Jump to content
The Wifcon Forums and Blogs

jlbdca

Members
  • Content Count

    32
  • Joined

  • Last visited

Everything posted by jlbdca

  1. Multiple Award Schedule is a unique IDIQ that does not allow teaming to win the contract itself. Schedule holders necessarily have to add subs postaward, particularly those with subcontracting plans. GSA only cares about your supply when it's a product, where dealers and resellers need to evidence their relationships and sometimes must rely on pricing information from manufacturers in their own Schedule negotiations. To FormerFed's comment, a Schedule offeror need only disclose federal sales when there are no commercial sales. On a services offer, this goes labor category by la
  2. Also, being an SDVOSB is going to be a big help at the VA.
  3. You may map the sub's rates into your Schedule rates, establish a Schedule contractor teaming arrangement (CTA) whereby the other firm also has privity of contract with the government and uses its own Schedule rates (assuming they have a GSA Schedule), or add their labor as an ODC. On a FFP, I'm having a hard time seeing why sub lcats can't be mapped into the prime's.
  4. Contractors call a preaward agreement laying out how they intend to bid an opportunity a "teaming agreement." This agreement becomes input to a subcontract, usually at contract award. What a sub isn't going to see in FPDS is the prime's load on their portion of the deal. Every company I've worked for has attempted to hide markups from subs on FFP deals.
  5. Schedule orders of any size may be protested at GAO. Schedules 70, 84, others, allow for the purchase of solutions including both product and services; GWACs tend to be for one or the other. Schedule CTAs provide additional flexibility. The universe of MAS contract holders is much larger than any other contract.
  6. I have, on multiple occasions, negotiated GSA Schedule contracts using indirects and blended salary data, presenting a cost buildup to justify pricing. The company may have rung a bell now difficult to unring when it presented fully loaded most-favored-customer rates from a CPFF contract. Woulda, coulda, shoulda, but it would have been better to state on the CSP that there were no customers, including federal, from which fully loaded commercial rates could be devised, ie, T&M or FP-LOE. Instead, provide the cost buildup, and in the pricing narrative propose "all commercial customers"
  7. First, the Price Reduction Clause is a clause in your underlying schedule contract, not part of the False Claims Act. Two, it's not clear to me whether your question is around the disclosures on the CSP as part of a schedule proposal/modification or around compliance with an existing contract. The "similar situation" you describe deals with the former; I believe your question revolves around the latter. If the latter, you should receive your schedule contract, including FPR, to determine your basis of award (BOA customer). Sales to customers outside your basis of award will not trigg
  8. One of the customers listed on the CSP is your basis of award; this is the result of your negotiation. GSA tends to allow its contractor partners to believe they must offer GSA their "best price" (i.e., the most-favored customer and the basis of award customer must be the same), but this is not true. For example, why should GSA receive the same discount as a distributor who warehouses product and assists the offeror with marketing and sales?
  9. Sorry, regarding second question: You decide how to structure your disclosures to GSA on the CSP. Generally, you would strategize so your disclosures guide the negotiation. The basis of award is a customer or category of customers for purposes of the PRC. Ignore everything else you read about it. It may be your most-favored customer, or it may not.
  10. The PRC won't be generally be triggered by selling at a higher price than the Schedule price, although that depends on your discount relationship. Only sales within your basis of award can trigger the PRC, exclusive of any deviations.
  11. Presumably the OP meant basis of award, which is the customer or category of customers that triggers the price reductions clause.
  12. T&M requires a competent project manager on the client and contractor sides. Such contracts are routinely used successfully in the commercial sector. For the government, they reduce risk the contractor will understaff. There is different risk on both sides than FFP, which can be mitigated through skilled project management, and which I hope is a prereq on any engagement. That contractors need not receive acceptance for payment is a huge advantage to them.
  13. If you are asking specifically about Federal Supply Schedule CTAs, then yes, all members of the CTA must (1) hold an appropriate schedule contract and (2) be small on that contract. This has been true since set-asides were added to Part 8.4. You may be thinking of the backdoor set-asides contracting officers used to achieve by using size status as an eval factor, including the primary eval factor, in which case they could (and still can) specify all or only one member of the CTA be small.
  14. Agreed. My experience is GSA KOs will only allow a federal agency as BOA when the company has no commercial sales, and will typically stipulate that should the contractor gain a commercial client (including a federal prime), it must notify the KO and the BOA will change to commercial customers.
  15. A new CSP is generally not required if you can affirm the new product or service fits within the previous CSP, and the previous CSP is still valid. I'd explicitly state that in your mod. You do need to provide supporting material, such as invoices, etc., for the addition. Note also you're modding your contract; the price list is the catalog file that's uploaded to Advantage.
  16. The rules changed several years ago to require, for orders exceeding the SAT, posting on eBuy or distributing the RFQ to enough vendors to "reasonably ensure that quotes will be received from at least three contractors that can fulfill the requirements."
  17. I think you may be misunderstanding what FedRAMP is. FedRAMP allows for a provisional authority to operate (ATO) a cloud system federal-wide (I think up to medium), I believe based on NIST 800-53. It is not FISMA and has nothing to do with SLAs. If you don't know what I'm talking about I'd strongly recommend finding someone who can assist you in understanding.
  18. You can modify your GSA Schedule contract between option periods; in fact, if you do not have an automatic fixed escalation each year, it's the only way to modify your rates. See I-FSS-969.
  19. Prior to the change, GSA did set-aside an entire schedule (TAPS) and certain special item numbers on schedules for small business. I believe the belief that set-asides were not allowable on schedule orders was from the ordering procedures at 8.405: Request for Quotation procedures. The ordering activity must provide the Request for Quotation (RFQ), which includes the statement of work and evaluation criteria (e.g., experience and past performance), to schedule contractors that offer services that will meet the agency’s needs. The RFQ may be posted to GSA’s electronic RFQ system, e-Buy (see 8.
  20. Primes must comply with the Price Reduction Clause (PRC) in their contract; that is, they must ensure that they preserve the discount ratio negotiated based on their basis-of-award customer or customer category. I believe what here_2_help is referring to from the linked page is this: This means only that if the prime has triggered a price reduction, it must honor those reduced rates on all labor, including subcontractor.
  21. You are correct. So long as you can fit the subs' employees into your labor categories, you can use your Schedule and labor categories. See http://www.gsa.gov/portal/content/202257#3
  22. Yes, most-favored customer generally means lowest price. Examples of excluding primes from BOA: "Basis of award is commercial end users, excluding prime contractors." "Basis of award is national accounts" (so long as that account class excludes federal primes). Etc.
  23. BOA and MFC are often conflated, including by FAS. MFC: GSA's goal is most-favored customer pricing; that is, your lowest price without regard to terms and conditions or quantity. In negotiating the schedule contract, GSA will attempt to secure such pricing, based on your disclosures of your standard and nonstandard commercial sales practices. A separate part of that negotiation is the basis of award. GSA may attempt to use your most-favored customer as your basis of award, but this is not necessarily the case. GSA generally attempts to negotiate the broadest BOA possible, i.e., "all commercia
  24. The basis of award is the tracking customer or class of customers that is monitored for price reductions. You need to first know who it is. Scenario 1: Basis of award is all commercial customers. Scenario 2: Basis of award is federal primes Scenario 3: Basis of award is all non-state and local governments Etc.
  25. Who is the sub's BOA? GSA will generally not allow a federal agency to serve as basis of award, as the Price Reductions Clause states:
×
×
  • Create New...