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Found 3 results

  1. SITUATION: I work for the Department of Defense (DOD), and my office executes a healthy number of time-and-materials/labor-hour (T&M/LH) determination and findings (D&Fs). My leadership has decided, at legal counsel's suggestion, that the requirements of DFARS 212.207(b)(iii) can apply to all commercial T&M/LH D&Fs, including those done under the authority of FAR 8.404(h)(3). The upshot is that nearly all such D&Fs require Head of Agency (HOA) signature, since nearly all are defined under paragraph (6) of the "commercial item" definition. As you can imagine, this has create
  2. My company has a time and materials contract for which we are a first tier subcontractor. The prime contract is not a FAR 12 procurement. The prime contractor wanted to include a requirement in the contract that travel would be subject to the Joint Travel Regulations (JTR). My company pushed back. We are a subcontractor supplying commercial products and services under the T & M contract. The prime tells us that their contract requires that their travel doesn't exceed the JTR. However, it's my understanding that the JTR is only for military personnel. I suggested to my team that we a
  3. Scenario: Lower-tier subcontractor performing on a DO issued under the restricted suite of an IDIQ MATOC for maintenance and services. The DO contained 2 types of CLINS: 1. FFP (for preventative maintenance) and 2. T&M (for corrective maintenance). Prime contractor (Company A) submitted hourly labor rates to Govt.; the resulting award contained the hourly rates but no details are given regarding whether the rates for each labor category are for the prime or its subs. NOTE: lower-tier sub was not involved with prime contract in any capacity until well after the award. As such, it was un
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