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contractor2589

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About contractor2589

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  1. 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.
  2. 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.
  3. 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.)
  4. Subjective Past Performance Evaluation

    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.
  5. Subjective Past Performance Evaluation

    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.
  6. 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.)
  7. G&A Prohibited on Travel

    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!
  8. G&A Prohibited on Travel

    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.
  9. G&A Prohibited on Travel

    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.
  10. G&A Prohibited on Travel

    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.
  11. G&A Prohibited on Travel

    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.
  12. G&A Prohibited on Travel

    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.
  13. G&A Prohibited on Travel

    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.)
  14. G&A Prohibited on Travel

    1. They are indeed telling us how to keep our books. To my knowledge, there is no CAS G&A allocation strategy that allows us to be inconsistent in which costs get a G&A allocation. CAS 410-50(d) [48 CFR 9904.410]: The cost input base used to allocate the G&A expense pool shall include all significant elements of that cost input which represent the total activity of the business unit. The cost input base selected to represent the total activity of a business unit during a cost accounting period may be: total cost input; value-added cost input; or single element cost input. The determination of which cost input base best represents the total activity of a business unit must be judged on the basis of the circumstances of each business unit. (1) A total cost input base is generally acceptable as an appropriate measure of the total activity of a business unit. (2) Value-added cost input shall be used as an allocation base where inclusion of material and subcontract costs would significantly distort the allocation of the G&A expense pool in relation to the benefits received, and where costs other than direct labor are significant measures of total activity. A value-added cost input base is total cost input less material and subcontract costs. (3) A single element cost input base; e.g., direct labor hours or direct labor dollars, which represents the total activity of a business unit may be used to allocate the G&A expense pool where it produces equitable results. A single element base may not produce equitable results where other measures of activity are also significant in relation to total activity. A single element base is inappropriate where it is an insignificant part of the total cost of some of the final cost objectives. We have used Total Cost Input base for 10 years and we've been audited on it. If DCAA comes in here and finds that we are allocating our G&A pool inconsistently (not allocating to some costs), then there will be trouble. So, how is this scenario not dictating accounting practices? 2. I'm missing something I think. G&A on travel IS a loading, so they seem to care deeply about it. If they asked each firm what loading they would be placing on travel under the BPA, they could make comparisons and chose the best value, rather than just prohibiting it. 3. Sorry, I didn't mean "...not fair to us," I meant "...not fair to other client agencies" (who will then pay for those G&A dollars when they get allocated to them). (I've been in Federal contracting for about 19 years; I'm with you on whining.) 4. Right. You're (1) and (2) are certainly our options (both with the same result). I still say that that your (3) and (4) represent an inconsistent cost accounting approach that could get us in hot water with audit agencies.
  15. I am a contractor looking at a solicitation for professional services under a GSA FSS. The Government intends to establish a single BPA and issue FFP TOs. The solicitation states that invoices submitted under any resulting contract will reflect actual travel costs incurred (flights, lodging, POV travel, etc.). The solicitation also states that G&A will not be authorized on travel. I have a few questions: 1. Our Accounting system, like any established consulting firm I would think, defines how we allocate G&A, and that procedure is routinely scrutinized by DCAA and others. So, how can a particular solicitation dictate how we do things? 2. Why doesn't the agency just ask competitors how they load travel, and use that in the evaluation, rather than dictating accounting practices? 3. If we agree to waive G&A for travel cost on this contract, then our other reiumbursable contracts are going to get a larger allocation and pay a higher rate. That doesn't seem fair, although I don't thing the dollar amount will be noticable. 4. Any thought on how I might respond to the agency?
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