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About here_2_help

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  • 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. Meanwhile. the heirs of von Steuben at the DoD OIG focus their attention on blaming contracting officers for not dispositioning DCAA audit reports quickly enough.
  2. "A committee is a life form with six or more legs and no brain." -- Robert Heinlein
  3. Thanks for this ... just went to the site to do some research and found it was down. Glad to see it's not just me.
  4. With some justification. 1. SECDEF Gate's initiative to enhance "efficiency" by reducing bloated Pentagon back-office bureaucracy. WaPo broke the story of what happened to that. (Spoiler: Nothing much.) 2. USD (AT&L) Report (Sept. 19, 2015) discussing progress on five years of efforts to roll-back regulatory burdens imposed on contractors. (Spoiler: Nothing much. And that's being generous.) 3. Pages 89-90 of that report identified a real opportunity to reform submission of (certified) cost or pricing data: " DoD should clarify policy guidance to reduce repeated submissions of CoP data. Multiple submissions are an unintended, and generally unsought, consequence of the FAR requirement that certified CoP data be ‘current.’ Frequent resubmissions appear to be the result of contractors’ fears that out of date CoP data that becomes inaccurate will lead to defective pricing claims by DoD post-award. However, lack of clarity on what is considered ‘current’ motivates some contractors to provide excessively frequent CoP data updates during negotiations (weekly or monthly), which creates unnecessary work not only for contractors, but also for the Procuring Contracting Officer (PCO). We recommend amending DFARS (and/or the FAR) to remove uncertainty about the appropriate frequency of providing certifiable CoP data to ensure it remains ‘current’ and/or to clarify pricing changes that warrant resubmission of CoP data. … Reducing unnecessary resubmissions of certifiable CoP data would lower contractor proposal costs and reduce procurement administrative lead time. Making this change also weakens the argument for making additional changes to the TINA statute, such as increasing thresholds or relaxing waiver criteria." What happened to that agreed-upon reform? It evolved into a DFARS Case (2015-D030) that would revise 215.407-1 (not FAR 15.407-1(c) as the study recommended) to: "stipulate that DoD contracting officers shall request a limited-scope audit, unless a full-scope audit is appropriate for the circumstances, in the interest of promoting voluntary contractor disclosure of defective pricing identified by the contractor after contract award." The final rule is currently being drafted, and will likely be touted as some kind of regulatory reform. To be fair it is "some kind" of reform; just not the kind we need. Seriously Joel, despite your anecdotes to the contrary, the overwhelming evidence of the past 40 years is that DoD is unable to stop itself from burdening its contractors with excessive regulations. Sure some of this (much of it?) is driven by statute--but not all. Even when DoD tries to roll the regulations back, certain constituencies within DoD go into battle on the regulations' behalf. Which is all fine for me, since I make my living parsing through the morass of moribund rules. But it's not so fine for the taxpayers who have to foot the bills.
  5. Reminds me of the time where I was auditing / reviewing contract briefs and it turns out all the mods had been signed by the VP's Admin. Unread. She didn't want to bother the VP with administrative stuff that wasted his time. That contractor is no longer in business. Coincidence? Not really.
  6. Another attempt at humor! It assumes that the contractor actually read the modification, other than the funding line.
  7. The question is too imprecise to answer. Direct labor rates and indirect rates used to establish firm, fixed-price contract values? T&M Hourly Billing Rates? Indirect rates used to establish estimated costs/target costs? Provisional billing rates used for monthly vouchers? Final billing rates established after audit? Yes, no, maybe so. What is the question?
  8. I feel like there's more to this story. Companies just don't reject business for no good reason. From the subK's point of view, there is a reason why the PO is being rejected. The prime should seek to understand that reason and, perhaps, make changes as a result of what it learns.
  9. I disagree that "any" cost can be charged to a cost type contract. The rules for charging contracts don't change depending on contract type. The same labor hours/dollars that would be charged to a T&M contract would also be charged to a cost-type contract. With respect to your comment about fee, I may not be understanding your point. To my way of thinking. if you add scope to a T&M contract then you have to raise the NTE value, which permits more hours to be billed. Those hours contain a profit component. More hours = more profit. On a cost-type contract you (generally) have a fixed fee; if you add scope then you may need to add more fee (or not, depending on what's negotiated). I must be missing your point because the two situations seem generally equivalent to me.
  10. Crowell & Moring, a law firm noted for its government contracting expertise
  11. I just read a C&M email that said the new administration was putting a hold on all in-process regulatory changes, pending review. (This is, I'm told, a "normal" thing.) Connection or coincidence?
  12. Did we ever establish what a "complex" contract was?
  13. Thanks all. (Probably should have posted this under the Beginner's section, since that's the level I'm operating at.) You responses are very much appreciated and helped me to understand.
  14. Thanks Bob! Contract Award Dollar Amount: $0.00 Base IDIQ Award; Ceiling Amount $580.2 Million Now I am about the least experienced contracts person here. I could be way off base and, if so, I expect to be enlightened. That being said, I am having a hard time distinguishing a "$0.00 Base IDIQ Award" from a BOA. Can somebody help me to see the difference?
  15. Matthew, My only "source" is the announcement I quoted in full. It says that a $580M FFP contract was awarded and "funding will be determined with each order." Further, it makes not mention of use or expiration of current year funds. Now I may be reading too much into this, but taken together I conclude that zero funding has been appropriated. Since we know that an ID/IQ contract requires a minimum quantity and that the funding for the minimum quantity must be obligated at the time of award, I am curious about the situation. As a taxpayer, if for no other reason. Your explanation makes sense. However, it fails to inspire me with confidence regarding the contract administration of this highly visible procurement.