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  1. Large public company is looking to hire a government contracts compliance professional to help build and manage a federal/state/local contracts compliance program. They do not currently have a program in place. Anyone here aware of a recruiter that specializes in this type of hire? Any recommendations would be much appreciated. Thank you.
  2. Yes, sound advice, but to implement that advice, we need a plan. This conversation is about what makes sense to put in the plan.
  3. @Neil Roberts - There is no rule precluding subcontracts. Yes, the company does have long-term agreements with material suppliers. It is my understanding that none of these agreements are with small businesses. Because those are long-standing agreements that pre-date this government contract and will not be modified for the performance of this government contract, I do not believe those long-term agreements are necessarily government subcontracts. I suppose we could propose that when those supply agreements are up for renewal, the company could use good faith efforts to identify and contract with small business suppliers. But my understanding is that we already know there aren't any small businesses that make the specific items that will need to be purchased under those supply agreements. Therefore, I am not sure what subcontracting goals make sense to propose--the company most likely won't hit any targets we set. For overhead item goals, could we include them in the individual plan or would those need to go in a commercial plan?
  4. @Don Mansfield a fair response to a vague question. I’m trying to figure out whether the VA can require the company to submit a plan that includes goals that are not zero. As I read the rules, there will not be any “subcontracts” involved in performance of the contract. Therefore, putting any goal other than zero is not attainable and I don’t even know what good faith efforts toward meeting the goal would look like. The company has its supply chain established with long-term agreements in place with the suppliers for the materials that the company uses to self-manufacture the products. None of this will change for performance of this contract. The company has no other federal contracts under which it could pick up credit using a commercial plan. This can’t be a unique situation. How do other companies handle this?
  5. Client is applying to get on VA Schedule to sell medical devices. There is no way to engage small businesses is any part of performance of the contract. VA will not accept a individual plan with a goal of zero. What should the company do?
  6. Because this is a micro-purchase for a COTS product on the VA FSS, there was no requirement for competition if the procurement agent gets a Dr. Rx. My understanding is that the VA Dr and patient saw the product and tested it to make sure of fit and function for the specific needs of the patient. The Rx was sent to purchasing dept. When a product was delivered to patient home, it was an entirely different product.
  7. Yes, the company learned about it -- this is helpful. Thank you
  8. Yes. We are the supplier that the doctor and patient prefer.
  9. Follow-up question - If the purchasing agent refuses to change his or her purchase order, which is the appropriate procedure for disputing/appealing the purchase? Thanks!
  10. @Jamaal Valentine and @Deaner - thank you for the input. This is exactly what I needed.
  11. FWIW - this appears to be the form that purchasing agents use to place prosthetic orders - Prosthetic Authorization for Items or Services, VA Form 10-2421
  12. Thanks, @Jamaal Valentine I realize that I packed a lot into my first question. I'll try to unpack it with a bit more factual context. The fundamental question is about purchasing authority. Generally, prescribing doctors working with VA patients do not have warrants. They are not authorized purchasers. They cannot bind the government. But they are responsible for determining what is medically necessary for patient care. Here, I'm trying to figure out how procurement of prosthetics works. Prosthetics are defined broadly by VHA to include basically anything that replaces, supports, or complements the human anatomy (e.g., orthotics, hearing aids, medical equipment and supplies, etc). According to VHA Handbooks 1173.1 , 1173.2 and 1173.08 , VHA Prosthetic Departments are responsible for procurement of prosthetics. Here is the scenario: Dr writes Rx for a specific prosthetic item deemed necessary for a veteran patient. Rx is for a COTS prosthetic that is under the micro-purchase threshold and is on VA Schedule. Other manufacturers that sell this general type of COTS prosthetic to the federal government. Dr thinks this particular COTS prosthetic is best for patient care. Rx is sent to the local VHA Prosthetics Department and a prosthetics purchasing agent makes the purchase. Prosthetics procurement agent decides to purchase a different COTS product from a different vendor. Dr. is not happy and neither is patient. Does a Prosthetic Purchasing Agent have the authority to ignore the Dr choice of prosthetic? Thanks for any insight you can offer!
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