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Kat

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  1. I'm currently working on Small Biz Subcontracting Plans for proposals that include both labor/services and hardware/items. We are a large business, subcontractor to a large prime. Seems an exception or clarification in the FAR would make sense so purchases of raw materials, parts and components that get fabricated/manufactured into a larger item would not be considered subcontracts for this purpose. Unfortunately I haven't found anything that strongly supports that, so we continue to prepare the Plan. As an example, current effort lists 500+ items amounting to $1M+ (~39% of total proposed value) to purchase from more than a dozen different vendors. Many material vendors do not identify themselves under any SBA socio-economic category. Following this thread in case of further participation. Thank you.
  2. Thank you for your quick replies @here_2_helpand @Vern Edwards! Very familiar with FAR 52.244-5; it is referenced in our draft policy. I may die on my sword muttering ". . . to the maximum practical extent . . it wasn't practical!". In most cases our hardware pricing team is on a quick turn and it's not practical to seek new quotes for every order. The consultant who drafted our policy manual followed the government thresholds as a guideline; I'll work to ensure the policy language doesn't lock us into something unnecessarily restrictive. The CPSR Guidebook has an update, dated June 14, 2019. It's always open on one monitor while working on these processes. Thanks, again!
  3. My experience has been in professional service contracting, and now work for a company that also does manufacturing. I have been searching WIFCON for this scenario. My employer has experienced growth through acquisitions similar to that described by jumpmanz5. My employer consists of business units, some that manufacture products which are sold to prime customers for government contracts, and, in some cases, other companies. We do not currently have officially determined commercial items, catalogs, or price lists. We are currently establishing policies and building processes to ensure we pass a future CPSR. I also agree with here_2_help: Question 1: Where can I find guidance regarding competitive source selection requirements when some of the components and raw materials are purchased for and pulled from inventory, while others are purchased for a specific build? Question 2: If a particular quote to our prime customer includes components from multiple suppliers, does the micro-purchase threshold apply to each supplier, or to the whole lot of widgets being purchased for that particular build? I do not want to violate the rule about not separating purchases to avoid thresholds. If it applies to the whole lot, then we would be required to obtain 3 quotes in order to be compliant, correct? Appreciate any help!
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