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Found 6 results

  1. Fed Reg Vol 81 No 104, May 31, 2016 finally implemented the “Similarly Situated Entity“ rule of the 2013 NDAA. Specific updates to 13CFR125 change the overall tenor of the Limitations on Subcontracting to a true limit on the amount that can be subcontracted rather than a prime performance requirement. Based on much of the reasoning included in that Fed Reg, the intent was to bring parity to the various programs, including the Limitations on Subcontracting. The Reg however did not change 48 CFR 52.219 and the various FAR clauses -3, -14, -27, -29, and -30 that implement the limitations
  2. Government has released an RFP with a 100% SDVOSB set-aside. The Government has stipulated they anticipate awarding the contract strictly on a FFP basis where all Offerors will be responsible for including all costs associated with travel and ODCs into each of the specific CLINs. Does the 50 percent that is required to be performed by the SDVOSB Prime consists of only labor or is it inclusive of all costs (labor, travel, and ODCs) as a result of how the Government is anticipating on awarding the contract?
  3. Reference FAR 52.219-14 (and similar clauses). I've seen several threads in this forum discussing the calculation methodology for determining the “cost of performance incurred for personnel”. I found the “Is this Professor right?” thread (started by contractor100 on 3/23/12) to be particularly informative and, in my humble view, conclusive as to how I have been calculating such costs (Vern's #25, alternate method). So I need to throw a hypothetical situation out there that I may find myself in soon. On a FFP contract (with resulting FFP subcontracts) I may not have visibility into my subcon
  4. The Government has a requirement for physician services. It has been determined that GSA Schedule 621 I has small and large schedule holders capable of meeting the Government's requirement. To the meet the agency's small business goals, the Contracting Officer intends to set aside the acquisition for small business concerns. The estimated value of this acquisition is $300,000. The Contracting Officer is now being challenged on the set aside. Those opposed to the set aside have stated that physicians being provided by the GSA staffing firms (found on schedule 621 I) are 1099 independent contrac
  5. A recently posted NAVFAC solicitation for construction services under NAICS 237XXX as an EDWOSB set-aside identifies a 25% limitation on subcontracting. FAR 52.219-14 Limitations on Subcontracting confirms a 15% requirement for “General Construction” and a 25% requirement for “Construction by Special Trade Contractors”. Other agencies (USACE, VA) have concluded that “Special Trade Contractors” refers ONLY to NAICS 238XXX (I assume based on the Title of NAICS 238…“Specialty Trade Contractors”) and further conclude that 237XXX falls under “General Construction”. I plan to ask about this as an
  6. As a (small) business owner, qualifying under several socio-economic programs, performing on a Federal construction contract, I am exempt from reporting requirements in accordance with Davis-Bacon. That is, whereas I have to report employees time/pay in accordance with Davis-Bacon, I am exempt from reporting wages (if any) paid to myself. How would the contracting officer (or SBA if subject to a later audit) allocate my compensation when it comes to calculating the labor portion as it relates to any applicable limitations on subcontracting? I often go without pay, if I chose to do so, for
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