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Neil Roberts

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About Neil Roberts

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  1. For DoD, see PGI 251.102 authorization "letter."
  2. Is FAR Part 51 of help to you?
  3. Subcontracting plans are not required from small businesses. Even if you were required to submit a subcontracting plan, since you apparently do not subcontract, it would be easy for you to fill one out with all zeros. Also, an argument can be made that a subcontracting plan is not required when there are no subcontract possibilities.
  4. Having contract battles in Government contracting is normal. If a contract is offered to you in writing, you can try take exception in writing to the clauses you think are inappropriate, indicating that you accept the contract without the objectionable clauses. In doing so, there is always a risk that your customer would just walk away from you and find someone else who will accept the clauses. I don't think anyone here can help your customer change its mind about whether you are a subcontractor that must be flowed certain clauses. Don't know what your goals are and what you think the solution is. Obviously, you can just walk away from the deal if you haven't signed the contract.
  5. Standard practice is to compete all subcontract work. In doing so, the proposed subcontractor responds to the RFP/ITQ with its rates. Supplier Management (Procurement) is generally the function that performs this work.
  6. What does you contract with the prime say with regard to your questions?
  7. You could file a complaint with the SBA and/or get in touch with your Congressional Representative as to fairness. However, you apparently agreed to the rate as your proposed rate, so what is your complaint??? Also, you have not indicated what the dollar difference per hour is between your fully burdened rate and the NTE rate. Anyone you discuss this with would want to know. Not sure either of these supports actually winding up being a subcontractor in a timely manner.
  8. As indicated in earlier posts, more restrictive advanced notice and prior consent requirements and withholding of payments are consequences. It is "tribal knowledge" in industry that an approved purchasing system is "required" to qualify for responding to large Government contract solicitations. Example: GAO Accountability Office protest case Symvionics B-408505 http://www.gao.gov/assets/660/658010.pdf . I am not aware that this is based on any regulatory/contract consequence of a failed system. Regardless, it is a competitive disadvantage not to have an approved system and this is often seen as even greater concern and risk than contract consequences such as consent or payment withholds.
  9. Per FAR 52.244-2 (i), the Contractor agrees that the Government may perform a CPSR.
  10. If the deliverable items are critical and not easily re-obtained in the event of non-performance, I suggest you request a written plan from the company with milestones dates for the correction, re-review and re-assessment of system approval. You should monitor this and meet with them regularly about progress. You may also want to consider requesting a performance bond from the company.
  11. A May 2017 version of the DCMA CPSR Guidebook has been located at http://www.dcma.mil/Portals/31/Documents/CPSR/CPSR_Guidebook_050917.pdf
  12. I always questioned the adequacy of the source justification when seeing distributor involvement in a proposed procurement, before looking at the adequacy of competition. For example, if it was requested that a Ford automobile is required to be ordered, was there adequate justification for that vs. issuing an RFP to many brand car dealers for automobiles that carry x passengers, get x miles per gallon or more, are licensed to drive on highways and streets, etc. I believe it would be a stronger file if the manufacturing source justification was adequate to support a determination of competitive pricing among distributors of that product. You may get better or more views if you could fill in the details of your scenario, Phil as to source justification and market research. But, it would be awfully nice if we could get a view from CPSR teams or those that deal with them daily e.g., see CPSRHelpandHints on Facebook
  13. Commercial SB Plans

    A commercial plan is preferred per 52.219-9 (g). I assume this clause is to be included your contract? If your are a subcontractor, you might look at paragraph (j) to determine whether your are exempt from such a plan.
  14. Hi Vern: Happy to see you are still involved day to day with this forum. The contract obligation I am talking about is the obligation to flow the -7007 clause. Z-Mil's initial posting asked for thoughts about a contractor buying electronic parts from an OEM even though the OEM would not agree to accept -7007. My thoughts were that action would be required to report the OEM parts as potentially counterfeit and quarantine the parts until this was resolved. I don't know why any contractor or subcontractor would want to shoot themselves in the foot by entering into such a contract with an OEM that will not accept -7007.
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