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Virgil Sollozzo

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About Virgil Sollozzo

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  1. I'm curious how this is effected. Isn't the contractor obligated to devote the specified level of effort for the stated time period per FAR 16.306(d)(2)? It sounds like, somehow, the contract is already operating like an IDIQ.
  2. I think this is the answer. Does Limitation of Funds create a contingency (like Availability of Funds might in other circumstances) that limits the Government's liability to the amount of incremental funds placed on the contract?
  3. I read the GAO Redbook. Te salut, Don. It clears up my understanding of an obligation, but it doesn't answer the questions. That's for a different thread.
  4. I've spent much time trying to unwind the use of the term "obligate" in the FMR. I suppose KO's don't "obligate" funding, but incur the obligation. At any rate, perhaps for this discussion it's easier to call the KO's action "putting the funds on contract." Yes, the plan is to do incremental funding. I, too, believe that there is no regulatory minimum, though I'm having trouble supporting my position. I have been advised that the funding obligation requirements in the FMR, which policyguy first cited above, are also the KO's requirements for the amount of funds to "put on the contract" at contract award. The Limitation of Funds clause permits incremental funding, however, and there's no regulatory minimum in sight. So the KO is ready to make this award, months in advance of the performance start date. I know he can put on contract the entire estimated cost. Can he put on half of the estimated cost? Can he put on $100? Can he put on $0?
  5. Great replies, thank you. The contract will not be funded entirely with current fiscal year appropriations. I'm comfortable with that concept, though I'm not convinced that it's the only option here. The DoD FMR appears to me to offer requirements for the "recording" of obligations, which is different from the act of incurring an obligation (incurring a liability). For example, FMR Vol. 3, Ch. 8, paragraph 080304 states, "The office that generates an obligating document, in the form of a contract, order, or modification, must provide official evidence of the obligating documents...to the office responsible for recording the obligation." DoD components must also record obligations in situations that don't involve contract actions, such as described in paragraph 081305: "As a general rule, the amount of the liability expected to result from pending litigation must be recorded as an obligation in cases where the government definitely is liable for the payment of the money from available appropriations...". In short, I'm not sure the FMR answers the question.
  6. Long time lurker, first time poster. Scenario: Your Navy contract shop is going to award a cost-plus-fixed-fee contract for severable services on February 1, 2019. The period of performance will be April 1, 2019 through March 31, 2019. The contract will contain the clause at FAR 52.232-22, Limitation of Funds and be funded with O&M,N appropriations. How much money must the KO obligate at contract award on February 1st?
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