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About TGLJ

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  1. Thanks so much for confirming my thoughts. I'm now more confident in applying all FAR 8 procedures without concerning myself with Pt. 13.
  2. My question is about whether or not we treat BPAs issued under FAR 13 and FAR 8 procedures are generally as it relates to issuing orders past BPA expiration. While searching for an answer I came across a previously referenced (in this blog) NIH FAQ on FAR 13 BPAs. The following was part of that FAQ: 7. Can a BPA Call for services extend beyond the period of performance of the parent BPA? Yes, BPA Calls for services may extend beyond the period of performance of the parent BPA. However, if a BPA expires and is not renewed, you may not add more funds to the BPA Call. 8. Can a BPA Call be placed on a BPA before it expires? Yes, a BPA Call can be placed against a BPA before it expires. However, performance must begin before expiration of the BPA. A BPA Call cannot be placed against a parent BPA with performance on the BPA Call to commence after the parent BPA ends. Reading FAR 8.405, I don't see any limiting factors similar to BPAs issued under FAR 13. If the same questions shown above were asked about a FAR 8 BPA would the answers be different? The way that my agency has handled calls issued against 8.405-3 is essentially akin to a task order issued against an IDIQ (FAR 16.5), at least in the sense that they fund a call after the BPA has expired (but not the schedule), and sometimes even "update" the scope of the call order after BPA expiration. Does anybody have information that specifically states we have to follow the same rules provided for under FAR 13 when issuing BPAs/calls under FAR 8? thanks in advance!
  3. Vern: Yes. Whenever funds are realigned we get the contractor’s signature. Thanks!
  4. Yes it does. I figured that was the answer based on my research but wanted some verification from the community. Thanks Vern!
  5. Yes, Vern. I do mean moving funds between line items in the same performance period. It's just that the base performance period is 5 years while the funds being utlized is one year money. I'm not sure if that makes a difference but it seems like it should.
  6. Hi all, first time commenter but have been following for a while. I could really use your assistance on the below issue/question as it's starting to come up more and more at our agency. I'm not sure why it's just now coming up but regardless...I've searched long and hard to see if this particular issue has been addressed and couldn't find anything that seemed to fit, so here goes a new topic posting: Issue: in FY15, an agency awarded a GSA FSS task order for travel management/logistics services. The task order is a mix of T&M and FFP CLINs, and the period of performance was set for a base period of 5 years, with 2 five-year options that aligned with the firm's GSA Schedule performance period. The order was initially funded with 1-year (FY15) money and, other than a smattering of no-year funds, there have been no additional funds added to the task order to-date. The program office has requested to realign/move funds b/w two CLINs, both of which are in the current 5 year base period, but they’re requesting to realign existing funds (from FY15) to cover costs. There is no ceiling increase or scope change associated with this request to realign funds. Question: Does the CO have the contractual authority to realign/transfer funds from one CLIN to another within the five year base period, even though the funding obligated on the order is all from FY15? Remember, for the purposes of this argument they're still paying for services using funds they applied in FY15 at the time of task order award. Thanks in advance for any guidance. This forum has been vital to my growth as a CO!
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