Nicole1986

Thanks, this was helpful!

Thanks, that is helpful!

Thanks, I am going to check these links out!

Thanks, everyone. May I ask what I should clarify? I was using allocated to refer to the payment amounts for each CLIN in the Consideration and Payment Section (maybe obligated is the right word?). To elaborate though, we have a contract that states: Estimated Cost: $XXX,XXX Fixed Fee: $XX,XXX Estimated Cost Pus Fixed Fee: $XXX,XXX And then (I could not get a good screen grab, sorry): CLIN 6 - Optional Services Component 6 (12 Months) (Severable) Estimated Cost: $XXX,XXX Fixed Fee: $XX,XXX Estimated Cost Pus Fixed Fee: $XXX,XXX I hope this helps clarify!

I am struggling to understand the difference from a funding perspective between severable and nonseverable CLINs. I always thought if funding was allocated by CLIN in the agreement expenditures must remain within the funding amount allocated for each CLIN and expended within the period defined for that CLIN, but I learned from my latest read of an agreement I might be wrong about that! If there are multiple, separately priced nonseverable CLINs under a CPFF contract, can the funds allocated for one CLIN be used for activities/tasks under other CLINs? And would the funds also rollover to other CLINs if the CLIN has ended and there are unexpended funds? Any thoughts or resources I can reference to learn more would be appreciated. I do not find the FAR definition to be entirely clear. Thanks!

Thanks again for the help!

My apologies, yes this is a T&M schedule contract. Hmmm, I have never seen a schedule that specifies dollar amounts for ODCs. Thank you so much, I will review that FAR clause.

Hoping for some insight from others! Recently asked for clarification from the government on the following question - can the contractor and subcontractors take their federally approved indirect cost rate on other direct costs? To which the government replied - GSA rates only; must be as identified in the GSA contract. Does this mean that the schedule must specify that indirects can be applied to ODCs?

Thanks so much, I will do what you have both suggested. I mentioned to my leadership that even if it is uncomfortable to the program teams, until we have a better understanding of how the government would classify these type of agreements, we will need to confer with the CO(s). I appreciate everyone that responded!

Thanks to you both ji20874 and Retreadfed. The only rationale the legal department provided to me that "these arrangements seem different than subcontracts." If they had something a little more defendable then I might feel more at ease. I have flagged these as a risk to those above me, because the org has not been consistently following consent or procurement procedures for "site agreements." I was thinking they could be grants or CAs, but I do not know where to start looking in the FAR to determine what we would need to do in such cases. I do not have experience with that. My organization never really addresses this with the agencies we work with (primarily DOL and HHS). And from what I have seen in past correspondence shared with me, the COs have referred to some of the "sites" as subcontractors.

Hello to you both - Sorry for the delayed response, I did not know there were responses! To answer the follow up questions: (1) Is your organization the prime contractor? Yes (2) Is the prime contract a FAR-based contract? [not a grant, not a cooperative agreement, not a contract under an authority other than the FAR] - Yes (3)(a) Is any site agreement solely between the prime contractor and the lower-tier provider? Yes (3)(b) The Government is not a party to those agreements? No (4)(a) Are the site agreements entered into because of and to accomplish the purpose of the prime contract? Yes, but this is where our organization is confused. Often the projects under which we will issue "site agreements" are either evaluation or program design work whereby we will design a program and work with the sites to implement it in their community. Or we will be evaluating a program and need these "sites" to participate in the evaluation. Or we will provide funds to a site to run a program we have designed. It seems so much more like grant work, but it is acquisition (FAR based). (4)(b) Or, do the site agreements exist without regard to the prime contract? No, they do not. To answer Retreadfed's question - the sites will sometimes be small non profits or state/local government health departments. The work would be as I described under 4a. It seems pretty clear to me they would still be subcontractors, but I could be missing something.

Hello all - I am new to an organization that does social policy research (mostly with HHS and Dept. of Ed). They issue lower-tier agreements under federal contracts which they refer to as "site agreements." The organization's Legal department believes that these "sites" would not be considered subcontractors, and therefore the procurement and other regulations related to subcontractors would not apply. Is there another type of classification for partners under the FAR? I have tried to do research on my own, but have not found anything and would not even know where to start. Thanks in advance for any insight.

It is for advisory/research services. There were no ISR/SSR reporting requirements at the Task Order level. What I wound up doing was submitting a final report, and stated in the notes section that our organization has interpreted that the reporting requirements are over, given the IDIQ has ended. I also pointed out that there was one open task order, but I have intepreted it to be a logical follow on and not subject to reporting under the IDIQ. The government accepted my report.

It is for advisory/research services. There were no ISR/SSR reporting requirements at the Task Order level. What I wound up doing was submitting a final report, and stated in the notes section that our organization has interpreted that the reporting requirements are over, given the IDIQ has ended. I also pointed out that there was one open task order, but I have intepreted it to be a logical follow on and not subject to reporting under the IDIQ. The government accepted my report. Sorry for the double post, tried to delete but not sure how.

I have determined the IDIQ end date because there was a 5 year period listed in the schedule. I am not sure why the federal agency issued a task order under this IDIQ after it expired (this was before my time at the org), but the Task Order references the IDIQ in the "Contract No." field of the schedule. And to answer your question abotu how I would report, yes, I would add the subcontracting costs from the Task Order to the cumulative numbers reported in the past for the IDIQ. I have seen this on multiple occasions with our org's IDIQs and other Indefinite Delivery Vehicle (IDV) schedules - there are task orders that extend beyond the IDV end date.

Hello all- Is Individual Subcontracting and Summary Subcontract Reporting (ISR & SSR) required for open Task Orders under Indefinite Delivery/Indefinite Quantity (IDIQ) contracts that have expired? I have an active task order under an IDIQ that expired years ago, and there are still subcontracting costs. Do I still need to report these or can I submit my final ISR/SSR reports and treat the subcontract reporting requirements as over since the IDIQ is technically over? Thanks!