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Don Mansfield

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About Don Mansfield

  • Birthday 11/04/1972

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  1. Does the contract contain DFARS 252.232-7003? If so, the WAWF Receiving Report is the electronic equivalent of the DD 250.
  2. I don't know of an official definition of "overhead". Without one, I don't know how to technically distinguish between G&A and overhead. I checked a few reference books that assumed, but didn't explain, a distinction between the two. The Government Contracts Reference Book said "See indirect cost" in the entry for overhead. I've also seen and heard the term "home office overhead" used synonymously with G&A in unofficial communications. The OP seemed to assume a distinction between overhead and G&A. I knew what he meant by G&A, but I didn't know what he meant by overhead--other than it was an indirect cost different from G&A. If the OP asked "why do some contractors include operating expenses in their G&A pools and others create separate indirect cost pools to allocate the same type of costs?", then I would have known exactly what they were asking.
  3. Yes, that's the idea. This is a good explanation that I found in a Linkedin article: The article is a good primer on the topic of indirect cost allocation.
  4. What distinction are you making between G&A and "overhead"? What do you think "overhead" is?
  5. I think sometimes you just have to appease the FPDS gods, even if it seems kind of weird.
  6. For what purpose are you trying to categorize the action as competitive or not?
  7. On March 15, the FAR Councils opened FAR case 2023-010, "Use of Covered Application Services". According to the Open FAR Cases Report of March 17: Under "Status" the report states: My "take" is the FAR Councils think that public comment is not only relevant but required.
  8. @Vern EdwardsI thought we agreed to disagree. Remember I had FAR paralysis and was a moron for not understanding the crystal clear OMB memo? Again, so what? So what? So what? Maybe, maybe not. Depends on what the statute says. Then you've misunderstood. Complying with law and executive direction may or may not require a deviation from the FAR. Depends what the law or executive direction says.
  9. Seems like a cost overrun. Adding funds to acquire the required level-of-effort wouldn't necessarily be out of scope. It's strange that you received all of your fee without providing the entire level of effort. Lucky you.
  10. I'll address this and then we can agree to disagree. That's not my "take"--that is you resorting to a straw man argument. The relevant parts of 41 U.S.C. 1707 are as follows: Note that the statute contains a provision to account for exigent circumstances. However, in practice, most agencies will instead issue a class deviation in the form of an internal memorandum authorizing or requiring contracting officers to comply with the new policy. The Director of Defense Pricing and Contracting website currently lists over 40 such class deviations. Similarly, the Civilian Agency Acquisition Council website contains a long list of CAAC Letters advising civilian agencies to issue class deviations as temporary measures to implement new policies. We should expect to see something soon for No TikTok on Government Devices. If you think COs should publicize the new policy within their agencies and hold planning meetings, you'll get no argument from me. If you think COs should start developing and incorporating their own provisions and clauses in solicitations and contracts to implement the new policy based on just the OMB memo, then I disagree.
  11. I'm not sure what OMB meant. The memo was sent to heads of executive departments and agencies. It wasn't sent to contracting officers. Heads of executive departments and agencies are most likely working out how to implement the policy within their agency in a coordinated manner. I don't think they are expecting individual contracting officers to implement the OMB memo on their own with no further guidance.
  12. So what? The FAR Councils are working on dozens of cases that will implement laws enacted by Congress and signed by the President. So what? 41 U.S.C. 1707 requires the publication of regulations. Specific laws don't have to require the FAR Councils to publish a regulation.
  13. This policy will have to go through the rulemaking process before it takes effect (see 41 U.S.C. 1707). The OMB memo shouldn't be interpreted as a direction to contracting officers to start drafting and including implementing clauses in their contracts. Agencies may issue class deviations to implement the policy in the interim, or the FAR Councils could issue an interim rule.
  14. How about we call it a PO with options?
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