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  1. The items would be a direct cost to the contract. If an indirect company expense, I wouldn't be concerned too much about it.
  2. Hi, I'm with a small business firm. First, we register annually with the JCP. This is typically the first step required to gain access to Govt. export controlled data. As far as actually manufacturing items and complying with any applicable EAR/ITAR regulations that apply to the items - we make sure all our drawings are marked with the appropriate export warnings. We counsel our fabrication vendors on export law, which requires that they may not provide the drawing or allow the part to be made/accessed by any foreign nationals. The electronic copies of the drawings in their system must also no
  3. This question is regarding an R&D CPFF type contract with DoD, (this is not a contract to deliver any specific supplies or materials.) As part of the effort, the firm is creating a prototype for testing. The science team at the firm wants to buy some used components on ebay to save money instead of buying the components new from the actual manufacturer. The prototype that would be made from these components could be consumed in testing, it is unclear at this point, or it could have to be delivered to the agency as residual materials. It is not specifically a deliverable in the contract, it
  4. The budget line for fee in the proposal says " Fee (RATE X%)......... $$$$$" It was shown as a whole dollar amount but described in the line as a percentage. I'm asking what the best approach would be to use with a contracting office who just says "We just don't do that anymore on CPFF Contracts." They aren't discounting my proposed fee using any cost analysis methodology described in the FAR like... using the DOD weighted guidelines (this is a DOD contract)... Just stating they won't accept fee as requested because of a newly enacted business decision... UNLESS I agree to a FFP
  5. In the process of negotiating a contract for complex Research and Development exceeding $750K with a performance over 24 months with an Agency my firm very often receive awards from. Submitted a technical and cost proposal, showing fee applied as a percentage of total budgeted cost. The Agency has just implemented a new but unwritten policy/business practice only allowing the proposed fee percentage to be applied to labor and overhead costs if the firm wants to pursue a CPFF cost type award - so, no fee can be applied to materials, equipment, travel, subcontractor, ODCs, etc.. Howev
  6. Yes! Thank you for pointing that out. That is true, we just call them NCEs internally and it is a misnomer. If they were truly at no cost I would not have a consideration issue. As often as I need to request them, if they were at no cost to the contract it is also likely my employer would go out of business so I wouldn't have a job either haha. When I formally request extensions, I state that the current funds remaining on the contract will support the requested revision to the period of performance and no additional funds are being requested .. not that it is actually "at no cost".
  7. Thank you! I administer federal awards and have been pushing our PM Director to provide consideration with each extension request I facilitate with the Government. He's been refusing to give it to me up front and wants to wait to address it until the Govt. asks for it.... just in case they don't notice or ask. I feel it is (in its very best light) bad form on my part and ultimately delays the extension and makes my job harder when the KO notices that we are not offering consideration in the formal request for extension. Then I have to go back and get it from the team, redo the request...
  8. Hello, Can someone direct me to the FAR provision that spells out the requirement for Contractors to provide consideration to the Govt. in exchange for granting no cost extension requests? (Specifically, the requests I am primarily involved in are NOT due to any Govt. cause)
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