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contractor2589

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  1. Wow. Ok. Thanks. So technically a company could get awarded a GSA MAS contract, become a large business the next day, then 4.9 years later get awarded a 5-year SBSA BPA under that MAS contract.
  2. I have looked but could not find a discussion on this, so any info or redirect to a previous topic would be helpful. My question: If a contractor is awarded a GSA MAS contract (for example, something under FSS "OOCORP") when the contractor is a small business, but then grows to exceed the size standard for a particular NAICS, can the contractor continue to compete for small business set-aside work or BPAs issued under that FSS within that particular NAICS until its GSA contract expires? In other words, if a small business set-aside BPA is competed under GSA FSS 00CORP, can a firm that does not meet the size standard compete as prime contractor if the contractor's GSA contract was awarded when the contractor was still a small business for that NAICS? Thanks in advance.
  3. Thanks, all. FYI, the only mention of these add-on items was that one bulleted line in the evaluation criteria ""Special features, such as systems or software, for effective program performance." Anyway, they cancelled the procurement action so I'm moving on. Thanks again.
  4. The evaluation criteria is based on best value with one of the criteria being "Special features, such as systems or software, for effective program performance." The scope does not refer to any such features or systems or tools, and nothing like that is necessary for the work itself. I"m concerned that they already have someone in mind and already know they will provide some add-on feature that they like, and I'm wondering if its legit to say, effectively, that "if you have some other whiz bang thing you can throw in, that would be great too." We have offered such things in previous proposals and had COs tell us they can't evaluate based on items not required by the scope, but here they are alluding to something but being rather coy about it. Makes me feel like I need to dream up something extra to offer them.
  5. I realize that proposals for professional services generally include a technical approach, and innovative approaches are valued, but what if my innovative approach involves delivering, say, a custom software piece that is not required by the scope? Is this me being innovative, or are there prohibitions on evaluating proposals based on "value add" items like that? (I recall there is a restriction here, but my searching the web and this forum has not turned it up. Apologies if this is old turf.)
  6. So, perhaps I should ask in the transmittal letter of our proposal or somewhere that we be allowed to respond to any past performance information that is anything less than exceptional. To say, "please let us explain if you hear bad stuff" sounds terrible.
  7. Makes sense to me. If there were some sort of restriction, I just wanted to know about it. This solicitation is wired for a competitor, so I was just hoping to move the evaluation to something more quantitative. Thanks all.
  8. Are there any restrictions or requirements on how Past Performance is used as an evaluation criteria? We are faced with a solicitation that includes Past Performance as one of the two primary evaluation criteria. The agency states that this evaluation will not be based on the information/references we provide in our proposal, or any kind of quantitative analysis, but rather "subjective judgment" of all available and relevant information the agency can find. This seems like a huge variable that would allow the agency to validate nearly any best value judgment it makes. Frankly, I doubt there is any restriction on including an evaluation criteria like this, but if there are, I would really like to know about them as this solicitation is wired for a particular contractor and this variable is troubling.)
  9. You're advice is worth a lot, actually. I really appreciate the input that CAS does not represent "best" or "core" practices. That probably reflects a misunderstanding on my part, and certainly tells me that more investigation is warranted. I guess I viewed the situation as "we'll eventually have to meet all of CAS, so I might as well accept it when we get pulled that way on various fronts." I will tell you that our "audits" seem to be rather qualitative on many points, with a lot of loose references to requirements. Even when we ask for specific references to requirements, we get vague answers relating to our ability to demonstrate various types of costs or allocations. We are reluctant to enlist our $185/hr outside accountants for every little thing, or to be viewed as non-cooperative, so we generally play along. Thanks everyone!
  10. Carl: Thanks. I like how all of that reads. ODCs must be authorized by the ordering agency, not subject to IFF, profit/fee frowned upon, subject to the contractor's accounting system, etc. That's all seems like a reasonable approach, and it makes sense to me. here_2_help: We're not subject to CAS yet, and I appreciate (and found interesting) your commentary on what the CAS is really about. We don't meet all of the requirements of CAS, because it's not worth it until we have to, BUT, we are held to the core practices because we hold Federal cost reimbursable contracts. Based on those contracts, we undergo audits from both DCAA and Financial Management Reviews (FMRs) from client agencies. These audits address all of our accounting practices, not just cost accounting associated with those reimbursable contracts. They do this, in part, to be sure we are making allocations evenly across all cost objectives (to be sure the cost reimbursable contract doesn't get more indirect loading than it should). They dig deeply into our indirect cost calculations, written allocation procedures, etc. To your other point, we push everything practical to overhead, and our G&A is competitive in our industry based on the surveys we have and what we see of our competitors. It's a good point, though, thanks.
  11. My general contracting commentary... When using noncost-reimbursable BPAs or IDIQs, we (the people) should be using multiple awards and competing each FFP task order whenever possible. These MATOC-type contracts eliminate the need for the Government to worry itself with how cost are calculated. We hold single-award IDIQ contracts, and it's great, but I would trade them and slug it out with my competitors in best value competitions rather than have to defend how we figure out how much a particular job will cost us. Competition among contractors is far more brutal than anything the agencies will ever come up with, and when managed, I really believe these free market forces effectively serves the public interest.
  12. Here_2_help: Yeah, I didn't mean I was done, so much as I didn't want to drag this out for others. Your points are good. We are small, but the CAS represents solid accounting strategies, we need to accurately calculate our costs (so we know how cheaply we can do a job), and we don't see the point in operating outside CAS just because we can. You also right about allocation strategies, and we are looking hard at switching our practice to "value added" allocations (for purposes other than described here). Alas, even under Value Add, though, we would allocate indirect costs to all ODCs (including travel). But, I think we all agree that if we make a change to our allocation strategy, it has to be company wide and consistent across the board. So when a particular client wants us to do it differently for them, it poses some challenges. I guess if all of our indirects were allocated only to labor (built into labor rates), that would resolve this, but then another agency would do it's cost comparisons only on labor rates and that would hurt us. Vern: I'm a huge fan of yours, and I think I fully understand your point on all this. It's a rather straightforward issue; I am primarily expressing why I don't like it. I'm neither confused or upset, but I may well have overstated a couple of points. Anyway, let me take another crack at a summary, based on what you point out. I'll try to be more careful. "The Government requires that we allocate G&A costs consistently across the company so that no cost reimbursable contract is paying more than its share. Our published and audited accounting practices state that we will use a Total Cost Input allocation method, which will allocate indirect costs to all ODCs, including travel. One prospective client, although not planning a cost reimbursable contract, doesn't want us to include indirect costs on travel in our FFP bids, so our options are to A) refuse to work for this client, take exception to this restriction in our proposal, C) change our allocation method across the company, D) allocate those costs, but write them off internally as a project loss, or E) allocate those costs, but instead of showing them in proposal/invoices, add those costs to labor or profit." If I've missed or misstated something there, I would like to know and would appreciate any input. I understand the client doesn't care if we allocate G&A or not, just that they not pay it. But for a company to actually accomodate this restriction ultimately means moving these (very real, hard dollar) costs to labor rates instead of spreading them over ODCs.
  13. I suppose I do understand, then: The Government requires (through DCAA audits triggered by other agencies) that we adhere to proper accounting practices and allocate G&A costs evenly to ODCs (including all travel costs) across all clients and contract, BUT this particular agency insists on controlling how we calculate our proposed costs by requiring that we eat the G&A costs associated with this work. I think we are simply seeing an attitude of either A) "G&A isn't a real cost" or "its a real cost and everyone EXCEPT ME should pay it." I can tell you that (at least at my small business) G&A sure feels like a real cost when I write checks for insurance, accounting software systems, website hosting, phone systems, accounting staff payroll, outside CPA and legal support, travel to Government trade shows, payroll for staff writing proposals, rent for our corporate office, corporate staff health insurance and annual leave, etc. (Please excuse the sarcasm here, but to illustrate...) Maybe instead of capping G&A, the agency could consider saying that "labor rates may not include overhead costs associated with office rent" (or copier charges, or electricity, or staff training, or employee health insurance). I think I'm done with this topic, and I sincerely appreciate all the input. I think we'll just increase our profit on labor to make up for the G&A loss in this case, but I really believe that the Government should try to find ways to promote open competition and stay out of trying to control internal cost-calculation methods.
  14. The more I think about this, it really seems like the philosophy, negotiating methods, and contracting language of cost reimbursable contracting (or maybe single award IDIQs) spilling over into FFP contracting. It only becomes an issue when competition is curtailed. I would rather see more multiple award contracts, so the Government doesn't have to worry about how companies determine the amount of money it will accept for a particular job.
  15. That's a good point. Any cap on indirect rates exerts control over accounting practices. I can tell you that internally, we would adhere to our established accounting practices, make the allocations, reduce profits, and cover the G&A out of profit. That's really the only way we could possibly do it. I guess we could increase proposed profit to cover this. From my perspective, when it comes to FFP work, it feels like meddling in how a private company comes up with its costs. What if we used a completely unorthodox system (our own terminology and some alternative cost tracking system)? What difference does it really make to any client other than the total cost (for FFP anyway). I understand the negotiating strategy of digging into the costs and picking them apart I suppose, but it seems that open competition handles that nicely for fixed price work. There is something else, though, which I didn't bring up. Aren't travel and other ODCs considered "open market items" under GSA FSSs? As I recall, GSA didn't resolve loading on ODCs very well in issuing FSS, but I'm certainly not up to speed on that. Here is an on-topic previous discussion. http://www.wifcon.com/discus/messages/8787/8669.html (After reading this previous discussion, I would just like to note that we are seeking to compete for this work and let the Government make a selection. I'm not "asking" for anything. In our case, we would probably not apply a fee/profit to the travel costs because I don't think our competitors do - we would allocate allowable G&A costs (like insurance, accounting, etc.) to all ODCs, including travel costs.)
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