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leo1102

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Everything posted by leo1102

  1. "Otherwise one could issue a task order with a base period of one year and 40 one year options. : )" This statement may not be accurate across the Federal acquisition landscape. In DOD, knowledge based service aquisitions can not exceed 3 years and non-knowledge based service or supply (material) acquisitions can not exceed 5 years (base and options included). This applies to orders under the GSA FSS schedule, open-market and sole source requirements. Please check with your agency guidelines.
  2. Is the contract FFP or Cost-Reimbursement? Work with your Contractor and do a bi-lateral modification to the contract. If the services required to be performed under the contract require the contracted employee to obtain certain training or maintain certain credentials, then that is the responsibility of the Contractor. Since this training was unanticipated at the start of this contract and since it is within-scope, then modify the PWS, and negotiate a price instructing the Contractor not to exceed the JTR reimbursement rates. The Contractor is well within his right to negotiate G&A and
  3. As a GPC Card Holder I have a follow-up question: Is each toll charge billed separately or is it all billed monthly together on the same invoice? If the sum of all tolls are billed on a single invoice and if that invoice is recurring on a monthly basis, then this is a recurring procurement and should not be paid using a GPC. The issue is the recurring nature of the charges, not the amount. You should look into entering into a BPA with the toll company.
  4. A warranted contracting officer obligates funding - even if that funding is being obligated between agencies. See OMB Guidance dated June 2008 regardig Interagency Acquisitions. If you are in the DoD, please see the DoD Financial Management Regulation 7000.14R, 11a_03 and DoD Instruction 4000-19 dated 9 Aug 95. Also, see FAR Part 17.504(d)(3) - statutory authority for contractual actions - a contracting officer has statutory authority up to their warrant amount. If you are interested more in IAs, send me an e-mail separately and I can send you what I have.
  5. The contractor is required to invoice IAW the contract CLINS and instructions in the Contract. Unless the contract specifically states that the Contractor is required to provide supporting documentation for each submitted invoice, he/she is not required to do so. Do you trust the COR to work within his appointment instructions? From my experience - KOs to not get involved with accepting or rejecting invoices - that is the job of the receiving authority or COR. If you have no proof of fraud, why are thinking there may be some?
  6. SBs are not required to submit a SB Subcontracting plan. See 52.219-9(a).
  7. Under a FFP contract, the contractor is owed all monies obligated under that contract. However, there are instances where the contractor invoices for less and the money can be deobligated in a bi-lateral modification. My suggestion is if the contractor has submitted his final invoice, and once that invoice is paid, issue a bilateral modification to deobligate remaining funds prior to closeout.
  8. You can take graduate degree courses from American Graduate University or Websters or other DAU affiliated schools and earn CLPs
  9. Assuming the inside safety lock is engaged - First - Don't respond to the knocking. Second - Call the front desk and get security. Third - Don't open the door. Fourth - Don't answer the phone. They teach us this in our antiterrorism training on an annual basis.
  10. Trenches aside, I like doing the day to day work. I am a retired US Army SFC - that may explain why I enjoy actually working for a living (a joke people!!). I have moved around - perhaps not as much as some but I have worked at several different offices learning much from each. Funny you mentioned Patton and 3d Army - I was in 3d Army 1990 - 1993 (yep - Desert Shield/Desert Storm). BTW - I'm not a "he". While I have had to document my contract files on several occasions when I did not agree with a KO, I will not do so here. The entire back and forth is in e-mail traffic. After yesterd
  11. Vern and Don - Absolutely correct in both of your responses. Frustration is often the product of the slow and encumbered process when various levels of review and application weigh in. What get's me riled up is that if, as of 29 Jun 12, we are not incorporating those provisions and procedures into our solicitations as applicable, we are in violation of the DFAR, and will be so assessed when we are inspected. I don't think I will ever be in charge that high up the acquisition chain - nor do think I want to be. I like being in the trenches doing the work, dealing with people and issues.
  12. I pulled the final rule from the Federal Register on 29 Jun 12 and furnished it to my supervisory contracting officers asking if we should implement it by adding the provisions IAW the prescriptions. I was told emphatically that until our HQ told us what to do, that we were not to take any action prescribed in the final rule. I find this amazing. The final rule is a final rule - the DFARS has been updated. We are a DoD agency. Now we have to wait until our HQ tells us to do what the DFAR update already tells us to do and until then, we are operating without the directions prescribed by the new
  13. I pulled the final rule from the Federal Register on 29 Jun 12 and furnished it to my supervisory contracting officers asking if we should implement it by adding the provisions IAW the prescriptions. I was told emphatically that until our HQ told us what to do, that we were not to take any action prescribed in the final rule. I find this amazing. The final rule is a final rule - the DFARS has been updated. We are a DoD agency. Now we have to wait until our HQ tells us to do what the DFAR update already tells us to do and until then, we are operating without the directions prescribed by t
  14. Are you referring to FAR Clause 52.222-41 or 42 or 43? Try checking the wording of these clauses and their perscriptions in FAR Part 22.1006? Then make a determination whether to flow them down or not. I would flow them down whether mandatory or not. David-Bacon Wage Rates cover construction, not SCA.
  15. Thank you all for your input. Yes - we at USACE have to pay DCAA for audits. That is one of the reasons we were looking at contracting it out. The contractor has filed numerous claims against the contract - that is why we are requesting an audit. I agree - no clause is required. I love this forum - so much info to consider.
  16. Thanks to all. We are not looking to audit a proposal - we are looking for an audit on a FFP construction contract.
  17. Have you contacted your directorate of information management or your contracting office or your installation management office? The utility companies may have a monopoly on your installation (like a single phone, cable, electricity, or water provider).
  18. Does "No separate contract audit organization independent of DCAA shall be established in the Department of Defense" mean that we can not contract with a commercial entity in support of USACE DoD. We are not creating an audit organization "in the DoD". We are considering contracting with a commercial entity to provide contract audit services. I found the same info you all did - I find it ambiguous at best. I am unable to locate a clear answer to whether we can contract out audit services or not. Unless, of course, I am not reading the material as it is meant to be read.
  19. Most contractors have their Reps and Certs in ORCA.
  20. We are not negotiating a new contract - we already have the FFP construction contract. I was wondering if we require a waiver from DCAA to get an outside agency to do an audit.
  21. BLUF: Can we contract with a private company to perform an audit on a FFP construction contract greater than $10M? We (USACE - DOD) have a FFP construction contract greater than $10M on which we want an audit performed. We requested an audit from DCAA on 11 Jun 2010. We received a Risk Assessment working paper B on 31 May 2011. We received nothing else. The DCAA website states that they "shall perform all necessary contract audits for the DOD". Do we need a waiver to contract out the audit and, if so, what is the process for requesting one? Thanks.
  22. Nathan - Welcome to the fold. A wise man (smile) once put these to items on WIFCON and they are posted at my desk as a constant reminder - not sure they are still on here so I will post them again with much respect for the author: Here are some of the traits that I think makes for an "effective" KO, which is a minimal standard. (I have higher standards for expert, excellent, superb, brilliant, etc.) Vernon Edwards, 29 Jan 11 1. Pride in competence, but not in title or position. 2. Deep knowledge of the rules. That means mastery of the regulations that govern the specific work that you do.
  23. I agree with everything said so far. I would like to add that there is a BIG difference contracting at military installation levels, at higher HQ levels, at civilian agencies, etc. There is a difference contracting for supplies or services or construction or R&D or A&E. There is a difference contracting using 1 year funds, 5 year funds and non-expiring funds. There is a difference between working pre-award and post-award administration. Talk to people. Get a feel for the type of contracting at each agency at each level and determine your interest. Remember - 1102 is a very mobil
  24. MATOC is often used for services. We have at least 6 MATOCs here for services ranging from materials testing services to cultural resources services to repair services to meeting facilitation services. We also have several for construction and dredging. MATOCs for services is common.
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