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Generally speaking, it is up to the prime to select the type of subcontract, subject to the subcontracting clauses in the prime contract from FAR 52.244-xx. In this case, the prime has proposed team subs, in effect making a commitment to the government that those subs would be part of the prime's team in performing the contract. For an IDIQ, performing the contract means performing each task order under the contract.

Practically speaking, what other subcontract type would one want, besides IDIQ task order? A separate, stand-alone subcontract or purchase order for every task order under the prime? Why would you want to do that?

If I were a team sub I would be most unhappy that my prime's commitment to me does not reflect the same commitment the prime has made to the government customer.

If I were the government I would wonder why my prime promised me the services of these team subs on the IDIQ but did not sign them up to the same extent I have my prime signed up.

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Cajuncharlie, Thank you for your quick response. We are very committed to our team subs so no worries there. The problem is maintaining task orders on 12 team subs in a seamless environment has become beyond an administrative burden that the government is paying for. We are considering changing to level-of-effort and removing all task ordering language from the team subcontracts. We would manage by total hours for the workforce on the subcontract and not by task order. Our contract team is so seamless that we have managers and directors in our org structure that are team sub employees. Almost all of our subs have the same labor categories and workshare is based on percentage of work received from the government. Its an unusual situation that our government customer liked because then we weren't married to one indvidual company that controlled a portion of the work on the contract, its all intermixed with the Prime being the overall controlling entity. There is no requirement in our contract on type for team subs. The only authority I have been able to find that says the Prime can chose the type is the DCAA CAM 5-611 Subcontract Award and Administration . Do you have another authority I could reference?

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Hi Beverly,

Long ago I was involved with an ID/IQ Task Order contract with two Team SubKs. We had more than 300 task orders--scores of which were active at the same time--and it was a nightmare to manage funding and costs by task order and by performing entity. So I definitely feel your pain!

But when I read, "We would manage by total hours for the workforce on the subcontract and not by task order," I wonder how you are going to comply with Limitation of Costs/Limitation of Funds requirements with respect to each task order. I wonder how you are going to accumulate labor hours and costs for invoicing each task order. I wonder how you are going to report progress or (heaven forbid!) Earned Value analysis of each task order. I wonder how you will calculate Estimates-at-Completion (EACs) for each task order. I wonder how you are going to prepare your incurred cost submission/final indirect cost rate proposal at year-end, when DCAA will want to see actual costs, by cost element (including subcontractor costs), for each task order.

Now maybe you only have FFP task orders and most of what I said is Not Applicable. Or maybe you have better systems than we had, long ago. But just in case your situation was similar to mine, I thought I would raise my concerns for your consideration.

Hope this helps.

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We have that covered. We require the team sub employees to enter time into our timekeeping system which has charge codes for task orders and other work that we have, then they invoice based on a weekly download of the entries through a preprocessor file. They are not allowed to invoice for any labor other than what they put into our timekeeping system. Since we have their hours and we have their fully burdened labor rates we are able to accrue their costs real time. EACs, budgeting, tracking, etc. is all done at the Prime level. LOF is also at the Prime level. Since we know every week what the team sub charges are, when we hit a certain point on the funding on a task order we shut off the charge codes and redirect the employees to other work until the government customer comes through with more funding. We are truly a blended team. Can you think of any other authority that says the Prime can pick the type or an authority that would require us to keep our subs as task order?

Thanks for your help!

P.S. We have had over 250 task orders this first year of the contract....and we have to have so many subs so we can meet a 33% small business goal that breaks down into further socio-economic goals.

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Cajuncharlie, Thank you for your quick response. We are very committed to our team subs so no worries there. The problem is maintaining task orders on 12 team subs in a seamless environment has become beyond an administrative burden that the government is paying for. We are considering changing to level-of-effort and removing all task ordering language from the team subcontracts. We would manage by total hours for the workforce on the subcontract and not by task order. Our contract team is so seamless that we have managers and directors in our org structure that are team sub employees. Almost all of our subs have the same labor categories and workshare is based on percentage of work received from the government. Its an unusual situation that our government customer liked because then we weren't married to one indvidual company that controlled a portion of the work on the contract, its all intermixed with the Prime being the overall controlling entity. There is no requirement in our contract on type for team subs. The only authority I have been able to find that says the Prime can chose the type is the DCAA CAM 5-611 Subcontract Award and Administration . Do you have another authority I could reference?

Why do you need something that says you can do this? The more appropriate question would be why can't you do this?

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I'm trying to convince my corporate office that we can make this change because they keep saying we can't but won't give me any authoritative reason why not. Our contract is suffering under this burden but my corporate office is holding hard and fast. My direct manager asked me to put some research together with quotes/citations to substantiate why we can or why we cannot make this change. We all here seem to agree that the Prime can chose whatever type it feels reasonable, but I can't find anything from an authoritative source to substantiate that one way or another...other than what I found in the CAM. I'm not looking to incorporate the CAM, I just need something from a quotable source. Do you have something other sources I can use?

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Retread is right.

BTW, in my 38 years in this business, I have yet to see a contract that incorporated by reference the DCAA Contract Audit Manual. (I am a four corners of the contract kind of guy.)

God help us if someone did incorporate the CAM. It is not a procurment regulation, and by its terms was not intended to be anything other than a guide for those conducting contract audits.

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Guest Vern Edwards

BTW, in my 38 years in this business, I have yet to see a contract that incorporated by reference the DCAA Contract Audit Manual.

Interesting statement. In those 38 years DOD would have awarded more than a million contracts valued in excess of the simplified acquisition threshold. How many of them did you see?

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Guest Vern Edwards
God help us if someone did incorporate the CAM. It is not a procurment regulation, and by its terms was not intended to be anything other than a guide for those conducting contract audits.

You wouldn't need God's help. People have incorporated worse things into government contracts.

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