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About Freyr

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  1. This is one of the things that's been confusing me. Looking at the CPRG it states that T&M/L-H/FP-LOE contracts are "are considered cost plus-fixed-fee contracts for the purpose of assigning profit/fee values." Why is that? It seems that T&M could be anywhere in a risk continuum between CR and FFP depending on the mix of labor vs materials but most the guidance I've read treats T&M as very risky to the Government but not as risky as cost reimbursable work. In our situation the large portion of the costs would be labor costs.
  2. That's exactly how I'm trying to look at it since it's a sole source as well, we're playing a game with the contractor by saying 10% is too high for us to justify try to come down a little. That said, if they come down on profit and up on direct labor rate that could, and probably will, increase the loaded labor rates. Some folks here have mentioned that 10% seems reasonable, my question to that is why? We're supposed to use a structure approach to negotiating profit, so for a T&M requirement what would drive up our objective on profit?
  3. The format we've got in our analysis document is a breakdown of each of the individual elements and an overall analysis of the fully burdened rates, so we're absolutely not ignoring the full rate.
  4. A. YES (we are requiring certified cost/pricing data) and A. FAR 52.232-7 and 52.216-7. That was my initial thought too (just negotiate the fully burdened hourly rates and they'll adjust profit accordingly right?) but my CO said she wanted a breakdown of each of the individual elements of their price (I pointed her to FAR 15.405(a) but she held her ground).
  5. Hi all, I'm being asked to determine whether or not a proposed profit of 10% is fair and reasonable on a sole source T&M contract we're planning on awarding. We haven't done this type of work before and I don't really have anything to base our decision off. I've read through FAR 15.404-4, The Time-and-Materials Contract: The Time Has Come for A Long, Hard Look, the DoD's weighted guidelines, and GSA's structured profit/fee approach and it doesn't seem like 10% is even close to something that should be fair and reasonable considering the contract type and risk involved, though I understand there's other factors to consider. GSA's GSAM says that only fixed price contract should be towards the high end of the profit range which they max out at 7%. I was also looking at the link below (table starting on page 18) where it appears to recommend a profit of 0% to 1% for a T&M contract. https://www.acq.osd.mil/dpap/cpf/docs/contract_pricing_finance_guide/vol3_ch11.pdf Am I off base in my thinking that 10% doesn't appear to be fair and reasonable at first glance for this type of contract? I was thinking, considering the factors in the GSAM, that a high profit objective for us should be closer to 3% which is leagues away from their proposed 10%. Appreciate any insight anyone can provide, thanks!
  6. I've got my FAC-C Level III already and I'm DAWIA Level 2 certified.
  7. Hi all, I'm at a bit of a crossroads right now where I need to relocate and the options for me are either to take a lateral PM position (I'd manage an acquisition program) or stick with contracting but take a grade lower (with pay matching, so step 7). I was hoping I could get your opinions on the two career fields, pros/cons, career and promotion potentials, etc. Anyone have experience in both fields or going back and forth between them that can share? What do you all think about folks who go from 1102 to PM the potential to go back to 1102, would that PM experience be seen as valuable? Thanks!
  8. It was they way we did it when I started at this office and no one's thought to question it, I try to question whatever doesn't make sense to me but this one flew right over my head. My assumption, or what I figure people would say in hindsight to make sense of it, is that it's to get all the information up front so you don't need to ask for it later (like Joel mentioned, streamline the evaluation timeline). Looking at it now, it doesn't seem to streamline much and could potentially cause other issues and make things take even long (or even still have to ask for updated information regardless).
  9. Those are the only responsibility type criteria we typically include in our full and open competitions along with whatever other technical and price evaluation criteria are necessary (we normally do not use LPTA and most requirements are above the SAT/non-commercial). So we're not actually using any of those three to discriminate between proposals.
  10. I feel like I ask the most basic questions on these forums but this is another one I haven't really seen any information on. I know FAR 19.301-1(f) states, "The contracting officer shall accept an offeror’s representation in a specific bid or proposal that it is a small business unless (1) another offeror or interested party challenges the concern’s small business representation or (2) the contracting officer has a reason to question the representation. Challenges of and questions concerning a specific representation shall be referred to the SBA in accordance with 19.302." My question is: What sorts of things would make a CO question the representation? I've recently seen a firm who's SAM report states they're small and shows them as 1 employees with less than $100,000 in receipts but it's also said that for the last 5 years, exact same numbers (if you look back on SAM 7 they have a different name with around $30M in receipts). We've requested financial statements that don't seem to add up to what they claim their size either. Is there anything else we should be looking for or any other standard procedures to assist in verifying size status claims? Thank you!
  11. Definitely understanding not to paint ourselves into a corner! For those proposal submission items I identified, our office's RFPs typically include them as requirements for their initial proposal submission (I'm assuming so we don't need to ask for them after a technical evaluation? Not sure.). For clarification, I have been referring to SB subcontracting plans, I apologize for not making that more clear.
  12. A colleague of mine actually saw this situation where a lot of vendors failed their compliance checks, protested, and the PEs suggested just giving awards to everyone. I think ultimately they ended up in discussions. I definitely agree that some MA-IDIQs are getting too big, needlessly so, but it seems like this might come up more since it's administratively probably easier to just give everyone an award rather than seek revised proposals or go into discussions (looking at those huge IDIQs like Seaport-e and OASIS (adding like 1000 new vendors?!)). Not to take things too off track, but I'm betting getting the PEs and highest levels of legal counsel involved will do more than just advise those inexperienced COs but would end up driving the bus for them.
  13. It's all a hypothetical still but does the reason matter? Is there a difference between an offeror who thought they uploaded it vs one who glazed over the requirement and didn't think they needed to? I'm taking from a lot of the responses here that the Government can tend to be a little too strict in their solicitation requirements, leaving little room for Contracting Officers to make judgement calls and use their discretion without appearing to bend the rules too far and appear to favor one vendor over others. Thankfully these forums exist to help educate those like me who are still learning the ins and outs of Federal Acquisition.
  14. Do you think that this might lead some agencies to strategically make decisions that would lead to lower risks of protests rather than to follow those basic procedures or do what's in the Government's best interest? For example, in an environment where multiple awards are anticipated but there's various compliance issues and a CO has removed so many offerors that they wouldn't meet their anticipated awards. The lawyers / Procurement Exec might say " just give them all awards, no one could protest that!" For the sake of the example above: MA-IDIQ with 20 awards anticipated, 30 proposals received, only 10 pass a compliance review.
  15. Thanks for the article, super helpful! It states in there "If it is a responsibility criterion, the exchange will still be considered a “clarification” even if the offeror submits a revised subcontracting plan." Do you feel there's a difference between allowing a revised plan and allowing a plan to be submitted in general? You also brought up a word our lawyers seem to hate, "waiveable." What conditions do you see need to be met in order to waive something? Outside of FAR 52.215-1(f)(3) that is, unless you consider it to be that minor in the context of the solicitation.
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