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ConMan1982

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  1. The more I think about it, I believe it's really just a bonafide need issue. If it's severable, we only have the year since we're crossing fiscal years.
  2. I'm working on a large dollar Advisory and Assistance Contract that is about to be transferred from DHS to USDA. Congressional approval was granted for DHS to transfer funds to USDA, These funds are FY18 two year funds which we anticipate receiving around August/September. I know we have until end of FY19 to get these funds obligated before they expire but what I'm trying to figure out is how long the funds remain useable. When using annual appropriations, bonafide need allows one year from date of obligation to use the funds (crossing fiscal years) unless we are purchasing a non-severable ser
  3. Yes, that may be our best bet. I prefer to solve problems before they've become problems but doing so could just cause more problems (protest). Based on the first two years of performance, government hasn't utilized the full level of effort afforded in the options. The thought is that the work, as originally estimated, still needs to occur just not at the schedule they wrote the contract for. We may end up just having to issue a follow on if the need arises.
  4. Sorry, meant a T&M with fully burdened fixed labor rates.
  5. I appreciate your thoughts on the matter. I wish I could find a specific case that shows how GAO would rule on the matter. My opinion is that it would not have affected the availability of competition as it's the same work, it would just be re-organized how we structure and elect to exercise said work. The more I think about this the more my thought is to leave it be. If there isn't strong support that GAO would rule in favor of the COs decision to restructure it would likely be something that could trigger a protest. I'm not convinced the current structure is bad enough to be willing to intro
  6. Starting over with a new competition or doing a new contract under sole source authority is not currently an option. Our original plan was that we would move forward with a sole source award for an IDIQ Time and Materials contract rather than transfer the original contract. Department has overridden us and is now instructing us to transfer the contract. Thank you for the reference CC, I actually went down this rabbit hole previously about changing contract type but determined that changing from a CPFF LOE to a FFP T&M would trigger CICA due to the accounting system requirements for a cost
  7. My agency has been tasked with transferring a CPFF LOE Term contract from another department. The contract was set up with a base and 9 option periods each with a level of effort and ceiling for a one year period of performance. I have a question concerning whether a restructuring of the future unexercised option periods would be allowed under a bi lateral modification or if adding options would trigger CICA. The rationale for considering such a change is that doing so would allow us to only exercise the amount of effort needed as we add work packages to the contract. In a way, making the cont
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