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policyguy

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  1. I would suggest in addition to checking with DMCA legal, if you have not already, obtain and review the Letter of Offer and Acceptance (LOA) between the foreign county and the US. It may not indicate the contract type but I found it was an important document and always reviewed it when I worked FMS buys. I made sure a copy of the LOA was in the contract file.
  2. If I understand you correctly what you are seeking to do may be permissible. See FAR Subpart 1.4 - Deviations from the FAR, as well as your agency FAR supplement, and local supplement/guidance.
  3. Excellent article. Thanks for sharing/posting. Sadly I don't see improvement any time soon.
  4. The base contract has the term and conditions and the delivery order is the order and payment etc. If the base contract did not have the DPAS clause it could not be applied to the delivery order. Since this action is with DOD you can obtain information from the office that handles DPAS: The Deputy Assistant Secretary of Defense Industrial Policy - contact information is as follows: Deputy Assistant Secretary of Defense Industrial Policy 1400 Defense Pentagon, Room 3B854, Washington, DC 20301-1400 (703) 697-0051 osd.mibp.inquiries@mail.mil https://www.businessdefense.gov/
  5. It's my understanding that OMB OIRA grants approval for the information collection for three years. After that time the agency must obtain approval for the information collection and as part of the renewal process the 60 day & 30 day notices are used to validate the information collection especially what the agency believes is the burden on the public. It's my understanding that if there is no OMB OIRA approval for the agency collection then the agency cannot collect that information. I believe there are consequences if they do but not sure what OMB OIRA can do as far as actions against the agency for using an unapproved information collection. It's my understanding that the information from the Federal Register Notices are used by OMB OIRA in the approval process. My impression is that OMB OIRA wants to reduce the burden on the public and will take seriously the responses from the public on the information collection. That is my understanding on what this exercise is about. This process may be connected with a final rule; however, once approved in the final rule the renewal of the information collection is a separate process due to the three year limit.
  6. EO designation number: Executive Order 14063 https://www.govinfo.gov/content/pkg/FR-2022-02-09/pdf/2022-02869.pdf
  7. You will need to see the clause that is flowed down to your company from the Prime. It's my understanding each Department & Agency will issue its own FAR Class Deviation and there is a possibility that, depending on the Department/Agency, the clause may apply to COTS. It will all depend on the policy that issued in that Department/Agency FAR class deviation. You also may want to locate the website for the Department/Agency that you support in the next weeks to see what guidance they are providing to contractors. Hope this helps.
  8. I believe the Federal acquisition system is complex. I have read and heard for many years that the Federal Government should run like a business but I think this is incorrect. I believe reformers should look not at business but other Governments. What do other Governments, for instance countries in the European Union, and their acquisition system, do or not do, that could be used to improve the US Federal acquisition system?
  9. Here is a GAO decision that you may want to research: GAO Decision B-318046, Library of Congress—Obligation of Guaranteed Minimums for Indefinite-Delivery, Indefinite-Quantity Contracts under the FEDLINK Program, July 7, 2009, https://www.gao.gov/assets/b-318046.pdf
  10. From the article it does not appear he has much of a background in Federal Procurement. If the past is prologue with recent OFPP Administrators I don't think he will be in the position very long.
  11. I noticed in the decision reference to several different dictionaries such as Oxford English Dictionary, Webster’s Third New International Dictionary, Random House Dictionary of the English Language, etc. I would take from this that when considering the use of a word you may need to research several different dictionaries.
  12. You may want to check NCMA and or Bloomberg Government as a source. I found a report by NCMA and Bloomberg Government on 2013 Government Contracting that contained data on 1102 work force "Total Number of 1102s, 1998–2013" and "Average Number of Contract Dollars Obligated Per 1102" and they may have better data in a more recent report. Here's the link for reference: https://www.govexec.com/media/gbc/docs/pdfs_edit/061914cc3.pdf
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