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About Lean_of_Peak

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  1. That does help a little in regard to contract clauses. Not sure the new NDAA 2016 issues I spoke of would spark new clauses. They may influence provisions though. I was wondering if an agency has to comply for new solicitations since its enactment. I thought we did but your comment in #5 gave me pause.
  2. The reason I ask the question is it seem contradictory to this discussion: www.wifcon.com/discussion/index.php?/topic/3250-comply-with-final-rule-not-yet-in-far/
  3. Vern, would that reasoning also apply to the new laws concerning small business Joint Venture teams and Prime/Subcontractor teams that came from the NDAA 2016 (the one requiring the consideration of capabilities and past performance of individual members of JVs as the JV's and subcontractors as the prime's) before implementing regulations?
  4. No I simply stated what it says. It doesn't say all types of contracts except T&M and LH. Maybe they should rewrite it to state "some types of contracts"
  5. FWIW FAR 19.800(a) states: Section 8(a) of the Small Business Act (15 U.S.C. 637(a)) established a program that authorizes the Small Business Administration (SBA) to enter into all types of contracts with other agencies and let subcontracts for performing those contracts to firms eligible for program participation. The SBA?s subcontractors are referred to as ?8(a) contr
  6. The approach you are contemplating is an "exclusionary" approach which is fine. Another approach would be a "quantitative" approach. For instance the evaluation range may be from poor/marginal/average/good/exceptional. You may rate the neutral as "average" which GAO has upheld. In other words there is not cookie cutter approach in how to treat neutral past performance. In at least one COFC case the court actually preferred the "exclusionary" approact which they held as being the most pure method of handling no past performance as neither negative or positive. Here is a snippit from that c
  7. Why just texting? I have a problem with shaving, putting on makup, eating, etc. We need a clause for these too! If it wasn't so sad I'd be laughing my butt off.
  8. I delved into an issue that I have not been able to come to any resolution. There seems to be two distinct camps when I talk to others about it. The issue revolves around the use of subcontractors on a T&M (or LH) task order issued against a multiple award, indefinite delivery indefinite quantity (MA/IDIQ) contract such as a MAC or GWAC. The underlying contract has established labor categories and fully loaded ceiling rates to be used on T&M and LH task orders. First, let?s start with the FAR: 16.601 Time-and-materials contracts. (a) Definitions for the purposes of Time-and-Mate
  9. Quick question for you guys. Do any of you have experience with or know of Agencies paying for the costs associated with NCMA certifications for employees? Said another way, can agencies do this?
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