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Everything posted by styrene

  1. A lot of it has to do with the work, severable vs. non-severable, in addition to the type of funding that is used (annual appropriations vs no year / multiple year funding). It would be nice to be able to use up all the funding as obligated before digging into the next pot, however, appropriation law seems to get in the way.
  2. Question: When there is a table of contents in a contract, wouldn't that need updating if the contract is modified? That may be easy if there is a systematic way to generate solicitations and contracts. I don't see why folks are not following the guidance in the FAR when it comes to setting up contracts (UCF vs commercial); one would not really need a ToC in those cases.
  3. Question: Is anyone hearing that their agency wants to incorporate the clause into actions valued at less than the SAT or in actions that are not included as part of the EO? If so, what are your opinions on this idea?
  4. A suggestion is to establish ALTs (Acquisition Lead Times) for your various types of actions. Your SLA will be a % of the established ALTs that were met. You do not want your program office to dictate how long it should take to complete an acquisition. Example: An ALT for a Unilateral Modification is 30 days. The SLA would be meeting the ALT 90% of the time. Also, ALTs also includes the times for program to perform their responsibilities of the acquisition process; there should be the ability to document excess time taken by program (or other situations outside of the COs control) so as not jeopardize the contracting office from missing the ALT and negatively impacting the SLA.
  5. 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements, and, we are not using Part 8.
  6. I am looking for clear directions as to what category a notice should be placed under when posting on Beta.SAM.gov (FBO). I have searched the FBO site and found only a brief description as to the categories and the types of notices that should be placed under each one https://www.fsd.gov/gsafsd_sp?id=gsafsd_kb_articles&sys_id=80e5f8211b5e601005f9a93ce54bcba4 I found the Air Force FAR (Part 5) Supplement that has the details I need; however, my organization is not under the AF or even DoD. In particular, I am looking for guidance / supporting documentation that talks to the placement of "Notice of Intent to Sole-Source". I know that these types of notices do not belong under "Special Notices". While I can logically show, based on the two documents, that the notice does not belong under "Special Notices", I prefer to be able to provide clear and convincing information to support my assertions. Sadly, reasoning and logic these days tend to be countered with "the FAR doesn't say you cannot do that" or "Contracting Officer's discretion" and I would rather not deal with my head exploding. IIRC, I want to say that an instructor in one of my classes mentioned there was a sustained protest in which the notice of intent to sole source was placed under "special notices" or some other incorrect category, and a company protested that by placing the notice under the incorrect category, they did not see it and did not have an opportunity respond. I searched the Google and the GAO site with many combinations of key words and came up empty. Perhaps someone here knows the case to which I am referring. Thanks in advance for any enlightenment one can share.
  7. Our COs have full workloads in addition to reviewing and signing for junior folks. (HHS)
  8. We use options on our BPA orders all the time. If the work is the same, and it's a known need, and the work can be priced out as an option, then why not take advantage of that instead of going through a longer process (and more expense) to request a quote/proposal, evaluate, document, and award? What is your concern about the options? That the vendor will not perform? How would issuing a separate order to the same vendor for the same work overcome your concerns?
  9. Forgoing the FAR research for now, questions such as is your company a small business, and was the competition a small business set-aside would be helpful? If so, there may limitation of subcontracting issues. What type of contract is it? What type of service is the contract providing? The fact that the CO is directing you to subcontract out positions, could be indicative of a personal services type arrangement that the federal agency may or may not have the authority to pursue. You are responsible, as the Prime, to perform the work as you see fit. There should not be a Government person directing you to hire from a subcontractor, unless whatever work the subcontractor is doing is specifically called out for the subcontractor to perform. That's my stream of consciousness for now.
  10. It is refreshing to hear someone interested in learning their craft as opposed to wanting to run up the grade pole as fast as possible. My suggestion is to take the DoD position, learn and experience all you can, and get your Level 3 certification. Once you feel you have reached a level of experience you are comfortable with, and if there are no promotion opportunities where you are, then consider moving to a civilian agency to finish the climb. My experience with DoD (I left 12 years ago, after 20+ years in) is that the grades were about 1 grade lower than what one can get in the civilian world (I'm in the DC area) for comparable work and responsibility. Good luck!
  11. "Mine can't do any of that. I never thought I'd long for PD2" Word! Been saying that since I left DoD over 12 years ago.
  12. I am under the impression that consideration for modifications (NCEs, for example) apply to Fixed Price type contracts, As Cost/T&M type contracts are considered "best efforts", consideration would not be needed. Have I been operating under an urban legend?
  13. Do the "Instructions to Offerors" mention how to set up the proposal? (I know, if they did you probably would not be asking. If there is a concern, sounds like a question to the Contracting Officer should be sent.)
  14. There is no minimum guarantee in a requirements contract. Instead, the "consideration" is that all specified (recurring) work will be given to that vendor for a period of time, so one advantage of a requirements contract is that there is no need to obligate funds at time of award to cover the minimum. In fact, there is no need to order anything. Under a requirements contract, the Government is pretty much on the hook to get their goods/services from the vendor for a specified period. There may be a "maximum" amount established in which the Government is tied to order from the Vendor, after which the Government could go elsewhere. Under an IDIQ, the Government needs to guarantee a minimum (and obligate that amount at time of award), but is not necessarily tied to that vendor beyond the minimum.
  15. When a COR was not appointed, two titles I would come across were PATR (Procuring Activity Technical Representative) (DoD) and TPOC (Technical Point of Contact).(non-DoD).
  16. I don't think it's the cliquish issue. It's more a matter of how the statement of work being defined and if there are "restrictive" requirements that are being allowed to remain in the statement of work. Stating "at least 29 FTE" could be program's way of saying that this is amount needed to perform the work; however, is the work described with such sufficiency that the offerors could come to their own conclusions as to the number of FTEs? As far as felons go, that could impact obtaining a clearance to work on the Government site. The determination of appropriate security clearances are not set buy the buyers; they are set by the program in conjunction with the security office. In some cases, elimination of a vendor on the basis of past performance may require coordination with the SBA (see FAR 19.6). I have seen program try to place a "radius proximity" requirement in order to get to who they want. However, once they have been questioned on the requirement (why so far, why not apply a period of time to reach them or the vendor to reach the Government, and then explain why it is so time sensitive) they will usually make the requirement more competitive. As a CO/CS we need to support the program, but we also need to follow the guidelines with which we are faced. It's okay to question the requirements as long as one has a valid reason for doing so, and, hopefully, a useful suggestion for something different.
  17. When my agency evaluates past performance in proposals, we use PPIRS data to evaluate performance risk: usually High, Medium, or Low performance risk. I have heard that some agencies are actually giving a "score" (adjectival or numerical) based on the PPIRS data when evaluating past performance in a source selection. Knowing that the quality of the past performance data in PPIRS is by no means standard, I would find it difficult at best to downgrade vendors who received less than an excellent rating, and I think I would have a hard time supporting that evaluation score if the vendor protests. Thoughts? . Anyone here actually "scoring" Past Performance instead of using it as a risk indicator? Thanks for your input!
  18. "My laptops should have the 6th Gen Intel Core i7 Processor " Please provide a brand name justification for this requirement or provide the salient characteristics as to what would be an acceptable equivalent.
  19. There is the DoD Small Business Innovative Research program, which issues a single solicitation that represents the various DoD Services, and once successful offerors are determined, technically, the proposals are forwarded to the various agencies for negotiation and award.
  20. It's not like the PM gave them the statement of work and told them how much money was available for the job! Gee-whizz guys, you are strict!
  21. Am I understanding correctly that DCAA is using the wage determination rates as the basis for reasonableness of the rates? Oy! Is that coming from the Supervisory Auditor in the office?
  22. From FAR 22.1001, Definitions: “Wage determination” means a determination of minimum wages or fringe benefits made under 41 U.S.C. 6703 or 6707© applicable to the employment in a given locality of one or more classes of service employees. It's a minimum and shouldn't require any approval to exceed the rates set forth within.
  23. I don't think it has to do with the unit rates. Was the overall price/cost associated with the 6 months of additional service taken into consideration as part of the evaluation?
  24. JMJ definitely has a point. There is a definite lack of critical thinking when approaching an issue. In fact, there is a general lack questioning when things clearly don't make sense. Then, there are the apathetic folks who seem to think that proper clause selection and following the FAR are just suggestions and don't really matter. Has anyone taken (or can recommend) a good critical thinking class that requires folks to use their problem solving / analyzing skills?
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