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  1. FPDS reporting of actions above SAP but under FAR 13.5 commercial procedures - how are these reported in FPDS? I'm sure the answer is buried somewhere either in FAR or FPDS material, but throwing it out as time is of the essence.... gotta love the SCI reporting time of year!
  2. Seriously considering proposing a modification to the expired contract - considering that the invoices could be considered a claim (FAR 33.2 - unless I’m missing something in FAR or law) the Contracting Officer has broad discretion in making the determination. Taking this approach, we would need to support an implied contract (FAR 33.203 Applicability) and I believe we could do this. Thoughts??? While I agree that some contractors may take advantage of the government by continuing work, I also feel that utilizing program, legal and contractor personnel to fight with the contractor i
  3. Folks - thanks for all the input on this.... I'm new to using this board and will certainly do so in the future. Additional details: 1. The contract (for cell phone services) expired December 31st and the contract was explicit in this (ie, no options, nothing that would appear as express or implied authority). 2. The contractor did not stop services and the personnel with the phones continued using the cell phone services; as the customer, they were unaware of the contract expiration. 3. Government personnel realized mid-Feb that the contract had expired and immediately
  4. In situations where the contractor continues to provide services (ie, cell phone services) after the purchase order has expired and submits an invoice, would the contractor need to submit a claim in accordance with FAR 33.206 in order to be paid? FAR 1.602-3 Ratification of unauthorized commitments would not apply (I don't think) because a government representative did not authorize (verbally or in writing) the continuation of services.
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