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FrankJon

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  1. Don - I apologize if I haven't been descriptive enough, but the contrast is significant. I'll try to be more specific in this post. (1) As we know, DFARS 215.470 requires a CDRL when the Government requests data. "Data" is not defined in the DFARS as far as I'm aware. (2) DoD 5010.12-M purports to provide comprehensive instructions for the acquisition and management of data, including the preparation of CDRLs. It defines "data" expansively (see above), to include technical data and data incidental to the contract, like financial and management data. Likewise, it defines "technical da
  2. As the word is used in DFARS 215.470. Most sources I have seen indicate this is a reference to technical data as described at the DAU link (see also the Government Contracts Reference Guidebook definitions of CDRL and technical data). On the other hand, DoD 5010.12-M states: And: So there seems to be a clear conflict between how the DoDM defines "data" and how other, more modern, sources define it.
  3. And thank you for the reminder about the applicability of FAR subpart 27.4 in DoD. I should have reviewed the DFARS on this prior to posting. Despite this, there are various sources (none primary that I recall) that describe the CDRLs meaning of data as it is defined at FAR subpart 27.4 or similarly.
  4. Hi Don, I'm not questioning whether it's active. I'm questioning whether it's necessary and reasonable to treat it as mandatory policy without an underlying DoDD or DoDI at its foundation. DAU also appears to reject the expansive DoD 5010.12-M definition of data. See: https://www.dau.edu/tools/Lists/DAUTools/Attachments/654/High-Level CDRL Plannng_26 June 2020.pdf pgs. 19-20.
  5. Carl...respectfully....you're killing me. That doesn't get me any closer to an authoritative definition of "data" as it pertains to CDRLs.
  6. At issue within my office are the conflicting definitions of "data" found at DoD 5010.12-M and FAR 27.401 as they pertain to the CDRLS requirement. If DoD 5010.12-M is not authoritative, then we would look to other sources, such as FAR 27.401, for the definition. A DoD Manual "implements policy established in a DoDD or DoDI." (DoDI 5025.01, pg. 17.) DoD 5010.12-M was "issued under the authority of DoD Instruction 5000.2, 'Defense Acquisition Management Policies and Procedures.'" The referenced DoDI 5000.2 no longer exists. The modern DoDI 5000.02T "Operation of the Defense Acqu
  7. Thanks for the enlightening discussion, all. I’ve yet to check all the references but it seems like I now have a few workable options to put forth.
  8. Formerfed: Apology accepted, but I would respectfully disagree with your characterization of how I consider the information shared on here. For instance the idea of a pre-competed BPA raised by Don and Carl is new and very interesting to me. I don’t merely disagree to be contrarian; rather I try to provide reasonable interpretations of often ambiguously-written text (in this case, 13.305(b)). If that shows inexperience then I have a hard time imagining what experience in this business looks like. If that annoys you then perhaps another hobby is in order. All due respect to ji, but s/he takes a
  9. Wow formerfed! That came out of left field! My interpretation of FAR 13.305(b) is apparently different than yours. It’s a shame you’re so irked by that. I started this topic in a much different place and thought it was over more than once until other approaches were brought up. I enjoyed the open flow of alternate ideas but I didn’t come here asking for them. And I remain optimistic about the possibility of employing the multiple award requirements approach, which I learned a lot about. This is an utterly absurd statement by the way. I wonder how much thought you gave it before ty
  10. I think I’d be limited to the SAT unfortunately. I have no supplementary regulation beyond the DFARS. That doesn’t offer a higher threshold in this case.
  11. Formerfed is pursuing a different line than you.
  12. I assume you're talking about establishing a BPA, although it wasn't stated. I don't see how the following could work: Since orders are over the SAT I'll need to comply with the competitive procedures at 8.405(c)(2)(iii). Otherwise, yes, there appears to be some potential.
  13. I didn't "start out" my research by posting to Wifcon. An IDIQ was of course one of the first approaches I looked at. I went down the requirements path because the customer seeks multiple awards and providing fair opportunity every day may not be feasible. The factors would probably not be difficult. Past performance and price. But the contract would require a dedicated KO to compete and cut orders (literally) every day, and often more than once per day. My office may not be able to support that. (Now, if we could accumulate orders as with a BPA and cut one order per month to pay for t
  14. That's interesting, Don. Do you have a reference for that text? I'll certainly add this to my list of approaches to research. But initially I'm not seeing the advantage of this over the "multiple/split award" requirements approach in terms of application.
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