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Tzarina of Compliance

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  1. Does anyone know where I can find the original study Defense Financial and Investment Review June 1985 or other relevant reading? I assume it discusses how the weighted guidelines for the DOD Structured Profit/Fee Objective risk ranges (2-7% etc) were set?. I am looking to see how this study could be leveraged by other smaller agencies to develop its own profit/fee objectives and ranges for assigning risk (why 2-7%? and not 2-15%?). Many thanks for any help or any helpful reading on this (other than Nash and Cibinic Cost Reimbursement Contracting which I have of course read).
  2. c) If the Contractor does not have an approved purchasing system, consent to subcontract is required for any subcontract that - [...] (2) Is fixed-price and exceeds - [...] (ii) For a contract awarded by a civilian agency other than the Coast Guard and the National Aeronautics and Space Administration, either the simplified acquisition threshold, as defined in FAR 2.101 on the date of subcontract award, or 5 percent of the total estimated cost of the contract. Which one applies? The SAT or 5% of the total contract cost? I always thought that consent is required for Fi
  3. Good point, looked at the IDIQ, nothing on evaluation except for this: b) The Contractor must furnish key personnel as stated in task orders. (c) The key personnel specified in task orders are considered to be essential to the work being performed thereunder. Prior to replacing any of the specified individuals, the Contractor must immediately notify both the Contracting Officer and USAID Cognizant Technical Officer reasonably in advance and must submit written justification (including proposed substitutions) in sufficient detail to permit evaluation of the impact on the program. No r
  4. Thanks all. @formerfed made me look at validity of the offer and it expired at 9 months (!!!! last month) and no extension has been requested (🙄 typical), so this works with timing and also with any potential protests. As always..... merci
  5. Section H Says Key Personnel : Project Manager, Deputy PM and Third Position TBD (positions and personnel to be proposed by the offeror). All replacements for Key Personnel will require approval of the CO.
  6. Correct. The Key Personnel positions were to be proposed by the Offeror.
  7. Thank you @formerfed Do you believe that this is okay because this is a Task Order and not a FAR 15 acquisition or just because the timeframe is unreasonable and the RFTOP does not specifically require evaluation of Key Personnel?
  8. Nothing in the Evaluation Criteria. It only says the offeror SHALL propose personnel for the following Key Personnel positions: Project Manager, Deputy Project Manager and a third position of offeror's choosing.
  9. Thank you all. It is very strange but this thread was not showing up in my feed so I am late to this party. Happily Vern answered my question in person. The Limitation of Pass Through charges is included and the subs do not represent more than 70%. Therefore it is irrelevant that their profit (in FFP subcontracts) or fee (in CPFF subcontracts) is in addition to the fee the prime charges. CAS DS includes allocation of Sub Handling indirects to all subs. Thanks again
  10. I am looking for the esteemed Demi-Gods of Govcon team's recommendations on the following: FAR 16 Task Order procurement under an IDIQ among 6 holders. Proposals submitted 10 months ago and oral presentations conducted 2 months ago but no award yet. Key Personnel individuals had to be proposed by the offerors under one of the IDIQ labor categories (discretionary quals in one of the categories). Evaluation Procedures did not specify that Key Personnel resumes would be evaluated but since the RFTOP required that Key Personnel be proposed, isn't it assumed that KP would be evaluated?
  11. The agency issues a CPFF Completion type contract and a Contractor submits a cost proposal which does not include any subcontractors. The Contractor wins the contract, the fee is fixed and a fee schedule is completed for the payment of fixed fee allocated to each of the required completion targets. After the award, the Contractor decides to bring on 3 subcontractors. It competes the subcontracts and wants to awards 3 fixed price subcontracts to provide services in the performance of the prime contract. The Contractor requests consent and is granted consent to subcontract. Should the fi
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