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LeighHar

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  1. Thanks formerfed for your input, its greatly appreciated.
  2. Aside from NCMA's Career Path In Contract Management, I'm wondering if anyone is willing to share resources that describe the skill set, experience, and performance expectations, etc of contract management professionals at various stages within their career. For example, a comprehensive description of knowledge/abilities to perform at the contract assistant, administrator, manager, deputy/associate director, director, vice president, etc levels. Thanks in advance for any suggestions or resources you can share
  3. I would like to receive input regarding compliance with Section 508 of the Rehabilitation Act of 1973. We received a USG-funded contract that includes the requirement to provide a comprehensive list of 508 compliant electronic and information technology (EIT) products, as a deliverable. Can anyone confirm that 508 compliance only applies to EIT products that are not incidental to a contract, i.e. EIT products expected to be turned over to the agency as deliverables?
  4. Thanks Retreadfed! So based on this, if prices did not change from the subcontractor's submission of their prices (nearly a year ago) that were included in our proposal and subsequent contract awarded by the government, my interpretation is that they actually were not wrong to include this date (original submisison date of their budget) in the certified cost or pricing form. We did not require them to submit this certification at the time of the proposal (although I think we need to consider modifying our internal requirements for the pre-award/solicitation phase), we are asking for it now at the time we are preparing their subcontract as part of the approval packet.
  5. We are requesting documentation from a subcontractor in the form of a Certificate of Current Cost or Pricing Data (btw, not required from us as the Prime from the government) but we in compliance with our procurement policy. My take on the date listed in the certificate is that it should be dated as close to date the final subcontract is signed as possible. We had a sub that completed the certificate recently and dated it from (are accurate, complete and current as of) August 2022, when they had submitted their prices to us for inclusion in our proposal. Our policy is silent on the date, but I want to get the community's input on this. The budget/theri prices did not change from their original submission/inclusion in our proposal and we are working on the details of their subcontract now. For auditing and compliance purposes, shouldn't the certificate be dated from today/recent date and not the date of their original submission?
  6. @Neil Roberts, this is helpful though I'm unclear on a few of your comments. It sounds like these two major prime contractors you worked for would/could then collect updated certs n reps several times a year if a subcontractor was receiving several large payments, because once a year was not sufficient in case the subcontractor's data changed between payments. Is that correct? I'm not clear on your point about administratively inconvenient and expensive. In trying to understand what to include, I looked through the FAR and also looked at a couple of examples in which my company is a subcontractor and were asked to complete annual certifications. I've compiled it in an Excel doc that I'm attaching here for everyone's use (and hopefully feedback). There examples of primes who sent us annual certs to complete and sign are in Columns I-L (and the check boxes in each of the columns represent that they had included). Please let me know what you think. As another option, I was wondering if it would be best to tailor each subcontractors annual certs-n-reps to include those FAR provisions that the CO had included in the solicitation. This could be quite time consuming and labor intensive. Annual Certifications.xlsx
  7. Just wondering how other contractors manage subcontractor annual certs-n-reps. Do you have a form developed by your organization that you request subcontractors fill out annually? If so, is it a standard form or is it tailored to the section K included within the solicitation that they now work on as s subcontractor? Do you review and keep copies of their SAM.gov current record? I am thinking that developing a statement similar to that found in FAR 52.204-8 (d) would be sufficient (changing reference to "solicitation" to "subcontract" and "offeror/offer" to "subcontractor/subcontract" to have the subcontractor sign off on annually, with a copy of their current SAM.gov certs-n-reps. Looking forward to getting your input on how you manage and document annual subcontractor certification after award!!!
  8. Joel, your summary is correct. We do not want to show up as a small business, but when looking at our current registration, we do (see screen shot in my message above) and I am not able to edit the box. As more context, we were previously a small business but have now grown and based on annual revenue/receipts, we do not qualify as small. I was trying to understand or ask if anyone knew why or how to fix it. I had previously reached to FSD help desk who referred me to PTAC. I started the process with them but then stopped because it was taking too long and I needed to get our registration active and also I think I recall PTAC prompting for payment for assistance which I did not have the authority to do. I'll go back and revisit this issue. I do get a sense that if you are checked as small in any of the NAICS codes you chose, you are automatically listed as small. Again, noting that of the 12-13 NAICS codes we list in our SAM registration, under one of those, which is based on number of employees and not receipts/revenue, we are listed as small because we do not exceed 1,000 employees. We have been completing certs-n-reps for individual solicitations, but if there's options to do it from our SAM.gov registration that would be preferable. For now, we will continue to complete Section K on a case by case basis. Thanks for your insights!
  9. I appreciate the responses to much! To clarify, I do have access as an administrator to our SAM registration. And a bit more context, my entity was previously fully considered a small business based on annual receipts/revenues and have since grown to exceed the revenue thresholds to all of our NAICS codes so we consider ourselves as and represent ourselves to the federal government and potential partners as NOT small so it is concerning that we show up as "small" in SAM.gov but it seems this may be the case because of one NAICS code. The also came up based on a recent solicitation in which we are not small for the NAICS code (541611) and the solicitation stated the following: The Offeror and each proposed subcontractor must complete and sign all the Representations, Certification, and Other Statements as described in Section K. Online submission of Annual Representations, Certifications, and Other Statements via www.sam.gov is sufficient if the Offeror chose paragraph (d) of the provision under FAR 52.204-8. Please indicate in your proposal if online certifications and other statements were submitted. We are not small based on the NAICS code (541611) for this solicitation but will complete and fill out section K because I don't think we can reference our SAM registration because we are listed as small (but maybe I'm not understanding correctly?). In the future, we would like to use our online certs/reps/assertions if possible instead of filing out Section K included in solicitations but based on the issue I described, I don't think we will be able to because it seems that the system marks you down as a small business if you qualify under one NAICS code as small. We were wondering if the issue and next step would be to reach out to SBA to resolve the issue, but I think the information on SBA's dynamic small business search page pulls directly from SAM.gov
  10. In renewing the SAM.gov registration for the entity I work for, I noticed that under clause FAR 52.212-3: Offeror Representations and Certifications – Commercial Products and Commercial Services (Nov 2021) and specifically (c)(1), the box in sam.gov is checked as “is” a small business concern. The box is greyed out and thus uneditable. The company was previously a small business but have since grown to other than small several years ago. We have 13 NAICS codes listed and one of those has us marked as a small business based on the number of employees (1,000 employees being the threshold which we have about half that number). All other 12 NAICS codes (including the one listed as our primary code) has us listed as not small based on our annual revenue. Does anyone have a better understanding of how sam.gov works? Would this one NAICS code cause us to be defaulted to "small" in the system? Can this be updated? Should I try to get it updated? I double checked in SBA's Dynamic Small Business Search and we show up there but I understand after doing a bit more research that it pulls from sam.gov. I appreciate any thoughts on this topic.
  11. I'm hoping this follow-up will help. I understand that novations usually occur between the government and the prime contractor. In this case, we are the prime contractor and a subcontractor (who was named in our proposal) has been bought by another entity and will be entirely absorbed by the new entity. We will need to modify their subcontract to recognize the new entity. The FAR details out what COs need to obtain from prime contractors undergoing a buy-out, but I am wondering what documentation we should be requesting to modify the agreement and ensure we are conducting due diligence and have sufficient documentation on file. Our contract also does not contain, 52.244-4. As I mentioned, the subcontractor was named at proposal phase though. Based on this, should I just inform the CO of the change in subcontractor and the circumstances of that change? Should I provide the CO with any documentation provided by the original subcontractor/new subcontractor?
  12. If you novated a subcontract, what documentation did you require before doing so? If you had a contract novated, what did your prime contractor asked of you before doing so? FAR subpart 42.12 lays out the requirements for the government to novate an agreement from the original contractor to a successor, and specifically, as per the list of items at 42.1204(e) and (f). In the case of the need to novate an agreement between you (as the prime contractor) and a subcontractor who has been bought and absorbed (merger situation) by the successor in interest, what documentation does your organization/entity require in order to process the novation? I'm assuming the extensive list required for government Contracting Officers to novate contracts (as per FAR 42.12) with their direct prime contractor is not necessary at the prime/first-tier subcontactor level but I'm curious to hear from others. I recently was advised by an entity that they did not require any supporting documentation before novating a subcontract agreement, which seems extremely irresponsible to me, but look forward to hearing from those who have such experience. Novations are brand new to me so I'm excited to hear others' experiences.
  13. Hello, Looking for advice on what specifically to report under the large business/other than small business category of the ISR/SSR reports in eSRS for those who have federal work largely implemented overseas (with such agencies as USAID and Dept of State). Do you include local businesses and LLCs that might be under purchase orders? If not purchase orders, do you include local entities, if they have a subcontract? What about work done in the U.S. Do you count purchase orders?
  14. Hello all, for reporting requirements of fixed price service contracts, how do you report on number of direct labor hours expended? Do you keep track of actual hours expended and report on that or do you use the estimated hours that were utilized to develop your proposal and subsequently accepted by the government as per the fixed price final price in your contract?
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