposes of reviewing, inspecting and evaluating the subcontractor?s property management plan, systems, procedures, records, and supporting documentation that pertains to Government property. 45.501 Prime contractor alternate locations. The property administrator assigned to the prime contract may request support property administration from another contract administration office, for purposes of evaluating prime contractor management of property located at subcontractors and alternate locations. 45.502 Subcontractor locations. (a) For property located at a subcontractor, FAR 52.245-1(g) requires that the prime contractor allow support property administration. Should the prime contractor fail to comply with FAR 52.245-1(g), the property administrator assigned to the prime contractor shall immediately refer the matter to the contracting officer. ( The prime property administrator shall accept the findings of the delegated support property administrator and advise the prime contractor of any deficiencies within the subcontractor?s property management system.
  17. Furrther "fuel for the fire". The Project Officer seems to have something against this particular supplier, one of two used by us on the Contract, both provide the same raw material to us. We want to have one of our reps accompany the PO to the supplier, but event the Contracting Officer is suggesting they can do this. I have been unable to find any FAR covering this.
  18. Some further information on "Project Officer" in the context of our contract. "Performance of the work hereunder shall be subject to the technical directions of the designated Project Officer for this contract....., technical directions are directions to the Contractor, which fill in details, suggests possible lines of inquiry, or otherwise completes the general scope of work set forth herein. These technical directions must be within the general scope of work, and may not alter the scope of work or cause changes of such a nature as to justify an adjustment in the stated contract pricelcost..........The Government Project Officer is not authorized to change any of the terms and conditions of this contract. Changes shall be made only by the Contracting Officer by properly written modification(s) to the contract....."
  19. Thanks for all the input. I thought I could add some further clarification. The work being done by the subcontractor is in support of a firm fixed price line item in our contract with the government. We use the product we get from the supplier in production of the end product which the government buys from us. FAR 52.246-2 Inspection of Supplies - Fixed Price is in our contract with the government. The complicating factor is US government property is used by the supplier in the production of the product, so the government project officer goes to the subcontractor to check on the status of the property.
  20. We awarded a contract to a small business. It sold the facilities required to perform the work to a large business, and subcontracted the work we needed the small business to do for us to that large business. Can the work we subcontracted to the small business still be included in our small business reporting, even though it is not doing the work?