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Found 5 results

  1. Hello everyone, I'm at a loss trying to figure out how this situation would be handled. Please bear with me as I lay it out: Parent Company A is the parent company to multiple wholly-owned subsidiaries. This scenario involves two; Subsidiary 1 and Subsidiary 2. Subsidiary 1 holds a GWAC that neither Subsidiary 2 or Parent Company A possess in their name. An opportunity is released on said GWAC that Subsidiary 2 would like to pursue. The opportunity requires DCAA audited accounting system, an approved purchasing system, and relevant past performance. Parent Company A holds the approved purchasing system, Subsidiary 1 holds the DCAA audited accounting system, and Subsidiary 2 holds the relevant past performance. Is it compliant to cherry pick the necessary systems from each company all under one blanket entity? Is there any guidance in the FAR aside from 31.205-26(e), which explains cost vs price in intra-company transfers. Hoping there's more info out there other than "its up to the contracting officer". Thanks y'all.
  2. Hello all, I have recently moved from a DoD contractor to an NGO without an Approved Purchasing System. This has not been an impediment for them, as they have only performed as a subcontractor under a handful of USAID prime contracts. However, there is interest in expanding their contracts portfolio and a desire to move beyond subcontracting into prime contracting. As that is the case, I have begun the process of determining how prepared we are as an organization for a CPSR audit. So far, it looks pretty grim. Little to no file documentation, no price/cost analysis being performed, policies and procedures exist but are likely insufficient or require revision, etc.. My question for the forum is: what is a *reasonable* estimate of level of effort to get a large (~$900M per year) NGO in a position to not get blown out of the water by a CPSR auditor? My extremely conservative estimate right now is 500 hours spread out across the org, but I think that is probably too low. Does anyone out there have experience in doing this? I know there are a number of consultancies out there that specialize in this, but as a non-profit that is already cost adverse due to some large IT investments in recent years, I suspect that leadership is going to want to keep this process in house as much as possible. Any and all feedback/advice/etc. would be appreciated.
  3. Tesla and SpaceX founder Elon Musk allegedly smoked a few puffs of cannabis ("weed") and drank whiskey with Joe Rogan during a live-streaming interview on the "Joe Rogan Show," which is a popular podcast hosted by former Fear Factor host and current Mixed Martial Arts (MMA) commentator, Joe Rogan. https://www.businessinsider.com/nasa-launches-safety-review-of-spacex-after-elon-musk-smoked-weed-2018-11 SpaceX (and Boeing) have big contracts with NASA. This behavior prompted NASA executives to request a "safety review" of SpaceX (and Boeing). What might this safety review entail? PepeTheFrog assumes at least some part of this review would be targeted towards any possible illegal drug use of contracted employees at SpaceX (and Boeing). What FAR or NASA clauses would this review rely upon? If SpaceX or Boeing refuses, what could the government use to demand compliance? Under which FAR clause would the safety review's initiation and execution be premised upon? FAR Subpart 23.5, Drug-Free Workplace FAR 52.223-6, Drug-Free Workplace
  4. For the last several years, the DoD has bulked up regulations aimed at detecting and preventing electronic counterfeit parts within Government contracts. Two major clauses apply these regulations to defense contractors: “Contractor Counterfeit Electronic Part Detection and Avoidance System,” and “Sources of Electronic Parts.” Here’s a summary of the main points of each clause. Read the full article at Petrillo & Powell's Patterns of Procurement.
  5. My company is interested in setting up CPSR-compliant policies and procedures. In my previous lives, I have tracked compliance actions (ie, EEO, TINA, Reps and Certs, etc) at the subcontract level (covering all subsequent Task Orders) and I've also done it on a per Task Order basis. I think each have their own unique pros and cons. I have my own preference but would like to hear the experience/thoughts of others. Thanks!
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