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Found 2 results

  1. Does the Fiscal Year of the PIIN Matter? A BPA was awarded in September with a FY15 PIIN, but performance starts Oct 01 (FY16). I was told that I should have a FY16 PIIN; however the FY16 PIIN is not available. Other suggestion was to start the contract in FY15 so there wouldn't be questions/problems about my PIIN and POP not matching. ***This was a follow on BPA competed. It was awarded/signed by the Gov't prior to the start date so the vendor could be prepared to perform - base access, etc.***** Is there something I am missing? It seems like the issue of the concern is with September awards with October start dates. Thanks for your help.
  2. WIFCON gurus, An internal review in a federal agency has suggested that unless a contractor's signature is handwritten in ink on a contract record it isn't official, i.e., not a writing & not authenticated so not binding. While the agency provides for 1102s to use electronic signature capabilities in Adobe Acrobat and MS-Word since those actions are tied to their CACs, the agency does not issue CACs to contractors with which it contracts. That effectively precludes (in the internal review's concept of the world) contractor's from signing a contract record any way but with an original handwritten ink signature. For the 1102s that rules out receiving faxed documents w/ an image of a contractor agent's signature, rules out scanned & e-mailed documents w/ an image of a contractor agent's signature, etc. for official contract records and rolls back the clock a few decades. When hundreds of contracts are involved the logistics of snail mail for ink signatures is daunting and inefficient. While ESIGN, Pub.L. 106-229, did provide for contracting parties to conduct electronic commerce provided they agreed to it, it also created authentication requirements to be established at the agency level. In this case the agency's authentication is not supportive. Are these 1102s stuck having to get a contractor agent's handwritten ink signature on contract records or is there a lever (statutory or argumentative) out there that would pry open the door to accepting faxed or e-mailed documents with signature images as official (to be writings, authenticated and binding)?
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