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About ICE-CO

  • Birthday April 18

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  1. Oh wow... I guess this thread could probably be deleted now... Was trying to get an idea of what other people did.
  2. Yes! I get the FAR reference which really is what has initiated most of this process. The FAR allows for you to NOT have to check at every contract action (depending on the action). I was more asking if there were any local policies that required us to check for exclusion. There seems to be an idea (which has caught on) at DHS, that you have to check for EVERY contract action. I'm trying to see if that is something people at other agencies do or where that came from. Thanks!
  3. Thanks for the feedback! I just mean, by "held accountable", is it something that would be universally seen as poor practice in an audit or is it considered as general organizational best practice; but also, how would management view this issue if it came up? Definitely not a paralyzing issue; just trying to get a feel for what may be "normal" procedure outside of DHS. Thanks!
  4. Thank you both! I think I just realized that it isn't a requirement for every action. That must have been a habit our office wanted us to get used to. However, I cannot find any local policy requiring that check. But there is a part of me that is concerned about that rare circumstance where a CO might award an administrative modification, not check SAM, and find out they are on the excluded parties list. Is that something they would be held accountable for?
  5. Hello! I thought this would be a good question for this forum to get a good idea on how things are done in other agencies. How often do you check the System for Award Management (SAM) for active exclusions? Do you check it for every contract action? That is how I was trained but someone brought up today that this may not be necessary. The FAR prohibits soliciting, or awarding to vendors that are on the excluded parties list but does not specifically require the Contracting Officer to check for every modification (e.g. admin changes). I found two applicable references which are verbose but nothing specific to requiring the check for every contract action - FAR 4.11 and 9.404-9.405: FAR 4.1103(a)(1) says that the Contracting Officer "(1) Shall verify that the prospective contractor is registered in the SAM database before awarding a contract or agreement. Contracting officers are encouraged to check the SAM early in the acquisition process, after the competitive range has been established, and then communicate to the unregistered offerors that they shall register;" FAR 9.404(c)(7) says that each agency must "(7) Establish procedures to ensure that the agency does not solicit offers from, award contracts to, or consent to subcontracts with contractors whose names are in the SAM Exclusions, except as otherwise provided in this subpart;" I'm at the Dept of Homeland Security. I can't find any agency specific information to requiring a check for every contract action either. Do you think this is something that was passed down as a best practice but not a requirement? This could also adversely affect a CO if they award a modification and find out that a vendor has been suspended so it could result in more dire consequences. I would love to know what you think!
  6. Hello all, I would like to request feedback regarding when to use the term "RFQ" vs "RFP." Based on my research, an RFQ is always used under the SAT (FAR 13) and an RFP is used above SAT. However, there have been instances with commercial (FAR 12) buys under FAR 15 or 13 where RFQ was used. This may be wrong. I've been under different offices and different COs. So I am seeking clarification to see if there is a hard/fast rule or can it come down to CO preference or particular situations. Thank you.
  7. Thank you for your response! I understand those requirements under 52.216-18(a) and FAR 52.216-21(f). Per this specific supply, a reasonable estimate of requirements is possible. And it is highly likely, if there are options, that they will just be exercised anyway. But that is a good thing to consider if we want to be held to that single vendor or not. (worth re-hashing with the program) Thank you again!
  8. Thanks. Right now, it's looking like it will be #3, Requirements. Would that have an effect on the POP limitations?
  9. Hello all, I am looking to re-compete a FAR 16 IDIQ, most likely a "requirements contract." It is for supplies, Firm-Fixed Price, and after competing, will be a single-award IDIQ. I have a question for input regarding the Period of Performance (POP) limitations. Is there any reason why the IDIQ cannot have a five-year straight period of performance with an overall ceiling? The FAR references that task/delivery orders are generally five-years with options but I found no reference regarding direction when setting up the POP for the over-arching IDIQ. Has anyone had experience with these? I'd prefer a straight POP avoiding the need to exercise options when we know we will be using this particular supply.
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