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here_2_help

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About here_2_help

  • 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. Why do you believe that your subcontract type has to match your TO contract type? Can you point me to the regulation or instruction that requires that?
  2. I'm not a government employee, so likely my opinion is irrelevant. That said, I've always mistrusted skills testing. It's hard to identify exactly which skills are critical to job success, and then creating a fair and consistent test is difficult. Sure, you can have somebody create Excel pivot tables in front of you, but how do you evaluate analysis of the information thus provided? As I typed, it's difficult. I think I posted a few days ago that when I started hiring for character attributes, such as curiosity, things changed in my department. I can teach to those willing to learn, and I can let those willing to read and think teach themselves. Those are the people I'm hiring for. So this approach doesn't strike me as the great innovation that's going to fix the government acquisition workforce.
  3. I read a good part of that particular decision, and found it to be depressing.
  4. You have several options available to you. Off the top of my head, you can -- 1. Call the possible subcontractors and see if they are interested in submitting a proposal in response to your RFP. If yes, obtain a point of contact. Send the RFP to that PoC. 2. Send an email to the CEO or President or whatever PoC you have for each potential subcontractor, inviting a show of interest in bidding. Upon receipt of a show of interest, send the RFP. Reminder: you're not the government. You don't need to solicit all sources - you only need to solicit more than one. But the better practice is to solicit as many potentially responsive bidders as you can.
  5. I don't understand how receipts for expenses in excess of $75 relate to the application of G&A on travel expenses. Receipts are support for claimed expenses, while G&A is an indirect rate that is billed on invoices. Can you please help me to understand how the two things are connected in your mind?
  6. It's hard to hire people with the specialized knowledge I need (contracts + accounting + FAR + CAS, essentially). A couple of years ago, we stopped worrying about specialized knowledge and started hiring for certain mental attributes--foremost among them: curiosity. One candidate, while walking to the office for her interview, noticed the unusual carpeting in the hallway (it was truly unusual and there's an interesting story behind it). She asked, "What's the deal with this carpeting? Was is specially ordered? Why?" After a brief interview to confirm her experience and that she was willing to read in order to fill her knowledge gaps, she received a job offer that same day. Since we started the practice of hiring curious people, we have been astounded at how the department has changed!
  7. I've always found that the best approach is to make my work product as close to perfect as I can get it, prior to review by another. Do I always meet expectations in that regard? No. But I strive for it.
  8. Luke, I don't especially want to pick a fight with you. But you have at least two errors in your post, quoted above. 1. Billing rates are defined in the FAR at 52.216-7, as others have already pointed out. The clause does not permit contractors to bill at a single rate. If you're thinking T&M contract type, then maybe. But never cost-type contracts. You can also use a wrap rate for ROM estimates, but not for FAR 15 proposals where cost analysis will be performed. 2. In manufacturing, it has been traditional to use a DL $ base. But in the 21st century, automation is taking over and the percentage of touch labor in the average factory is declining. Thus, the connection between touch labor hours/dollars and indirect factory expenses is becoming more tenuous by the year. At this point, it makes as much sense (if not more sense) to use a machine usage hour base. Continuing to use a DL $ base tends to result in Manufacturing Overhead rates that are well north of 100%; I saw a 400% rate once. It's not wrong, but it's not right either. A decent Activity Cost analysis should be performed to figure out what costs are driving factory activity. At many places it is no longer touch labor costs.
  9. I saw this! Lesson to be Learned: When low-balling FFP or FPI contracts, don't misestimate the amount of your investment in the program.
  10. Don't know the agency but the following pertains to DOD. Normally, when the DCAA does not perform an audit because it deems the contractor's final billing rate proposal to be low risk, it generates a Memo which is sent to the Contracting Officer and retained in DCAA files. At that point, it is up to the CO to establish final billing rates, which may be done either by accepting the contractor's proposed rates as submitted, or by negotiating with the contractor. (Typically, it's the former.) If the contractor submitted its proposed final billing rates timely and -- for whatever reason -- no audit was performed and no Memo to File generated by DCAA then, as Neil pointed out, there is an opportunity to negotiate final billing rates. If the amount of "unsettled" indirect dollars is judged to be low (either within FAR limits or within limits established by the DCMA Class Deviation to those FAR limits), then the CO can close out the contract at either provisional billing rates or the contractor's submitted/certified final billing rates. Edited to add that recent NDAA language requires DCAA to issue its audit report within one year of the contractor's submission. If that doesn't happen, the contractor's rates should be accepted as proposed.
  11. LuketheNuke -- per the OP, provisional [billing] rates have already been established. That's not what the OP wants to know.
  12. Vern pulls no punches. One of the problems is that the "system" rewards adherence to the sub-optimal status quo, while at the same time punishing those few creative thinkers who seek to break the paradigm. There are few, if any, consequences for incompetence ... except those consequences felt by the citizens. Thanks for writing this and giving Bob permission to post it here, Vern.
  13. I honestly believe you have just described most of what is wrong with government acquisition in one post.
  14. Yes to all your points. So ... initiating Information Collection to assess the industry burden (at least with respect to CAS) is just creating one more burden for industry. That was kind of my original point. It's a pointless task that creates work but does not lead to any significant work reductions. Somehow I'm not sure that was the original intent.
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