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About NenaLenz

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    Copper Member
  1. I think it is a bit odd, too. The SINs are for services. If there are goods/supplies, they are ancillary to the services. The sister companies are listed on the GSA schedule as "participating dealers", with the idea that the company would "self-perform" work by using the labor of its affiliates/sisters. I'm trying to untangle all of this and figure out how it should be set up.
  2. No. The parent company and all the subs/sisters are large. So: the FAR regs are silent as to whether transactions between separate but affiliated companies are subcontracts. But the SBA regs are not silent -- they consider those transactions to be subcontracts. Accordingly, while subcontracts with mandatory flowdowns are not required, consideration of small business subcontracting goals is required? The sister company can't delegate 100% of the work to its affiliates/sisters without violating its small business subcontracting plan, which require good faith efforts toward S/DBE subcontracting goals? Your conclusion makes sense from a strict reading of the definitions. But it is not good news for us.
  3. It sounds like there is no clear answer in the regulations on how to structure/document the assignment of work between the sister companies. The contract itself does not say, either. Follow-up question: The contract-holder is a large business with a small business subcontracting plan. Relying on the regulations, can we take the position that they are not subcontracting when they delegate work to the sister companies, meaning they are not required to use good faith efforts to award that work to S/DBEs?
  4. You're right, the concept of affiliates is broader than what I described. Here, they are "affiliates" because they share the same parent company (they are "sister companies"). They are each wholly owned subsidiaries of the common parent. They are different companies with different DUNS etc. One company holds the GSA contract. Other companies do the work. How should they facilitate that? Subcontracts? Inter-company work authorizations? Does that clarify my question?
  5. I am wondering if the current practice is acceptable.
  6. I searched prior threads and couldn't find guidance quite on point. Question: What is the proper way for a GSA Schedule-holder to delegate work to affiliated companies? Intercompany work authorizations? Subcontracts? Facts: The companies are wholly owned subsidiaries of a common parent. One affiliate holds the GSA Schedule contract. The SINs are all for services. Contract-holder gets the contracts/POs/BPAs. Work is performed by affiliates. Contract-holder delegates work to affiliates through work authorizations. Contract-holder submits requests for payment to purchasing agencies. GSA contract lists affiliates as "participating dealers". Contract-holder does not have "subcontracts" with affiliates. I've searched the regs and guidance and I'm not finding a clear answer. Am I missing something.