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pmh

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About pmh

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  1. I don't know if all DoD agencies will use it, but this one is from the Office of Naval Research website. Subcontracting Plan ONR 2013 template.docx
  2. What contract type do you have? If it's a Time and Materials type, then you acquire supplies on the basis of "actual cost for materials". See FAR 16.6.
  3. Tj, it may vary by agency. For some reason it won't let me add the subaward link here, but if you go to www.nationalacademies.org, under their documents section, they have a template that NIH put together to conform with the new Uniform Guidance requirements.
  4. It's from the agency's internal acquisition regulation. It's in our CR type contract.
  5. There's no introductory portion in the specific clause, at least not the Aug. 2011 version. There is also no language that states it needs to be flowed down to subcontractors.
  6. Grant Audit Companies

    McGladrey is one.
  7. Also, be as specific as possible. Include version numbers of the software and dates if available.
  8. The new Uniform Guidance at 2 CFR 200 is applicable to universities and educational institutions. Specifically see 2 CFR 200.319 for competition.
  9. Just because your prime contract is CPFF, doesn't mean your subcontracts have to be CPFF as well. It depends on what the requirement of your subcontract procurement is.
  10. Executive Comp

    Would this new rule apply to Nonprofit Organizations? This rule only references changing FAR 31.205-6, as a nonprofit we follow FAR 31.7. We always have the Allowable Cost and Payment clause tailored to add Alternate IV, which replaces 31.2 with 31.7. Although 52.216-7 does mention that established rates will be in accordance with FAR Subpart 42.7, which contains 10 USC 2324 (a). The federal register article above states "all" contractors, not just for-profit. I would interpret all this to mean that it would apply to a nonprofit organization since it does reference the appropriate 10 USC 2324 section in 216-7, but we have some folks stating that it doesn't because FAR 31.7 hasn't been, or won't be changed. Am I correct, or will this not apply?
  11. Local Clause for WAWF

    Thanks dcarver, they actually issued the modification unilaterally. I'm looking into the REA now.
  12. Local Clause for WAWF

    We just had the exact same supplement added to the WAWF clause in our contract. Don, what was your resolution to this problem?
  13. Each situation will be different, but a good starting point is FAR 35.006: "( c ) Because the absence of precise specifications and difficulties in estimating costs with accuracy (resulting in a lack of confidence in cost estimates) normally precludes using fixed-price contracting for R&D, the use of cost-reimbursement contracts is usually appropriate (see Subpart 16.3)."
  14. A grant is not a contract. As a nonprofit also that has many grants and contracts, this needs to be drilled into our staffs heads daily. See the definition of contracts under FAR 2.101, it ends "Contracts do not include grants and cooperative agreements". A grant is a financial assistance award with very little oversight, and are subject to different policies (NIH grant policy statement, DODGARS, etc.), instead of the FAR, HHSAR, or DFAR. The OP is a nonprofit and would use A-110 which uses the terminology "subaward" or "subrecipient", not "subcontract" or "subcontractor". Subawards are issued under grants and subcontracts are issued under contracts. There are some instances that you can have a subcontract issued from a grant, but they must include the requirements at 45 CFR 74.48.
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