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Krimz

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  1. I realize this is an old thread, but my agency is doing exactly this. I email a DUNS number to specific email address and within 20-30 min. receive a Contractor's Responsibility Assessment that consolidates SAM Registration, FAPIIS, Reps & Certs, etc.
  2. Thanks for taking the time to explain it to me. I believe I have a way forward that will satisfy myself & my customer.
  3. I do want our agency to be successful, that's for sure. My final question is, what is the difference in a labor-hour contract for 2080 hours, and a FFP contract for 2080 hours, both having identical SOWs? That's what's confusing me, and I am only just realizing that. I know what FFP is, and think if we defined exactly what the contractor was expected to do with defined quantities and deliverables, I can see how FFP would be appropriate whether the contractor proposes an hourly or each (task) UOM. But our SOW is open-ended, and since the UOM is based on hours worked, I don't see how that ca
  4. FAR 37.104 Like I said before, this isn't a pass/fail test, but the contracts in question tick almost every single box in FAR 37.104.
  5. That is exactly what is happening with these contracts. A very apparent employer-employee relationship has been established, and I do not know any other way to structure this contract so as to avoid that. There are other details that I can't share here that I am sure would make this much more clear, but I think based on what I've given so far, it's pretty clear these are LH or personal service contracts, and should not be FFP. Maybe I'm wrong. As for FAR 37.112, that's exactly how some of these contracts began, as NTEs for 120 days. These required approval at a very high level (I don'
  6. jl20874, out of curiosity, what do you consider a personal service? We can state service contracts in terms of outcomes, but the FAR is pretty clear that personal service contracts are prohibited unless authorized by statute, which they are not in my organization. I'll try to find the law referenced in the FAR and by our HR that states circumventing the hiring process is illegal. Some of these started as temporary personal service contracts NTE to 120 days, and then grew into base + 4 contracts, which was expressly prohibited. Maybe I have a different definition of personal service tha
  7. Because they are attempting to contract for a position that parallels a government employees PD. And they explained to me that they’ve tried hiring a federal employee to do the work, but they can’t get certain approvals, so that they will need to contract for this person. I’m fine with contracting for performance based acquisition and defining the need in terms of required results/deliverables, but that’s not what my customer wants. They want an employee that they can assign work to on an as-needed basis. They tick almost every box for FAR 37.104(c)(2)(d): (d) The following descri
  8. Asking them to provide a receptionist is exactly what I am trying to avoid. To me, that is very clearly a personal service.
  9. I'm fine with a broad scope as long as it can be administered without much CO intervention. We've been told that labor-hour contracts will not be approved, so that we should treat them as FFP and do our best to structure them so. I'm just not sure how to do that since LH and FFP are polar opposite contract types.
  10. I'm not saying we can't contract for these services, but I don't see how an open-ended contract for undefined services meets the definition of FFP: In the scenario at hand, these contracts are not actually FFP because they are open-ended. How can the contractor provide an FFP quote unless we define exactly what work/tasks will be required? The only way I know to structure a contract for this kind of requirement is to go the labor-hour route, which I'm told we will not receive approval for. I asked my customer to re-work their SOW so that it addressed a specific, well-def
  11. Hello Wifcon, I'm a specialist at a civilian agency, and, along with a few colleagues, I continue to come across "support service" contracts that are being administered inappropriately. I'd rather not be too specific for obvious reasons, but I'll do my best to lay this out in as helpful a manner as possible. My goal is to find a way to get my customers what they need, as difficult (or sometimes impossible) as that may be. The current scenario is this: the service contracts in question are essentially open-ended labor-hour contracts (2080 hours annually, no specific tasks or proj
  12. Well, a BPA call becomes binding. A BPA never is binding.
  13. Thanks for the suggestion. It's a good read, and it really confirms my own thoughts. That said, I've just come across a BPA against which I am authorized to place calls with a per-call limit of $1,000,000, which does not require synopsis. I do not have all the details on how it was established, but I know of no procedures that would allow me to circumvent the synopsis requirement of 5.201.
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