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About here_2_help

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    Contributing Member
  • Birthday 12/17/1960

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    No special interests, really. Kind of a jack-of-all-trades/master-of-none kind of person.

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  1. Neil/Joel, I wonder if you are missing a nuance in the original post. It doesn't say that the prime is buying commercial items. It says that the prime is buying goods and services using "commercial terms and conditions." I may be reading too much into that phrase, but to me it says that the prime has a standard set of Ts & Cs that it uses when acquiring goods and services that are not subcontracts (meaning not in direct performance of a prime contract SOW). This is very common in industry. The General is asking whether those standard Ts & Cs can be used when acquiring goods and services that are qualifying subcontracts (meaning that they are in direct performance of a prime contract SOW) when the prime contract is not for acquisition of commercial items. If my interpretation is correct, then I believe my answer was also correct.
  2. The prime can award a subcontract using any type and terms it wishes to, so long as the prime's mandatory flow-down clauses are included in the subcontract.
  3. Joel, my point of view is that the government unilaterally changed the contract when it required the contractor to do more than was stipulated in the contract.
  4. Indeed. Who reviewed the proposal prior to submission? Do you have a Delegation of Authority matrix in place? Also, if the company is harmed then you may have a basis to take further legal action against the former employee.
  5. Agree that the DSSR is not automatically incorporated. Disagree with the interpretation of 31.205-46. In my reading, DSSR lodging and per diem rates apply ONLY IF there is no FTR or JTR coverage. Thus, first look to FTR and JTR for coverage. If there is no coverage, then (and only then) look to DSSR.
  6. Hi

    You wrote a comment about DSSR being in the Contract.

    I would appreciate if you could tell me how the various DSSR Allowances get on Contract.  Is it assumed or is it a Section H Special Instruction

    hank You


  7. I don't know your circumstances or whether you are subject to CAS; however, I like the result of the change!
  8. 1. Hire a knowledgeable attorney to advise you. 2. If the government does not give you a formal accept/reject decision within 60 days, file a claim.
  9. Don't your in-country operating locations have their own indirect costs? Charge 'em there; but not as direct costs of the contracts they are performing.
  10. Joel, Perhaps you missed the point of my post, which was not about brake jobs or the type of car one drove. It was about commercial item contracting. In my experience it is often overlooked that the government is required to acquire commercial items IAW the terms of the marketplace. I extended that requirement to post-award administration requirements.
  11. Joel, This is a commercial item contract so I doubt there were many performance specifications. We might wonder what qualified the services to be considered a commercial item, but that was an a priori condition associated with the original question.
  12. Joel, normally I would agree with you. But in the commercial marketplace, shouldn't standard industry practices prevail? For example, if my auto mechanic tells me I need to replace my brakes and that it's an extra $800 over the initial estimate, my verbal okay is typically acceptable. Thus, to me, the questions are (1) what changed and (2) how does the marketplace typically deal with those changes.
  13. It's interesting to me that a contractor would make job offers contingent upon receiving a successful clearance. That process could, and often does, take many months to complete. During that time, what is the potential employee doing? Searching for another job at another company, I hope. Alternate courses of action, for consideration: 1. Post job offers that require an active clearance. Anybody without an active clearance is rejected as not meeting requirements. 2. Hire people who don't have clearances, with the understanding that if they don't receive a clearance, they will be moved to another position that doesn't require a clearance or terminated. What do they do in the meantime (while waiting for the clearance)? Perhaps there are some other tasks that need to be done. Perhaps they can receive training to prepare them for successful execution of their job duties when the clearance is received. Maybe hand them a broom or a mop and tell them to clean offices. The point is, put them to work and receive benefit. Yes, the clearance process is expensive but it's also a routine cost of doing business. Normally, it's an indirect cost because it's so prevalent.
  14. All that may be true, but does your G&A function really spend all that much time managing travel? Remember, G&A expenses are those that benefit the entire business unit as a whole. Certainly, the accounting function may be in G&A but also I would expect to see (without knowing your company) the costs of executive management, B&P expenses, IR&D expenses, and other central payments. Given all that, do you still maintain that managing travel is a significant portion of how G&A functions spend their time? If so, wow. You are essentially describing a travel agency.
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