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Government has released an RFP with a 100% SDVOSB set-aside. The Government has stipulated they anticipate awarding the contract strictly on a FFP basis where all Offerors will be responsible for including all costs associated with travel and ODCs into each of the specific CLINs.

Does the 50 percent that is required to be performed by the SDVOSB Prime consists of only labor or is it inclusive of all costs (labor, travel, and ODCs) as a result of how the Government is anticipating on awarding the contract?

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I recommend looking at the contract clause instead of the underlying regulation -- you will see the same words in both places (clause and 13 CFR), but the clause is enforceable as a matter of contract administration. I suppose a 100% SDVOSB set-aside solicitation and contract will include the clause at FAR 52.219-27, Notice of Service-Disabled Veteran-Owned Small Business Set-Aside -- see para. ( d ) o the clause.

[edited to correct clause number]

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I recommend looking at the contract clause instead of the underlying regulation -- you will see the same words in both places (clause and 13 CFR), but the clause is enforceable as a matter of contract administration. I suppose a 100% SDVOSB set-aside solicitation and contract will include the clause at FAR 52.219-22, Notice of Service-Disabled Veteran-Owned Small Business Set-Aside -- see para. ( d ) o the clause.

The correct clause for SDVOSB set-asides is 52.219-27.

You shouldn't look at the clause "instead of" the SBA regulation. You have to look at both the clause and the SBA regulation.

The SBA regulation includes official definitions of terms in the clause. Those definitions do not appear in the FAR. For instance, if the contract is for services, the SBA regulations define the "cost of contract performance incurred for personnel" and "personnel," which presumably covers the phrase in the clause, which is "cost of personnel for contract performance." If the contract is for supplies, the SBA regulation defines the "cost of manufacturing" and the "cost of materials." See 13 CFR 125.1. 13 CFR 125.6 also includes important interpretive information.

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