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WifWaf

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  1. This referred to the question: A poorly worded question to be sure, but still we could just as well make something of this OP and reword it: “How should a contractor ensure a causal/beneficial relationship between the ‘costs for rent, electricity bill, corporate jet operations, the company Fourth of July picnic, or anything else included in OH or G&A pools’ and a fluctuating direct labor base, subject to PCO wage determinations and sovereign acts of minimum wage increases?” This would serve to broaden perspectives of P/ACOs to their industry counterparts’ in this Contract Administration (a two-way street) forum.
  2. This thread makes sense from a PCO perspective only. From an ACO or contractor perspective, the answer given is rather unsatisfactory. @Neurotic, are you asking questions from the perspective of a PCO/analyst, an ACO/analyst, or a contractor?
  3. Some use a DL hours base for their SCA work’s overhead, for this very reason.
  4. Having once worked in a high-functioning organization of the USAF that procured these, I can help here. We won an award at the AFMC level for an our work one year competing amongst other systems contracts shops made up of 50 people or less. As a GS-12 CS, you could get a $5M limited warrant based on supervisor discretion by passing a written board exam after 2-3 years’ experience in the shop. To go from that to an unlimited warrant, you had to pass two boards and have no less than 3 years’ experience in the shop to get a warrant. There was the written warrant board that was standardized across all of AFMC, and then there was the oral board chaired by our GS-15/O-6 Chief of the Contracting Office (known outside USAF as a “Procurement Director”). A GS-13 warrant candidate would normally speak with a GS-14 supervisor during midterms or performance appraisals about their intent to go to the board, and would then be allotted some time to pursue this. You kept your workload but would have your assigned CS prepare much of your work at the same time. You spent time in self-study after work and were allowed time for group board cohort study during work. The process to get the warrant took 3-6 months. How else can I help, @MichaelJonReed?
  5. Neurotic, Just follow FAR 52.222-43. FAR 52.222-43 and FAR 22.19 are set up so that the PCO will just increase his DL costs, thus letting the newly increased costs accumulate in the overhead base (if contractor uses a DL cost base) and the G&A base without making a change to his contract-level indirect rates. That way, the contractor’s DCAA or ACO can in turn respond to him and other PCOs increasing DL costs by issuing a new PBR letter or FPRR based on the accumulation of these new, increased costs shown in the contractor’s certified incurred cost submission’s bases, in the year they are incurred. We are all cogs in the machine here.
  6. From the subject article, preceding its conclusion to use the perceived inadequate definition of "Subcontract" in 13 CFR 125.1: My emphasis in bold. Might the FAR Council resolve this issue by revising FAR 2.101 to add a definition of "subcontract"? I see there is currently an open FAR Case No. 2018-006, "Definition of 'Subcontract'," but I am not sure what their plan is to implement that Case's statutory basis for change, which was that 41 U.S.C. 1906 was amended to change its definition of "subcontract" for reasons unrelated to the matter at hand here. Regardless of how it happens, there is a basis for consolidating the definition into FAR 2.101 sometime soon: it was part of the Section 809 Panel's first recommendation. See Report of the Advisory Panel on Streamlining and Codifying Acquisition Regulations, Volume 1 of 3 (January 2018), Recommendation 1, p. 14 (https://discover.dtic.mil/wp-content/uploads/809-Panel-2019/Volume1/Recommendation_01.pdf)
  7. Well, if that ever changes, or if any other reader ever wants to know how to work the system, then note I just went to usajobs.gov, typed in keyword “writing system” using quotation marks, and clicked on the only high-paying job in the query results. The lower grades’ JOAs just required you know a contract writing system, not oversee it.
  8. No. There are programmers contracted to insert the clauses in the contract writing software databases. They usually have a COR whom can navigate the Federal Register, the regulations, and the Class Deviations, in order to assign them their work. Maybe that's the kind of job you want to pursue? Try this one, which is open to veterans: https://www.usajobs.gov/job/640252800 You'd have to have this experience (my emphasis in underline): I guarantee it's good work if you can get it - at least, until it gets automated someday. By then, however, you're already in with the U.S. Army Medical Research and Development Command (USAMRDC)! Read about them here: https://mrdc.amedd.army.mil/ and see this excerpt about their mission: I used to love job-hunting. This just made my lunch hour 😃
  9. Thanks for sharing that, Joel. Did he teach any classes you attended while he was there?
  10. https://bitwizards.com/thought-leadership/blog/2012/march-2012/4-types-of-people-every-entrepreneur-needs-to-know
  11. “Now, I know advice is cheap and often suspect, but here goes. You’ve had a good start and there’s a long road in front of you, but always remember this: Your most difficult problem will be the people. In the military, they mostly divide themselves into four major categories: There are the ‘me-firsters’, the ‘me-tooers’ the ‘deadwood,’ and the ‘dedicated.’ You are among the minority, the ‘dedicated.’ Stick with them, search them out, and work hard to be worthy of their company. You won’t be popular with a lot of your bosses who act dedicated but really aren’t, and that can make life difficult at times. Beware of the ‘deadwood.’ Most of them mean well and, in their own way, try hard, are loyal, and even useful. But too often they’ll botch things up and get you and your outfit in trouble. Watch out for the ‘me-tooers.’ These guys will tell you whatever they think you want to hear. They borrow thoughts and ideas from others and present them to you as though they were their own. They are opportunists who look for every avenue to advance themselves, without sticking their own necks out. They ride someone’s coattails and try to make themselves indispensible to the boss. Believe me, they are not to be trusted. You don’t want yes-men around you. But you can’t always avoid them. The worst and the most dangerous are the ‘me-firsters.’ Most of them are intelligent and totally ruthless. They use the service for their own gain and will not hesitate to stick a knife in your back at the slightest indication you might stand in their way. They seem arrogant, but don’t be fooled; they are really completely lacking in true self-confidence. Do you understand that?”
  12. In DOD system acquisitions negotiations, is the understanding of these points the CO's job or the Contract Price/Cost Analyst's job? In other words, should a CO take the analyst teammate's word for it if the teammate agrees with the contractor.
  13. Joel, I know you’re speaking in context, but out of context my mind goes: “Oh, what a novel idea!” 🙄
  14. That NASA article says the SpaceX subcontractor knowingly transported contaminated fuel from 2012 to 2020. The Wikipedia article on SpaceX Dragon 2 says, “The first automated test mission launched to the International Space Station (ISS) on 2 March 2019.[51] After schedule slips,[52] the first crewed flight launched on 30 May 2020.” I remember this being a moment of American engineering resurgence, as we no longer needed to rely on Russian rockets to get to the ISS. Here’s a source confirming my recollection. Was this company “Anahuac Transport Inc.” and particularly its Corporate representatives Gary Monteau and Brant Charpiot (whom admitted guilt) willing to risk the United States of America’s international standing on the world stage just for a few extra thousand bucks each shipment?
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