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Minimum IDIQ Order Award FY vs POP FY

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Really, Vern?  Do you really think a single contracting officer can require that his or her agency comply with your expectations of data processing system functionality?

In today's practice in several agencies, it is common to issue IDIQ contracts without funds citations for the contract minimum.  If those agencies record the minimum as an obligation on their books, they do so administratively -- or manually, if you prefer.  The recording doesn't occur automatically, but is done by humans in the comptroller community.

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Guest Vern Edwards
24 minutes ago, ji20874 said:

Really, Vern?  Do you really think a single contracting officer can require that his or her agency comply with your expectations of data processing system functionality?

ji-- Where did that question come from? Red Herring!  Who said anything about what a single contracting officer could do? Give me a break.

24 minutes ago, ji20874 said:

In today's practice in several agencies, it is common to issue IDIQ contracts without funds citations for the contract minimum.  If those agencies record the minimum as an obligation on their books, they do so administratively -- or manually, if you prefer.  The recording doesn't occur automatically, but is done by humans in the comptroller community.

Name one such agency and provide proof of your claim--a written policy or regulation like the DOD FMR--and provide support for that "it is common" assertion. I don't take your word for it.

In any case, what sense does it make to leave the fund cite off the contract? Isn't the contracting officer going to have to an administrative commitment before awarding the contract in order to insure against an ADA violation?  If the CO is going to have a commitment of funds, and if the comptroller is going to record the minimum as an obligation on the books, presumably from the commitment account, why not put the fund citation on the contract? What's the point of leaving it off?

The mechanism by which the recording is done is not an issue, so you don't have to keep repeating the "administrative" and "manual" bit. The mechanism is irrelevant, whether it's through IT, by humans or monkeys, by pen or pencil, or using a stylus on a clay tablet, as long as it's done.

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Oh, you weren't telling me to teach the IT pukes to design compliant systems?  

You can take my word for it that it is common practice in multiple agencies to award IDIQ contracts without funds citations. Indeed, I just called a contracting officer in a different agency -- he said (with no prompting from me) that no, there is no funds citation in the IDIQ contract -- the recording for the minimum is not done contractually, it is done administratively.  

I'm not defending the practice of not including the funds citation, just explaining it to you as common and current practice.  Anyway, a current practicing contracting officer tells you that it is common practice that an IDIQ contract does not contain a funds citation for the contract minimum, and you refuse to believe it?  I'm not a liar.

Why don't you cite me proof that an IDIQ contract must include a funds citation for the minimum?  If you can cite that proof, I can share that with others and maybe we can start accommodating you.

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Guest Vern Edwards
2 hours ago, ji20874 said:

Oh, you weren't telling me to teach the IT pukes to design compliant systems?

But you aren't just any old contracting officer. :)

2 hours ago, ji20874 said:

I just called a contracting officer in a different agency...

Somebody else just gave me that kind of evidence in another thread! No good. Anecdotal from only one source.

2 hours ago, ji20874 said:

I'm not defending the practice of not including the funds citation, just explaining it to you as common and current practice.

Really? I could defend it. But I'm glad to see you don't think it's a good practice.

2 hours ago, ji20874 said:

Anyway, a current practicing contracting officer tells you that it is common practice that an IDIQ contract does not contain a funds citation for the contract minimum, and you refuse to believe it?  I'm not a liar.

I don't think you are a liar. But if I had a nickel for every fairy tale I was told by some current practicing contracting officer I'd be much richer than I am. I hope the industry folks are getting a good laugh out of that. Anyway, you should be able to provide documentary evidence of that. I could, but I'm not going to help you. I just want to see if you can back yourself up or are just talking through your hat. Come on, Mr. Current Practicing Contracting Officer. Show us what you know.

 

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It's not a fairy tale, Vern -- really and truly, it is common practice across agencies to award IDIQ contracts without funds citations in the contracts to cover the contract minimums.

Please show me the regulatory citation where an IDIQ contract must contain a funds citation to cover the contract minimum.  Show us what you know.

Sad.

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Guest Vern Edwards
On 2/2/2018 at 5:51 AM, ji20874 said:

Please show me the regulatory citation where an IDIQ contract must contain a funds citation to cover the contract minimum.  Show us what you know.

Why do you always answer a question with a question?

I will show you the regulatory citation. But first, show me, by direct quotation, where I said that there is such a regulatory requirement. In what post did I make such an assertion? I want you to show me where I used the words "fund citation," "regulation" or "regulatory," and "required" in a sentence.

By the way, I can also show you a regulation that exempts IDIQ contracts from the requirement to have a funds citation. But I won't until you show me where I said that a regulation required one.

I believe that inclusion of a funds citation is proper practice, but I don't think it is required in all agencies. I believe that when awarding an IDIQ contract a CO must have funds to cover the minimum, even if the minimum is not ordered at the time of award. I believe that if a CO has funds he or she will have some kind of "funds citation" (really a DOD term--I don't all think all agencies use it). I believe that if a CO has a funds citation, then it should be recorded in the award document. That's why the contracting forms have a block for "accounting and appropriation data."

And what's up with the "Sad"?

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On 2/2/2018 at 8:51 AM, ji20874 said:

it is common practice across agencies to award IDIQ contracts without funds citations in the contracts to cover the contract minimums.

So much for my attempts to shut down a thread that had devolved into an argument over rather meaningless semantics...:o   For the record: I have always understood the process and maintain the exact same position I laid out in my first post.  

In my travels implementing PD2 across DoD, I did in fact run into the exact case you described, specifically,  1102's attempting to Release IDIQs without funding, whereupon  the award failed system validation because it violated DoD policy, and was always halted as a business practice when it was discovered.

 It is also common practice to obligate $1 on an IDIQ IDV (and I can point you to the exact vehicles if you're interested), but that doesn't mean that it's  a good idea.

Regardless, it's not an "administrative obligation" to issue an IDIQ without a funds cite....and  I have no doubt that Vern has a deus ex machina up his sleeve regarding unfunded IDIQs, but hey, that's Federal contracting - there's always a waiver or  exemption lurking somewhere! :D

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