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p5tMike

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About p5tMike

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  1. It's FFP type Retreadfed, and correct, the language doesn't specifically state the issue; and Vern - you are correct I was quoting some standard verbiage from delegation formats. Thanks all for the information. I think I have enough to rely on now regarding the matter. Again, thank you all. Mike
  2. A typical delegation includes a statement saying "the COR CANNOT "make any agreement with the contractor requiring the obligation of public funds......." and ", or in any way obligate payment of funds by the Government"". I interpret that signing time cards are inconsistent with both of those 2 stipulations.
  3. Thank you Vern, PTaylor and BowtechDan - each of you confirmed my position on the practice. Now, to make such a widespread practice stop - it won't be an easy tasking at all.
  4. Vern - no, the contract doesn't require to sign time cards. The label is shown in the attached. The companies are essentially requesting the Government perform their administrative/supervision/payroll function from what I observe. Retreadfed - they are non-personal, as stated in the award documents. PTaylor - my position is that the signature obligates the signer to verification of time. But worse, in my opinion, it eliminates Government ability to argue if outside observers, i.e. other physicians, etc., make claim on non-attendance. Additionally, my position is that the signing in itself "receives" the services prior to a demand for payment. Further, it opens the door to conflict of interest. And, how can I trust my COR at this point? I'll check out that action. Thank you. I'll take any further advice anyone has. Thx - Mike Copy of Requested Signature.pdf
  5. Can anyone provide information regarding risks related to a Government employee signing a timecard (as if the Government employee were a supervisor)? I'm finding instances where Contracting Officer's Representatives (CORs) have been signing timecards for doctors or related contractor-provided personnel (whether they are an employee of the contractor, or acting as a subcontractor). The then-signed timecards are then sent to the company by the contractor employee. I'm concerned about risk, but I'm not finding any significant supporting information about the does-and-don'ts about this practice. Thanks in advance for any assistance. Mike
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