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lotus

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About lotus

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  1. Why is the Govt so cliquish?

    Thanks. I just read the first case summary. I find the the administrative judge's decision to be irrational. What difference would it make if the PM got his knowledge, skills, and abilities in 5 years instead of ten, or gained in critical thinking skills via a path which included a degree or via another path? And, although the judge didn't spell out in his opinion exactly what the end product was to be (something to do with clean water or systems for making water clean), does it really matter if the PM has any qualifications, so long as the end product meets the Govt's needs (or is as specified in case the specifications don't align with needs).
  2. Why is the Govt so cliquish?

    I choose a supplier service provider based on two criteria. Can they (i.e. the company) do the work and price. For example, when I did a bathrooms remodel I visited area showrooms and offices to see what they offered. Ability to perform was not so much an issue as understood. All were established in the local market. Ultimately I picked the major items and negotiated a price and timeline. I was indifferent as to whether their employees were felons, or Martians, or whatever, or how many or how few of them there were. Unlike an RFP on my plate now. The Govt said they were looking for at least 29 FTE's. Guess how many people (FTE's) are on the incumbent staff.
  3. I've often wondered why the Govt is so cliquish when it procures services. It's requirements are of the nature of who you are rather than what you do. To stretch the point, does it matter if your service provider is Joe Felon, with lengthy list of felonies, or Joe Upstanding Citizen, who has no such record? If Joe Felon is better at what is to be done, then he should be chosen. The Govt buyers use security clearances, and past performance within the agency and within the Government, as screening criteria to choose the persons they want to buy from. I once sat through a debriefing from the FBI and it was clear that they wanted someone who already worked at the FBI. If they had quotes from the incumbent janitorial firm to do plumbing, and competing quotes from master plumbers without FBI connections, they'd have gone with the janitorial firm. A BD rep reporting on his meeting with State Dept people ahead of the release of a big services RFP reported that the highest ranking State Dept person said, "We want us." Clearly he was judging based on retaining the incumbent staff more than whether or not the work would get done or a better solution proposed. Since I don't buy based on these kinds of criteria, it strikes me a bad thing that the Govt does. Why does the Govt act in this manner?
  4. Invoicing for unworked hours under a FFP TO

    It seems that this turns on the question, did you (the Government) receive what you contracted for? From what I can see in your write-up, the answer is yes.
  5. Thanks, Retreadfed. (Who would have thought there would even be such a regulation?)
  6. Perhaps there should be a default acceptance time. If the audit is not completed by X days after submission, the ICS is deemed accepted as submitted.
  7. I'm looking at a RFP. The Gov't wants to buy labor on an IDIQ basis anywhere in the US. One CLIN equals one labor category. The Gov't is seeking a single hourly rate per CLIN. A few wage determinations have been included in the RFP, but nowhere near all of them for the entire country. To help focus, let's say Manhattan is not covered by any of the wage determinations in the RFP. After award of the IDIQ, how would the SCA rules apply if the Gov't wants to buy labor in Manhattan?
  8. To answer questions: It is a small company without a CAS disclosure statement. (Although the owner dreams of becoming a big company. Other than travel and ODCs on predominately FFP contracts and minimal Materials on T&M contracts there is no cost type work. Whether the commission costs would be proposed as direct costs or included as direct costs in a cost estimation used to help determine a FFP price or T&M labor rates, I can only presume yes. The benefits are 1. The G&A rate is reduced. (The BD people & owner are saying the G&A rate is too high.) 2. Costs would be better matched to the causal relationship. Ditto for profits. (There are some legacy contracts that are not part of any sales reps book of contracts so no commission is paid when those receive additional bookings, but G&A including commissions, is allocated to them.
  9. The sales people (business development representatives) have compensation plans that include commissions as a percentage of bookings. I believe those are properly accounted for as direct costs, easily passing the "but for" test. They are currently part of G&A, and my attempts at telling the owner and the BD people that the costs should be accounted for as direct costs are met with a chorus of objections from the BD people. The owner typically gives them what they want, and their several voices outshout me. A. Is my interpretation correct, these should be accounted for a direct costs? B. Assuming yes to A., what arguments are likely to persuade the owner? C.(1) I was once advised to be more aggressive in pursuing my ideas. I am considering more aggressive options and following that advice. C.(2) Salespeople tell me that a customer won't buy unless he feels pain. In this case, effectively the owner is they customer, and he won't change unless he feels pain. C.(3) Assuming my interpretation is correct, what is the best way to make him feel enough pain to change?
  10. Are the rules for solicitation questions and answers spelled out anywhere in the FAR or elsewhere? My search did not find them. I'm thinking of situations where the solicitation has a date to submit questions by, but that date is now in the past, and (a) I have a new question, or (b) the Q&A are published and the answers open more questions, or (c) the Q&A are published, but the answer provided does not answer the question that was asked.
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