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Found 17 results

  1. Hello - We are adding a subcontractor to a project that is under GSA. The subcontractor does not have a GSA schedule, so we are planning to map their hours to our approved LCATS. The biggest question is what rates should be included in the subcontract? Does the sub charge us our rates, or do they charge their rates? If the subs rates are lower than the rates we are mapping them to and we charge the government the higher rates are we opening ourselves up for an audit risk? Thank you for your assistance!
  2. Hi ALL, Government customer is pushing back on our Prime invoice submission which included (a reduced) G&A on top of a Subcontractor ODC where they (sub) applied G&A to ODCs (Travel). Basically our sub incurred travel expense that are allowable and billable to the program and sub applied G&A to ODCs when submitting their invoice to Prime for processing. Prime applied G&A when processing the subs ODCs (at a reduced rate) onto final invoice (in customers mind we are "doubling up" G&A - I should also note this is the first time this long standing contract (FFP) has had a sub
  3. Can anyone provide information regarding risks related to a Government employee signing a timecard (as if the Government employee were a supervisor)? I'm finding instances where Contracting Officer's Representatives (CORs) have been signing timecards for doctors or related contractor-provided personnel (whether they are an employee of the contractor, or acting as a subcontractor). The then-signed timecards are then sent to the company by the contractor employee. I'm concerned about risk, but I'm not finding any significant supporting information about the does-and-don'ts about this practice
  4. We are bidding on a contract that requires a proprietary software to be updated during the contract period. We received a quote from the company that owns the software and will come in annually to update it. A question came if this company should be treated as a Subcontractor (which of course affects our subcontracting goals) or if they are considered a vendor and should be treated like an ODC. I have searched the RFP to see if they define either of these terms with no luck. I have found the term subcontractor defined in FAR 44.101 but cannot find a clear definition of vendor. Can so
  5. I am currently a CPFF subcontractor under a Government prime contract. My company cycles on a calendar year and each January we update our provisional indirect rates for the upcoming year as well as calculate our final rates for the previous year. These rates are then provided to DCAA for review/approval and used for billing purposes under any CR contracts. This year, DCAA has stated that since we do not have a CPFF or T&M prime contract ourselves, we do not have a requirement to submit our PBR and they will NOT review our 2017 provisional rates. Our Prime contractor will not acc
  6. Does anyone here use the weighted guidelines to evaluate the reasonableness of a subcontractor's fee? Would that be appropriate? This a firm-fixed price subcontract.
  7. I am currently working on a sole-source IDIQ. I have solicited multiple fixed price supply items (non-commercial). My RFP includes range pricing and a Best Estimated Quantity (BEQ) /Annual Demand Value (ADV). The BEQ/ADV is based upon forecast data provided by the customer tempered with common sense and buy history. For Instance: A CLIN on my RFP may look something like this 0001AA Antenna Widget Quantity Range 100-190 (BEQ/ADV – 150) 191-200 201-270 I expect discreet pricing for all ranges, for all years of the contract (5 in this in
  8. Hello Wifcon members, I have a situation that I hope one of you can help me with. A subcontractor that worked under one of our Prime Contracts recently sent me their final invoice this month (Sept 2016), their final invoice was a rate adjustment based on their DCAA approved final indirect rates. The Prime Contract they worked under ended in 2014, but still has funding remaining on it. My questions are: Can I bill their Final Rate Adjustment Invoice against the remaining funding left on the prime contract even though the prime contract has already ended? Our prime contract co
  9. FAR 44.101 Defines Subcontractor as , "any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor ". 10 USC § 2474 (b) allows Depots to enter into Public-Private Partnerships (PPP) and further says that they may provide, " (A) For employees of the Center [...] (under contract, subcontract, or otherwise) work related to the core competencies of the Center, including any depot-level maintenance and repair work that involves one or more core competencies of the Center". Now, Title 10 allows the depot to en
  10. I was hoping I could pick someone's brain, as I wanted to confirm as to whether or not there is some federal or accounting principle that would prevent the following or if there are any ramifications that I may not be aware of? Long story short, we are a Subcontractor to a contract in which the Prime is requesting to handle all travel for our employees. From making arrangements, to reimbursing and/or paying the employee. The CLIN associated with travel was awarded on a cost reimbursable basis not-to-exceed $350k. Not sure if it's such a big deal but logically it just doesn't make sense
  11. I am competing a requirement amongst GSA IT Schedul 70 contract holders. The requirement is combination of Firm Fixed Price and Labor Hour. In discussions with one of the other Contracting Officers here, he mentioned to me that I would be required to get subcontractor proposals in order to determine the reasonableness of the Prime Vendor's rates (i.e. determining the prime's profit, etc.). This is not something that I have done before, nor in my time working in private industry have I submitted subcontractor proposals with my GSA quote. I would consider doing this if it were a sole sou
  12. Contract Type: Design Build - FFP Scenario: First tier subcontractor to prime contractor refuses to submit its invoices in the schedule of values format required by the prime contract. Background: 1. The prime contractor incorporated the schedule of values invoicing requirement into the subcontract; subcontractor concurred and signed subcontract. 2. Subcontractor attempts to "front load" charges into its invoices and demands prime contractor pay subcontractor well in advance of what prime can bill government for said charges under the required schedule of values. 3. Prime contractor contacts
  13. A small business subcontractor working for a prime contractor has not received final payment for work completed from April 2012 to August 2012 due to the non-acceptance of a major deliverable (a report) by the government. The prime contractor has a cost plus fixed fee contract with the federal government. There have been several iterations of the deliverable in question primarily due to the government COTR changing three times. The first COTR asked for more detail and when revised, a new COTR was appointed, and asked for less detail. The deliverable was revised again to meet his request, a
  14. I am a 1st tier sub on a Federal Contract and my 2nd tier sub submitted an RFP to the Prime which was then approved and sent back as a Change Order. I signed my Change order with the prime and sent my Change Order down to my sub to sign. My sub found an error in the amount that they submitted and are not willing to sign this months pay app which includes the executed Change order nor will they sign the Change Order. My sub said it is my fault and I should not have signed the Change Order. I do not feel that I am in the wrong here because my prime submitted the number that my sub submitted
  15. We have a CR contract awarded in 2012 to a not-for-profit small business organization for R&D. Now, in one of the option years, the contractor is claiming that they can do a portion of the work for less if they hire a subcontractor to do that portion of the work. They are trying to charge the government for the audit of a potential subcontractor to do this work. The government did not 'request' or 'require' that the subcontractor be used--the contractor proposed it on their own. I can't find anywhere that addresses this directly (or indirectly on the facts presented--existing contract, sub
  16. A company being 100% stock-acquired is a T&M subcontractor to large prime. Certified Cost or Pricing Data was not required during proposal process. Subcontract includes non-assignment clause by prime and flowdown of 52.215-19 Notification of Ownership Changes. Since the sub is being purchased in whole, assignment doesn't apply. Would a T&M subcontract be subject to postaward cost redetermination if there are immaterial ODCs, thereby requiring the notification of ownership change?
  17. We as a prime contractor have been wrestling with who is responsible for reviewing a subcontractors final indirect cost rate proposal and determining the rates. It's an easy thing if the subcontractor has an approved accounting system but what if he doesn't and you are awarding a T&M subcontract. FAR 42.202(e)(2) states "The prime contractor is responsible for managing it subcontracts". Does this mean every function described in 42.302(a)? Further when you get to T&M subcontracts there is no requirement to flow down the T&M payment clause 52.232-7 nor is there a requirement to
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