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Redskin Fan

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About Redskin Fan

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  1. Here's a different aspect I would look at as well. I see you indicated the technical personnel indicated the costs were envisioned as an ODC when they prepared the IGCE. My initial reaction to similar claims by technical personnel is then why the requirement was not specified in the SOW and priced accordingly. If they are attempting to tap into a pot of money (ODCs) for an award made in a prior fiscal year, just make sure you can establish there was in fact a bona fide need for the subscription in the prior fiscal year. (Of course I don't know the specifics or what type of money is involved but if you are crossing fiscal years I'd make sure I knew the answers.)
  2. Multiple-Year Funding

    Thanks, and sorry if I confused my post. I have two-year money that was awarded in FY16 and performance spanned into FY17.
  3. Multiple-Year Funding

    I have a question regarding multiple-year appropriations. With the end of the fiscal year coming, I’m getting requests to spend money, do extensions, etc. I’m not comfortable with one particular request. Unfortunately, I have no access to an appropriations attorney or another individual that can help out. So here I am. I have a severable services contract that was awarded last September using FY16/17 funds. It’s set to expire before the end of the month and we need an extension for a short period pending a re-compete. The existing T-M contract has funds remaining (no delays etc.- the work has just gone easier than anticipated). Program is asking to use the funds remaining on the contract to fund the extension into FY18. My Finance Office indicates the money can be used to fund performance into FY18 (though I have been given no specific reason why). I took a look at the Red Book and at GAO cases. I found one GAO opinion (B-317636, Subject: Severable Services Contracts) that seems on-point. It indicates “severable services are considered a bona fide need of the appropriation current at the time rendered. Consequently, an agency using a multiple year appropriation would not violate the bona fide needs rule if it enters into a severable services contract for more than 1 year as long as the period of contract performance does not exceed the period of availability of the multiple year appropriation.” That seems straight-forward to me that these FY16/17 funds cannot fund performance beyond September 30, 2017. I’d appreciate comments in the event I’m taking these few sentences out of context. Thanks