Paying for Mobile Hot Spots via ODC

[C Culham]

47 minutes ago, Jenkins83 said:

The rude and sarcastic comments are a bit much.

Sorry that you took my comments to be rude and sarcastic.   Was not my intent.  I was truly mystified as to why you kept raising the question when responses had been provided regarding the common use (FAR Part 15 and 31) of what a ODC is.  I now understand you were really asking about establishing CLINS to pay for a cost.  Now clarified I hope the additional posts help with your original post.

 

 

[Lionel Hutz]

1 hour ago, Jenkins83 said:

This is all true and I can’t negate any of it. I’m now wanting to dig further as I’ve been an 1102 for 8 years and a CO for 3 and I must say my organization has always established line items for travel and other direct costs hmmm.....

I'm not sure that this is the definitive answer, but DFARS 204.7103-1(f) states, "If a supply or service involves ancillary functions, like packaging and handling, transportation, payment of state or local taxes, or use of reusable containers, and these functions are normally performed by the contractor and the contractor is normally entitled to reimbursement for performing these functions, do not establish a separate contract line item solely to account for these functions. However, do identify the functions in the contract schedule. If the offeror separately prices these functions, contracting officers may establish separate contract line items for the functions; however, the separate line items must conform to the requirements of paragraph (a) of this subsection." (emphasis added)

So, it seems like the contracting officer can establish separate contract line items for other direct costs like transportation, provided it satisfies the listed requirements.  Or am I reading that wrong?

[Jenkins83]

16 minutes ago, Lionel Hutz said:

I'm not sure that this is the definitive answer, but DFARS 204.7103-1(f) states, "If a supply or service involves ancillary functions, like packaging and handling, transportation, payment of state or local taxes, or use of reusable containers, and these functions are normally performed by the contractor and the contractor is normally entitled to reimbursement for performing these functions, do not establish a separate contract line item solely to account for these functions. However, do identify the functions in the contract schedule. If the offeror separately prices these functions, contracting officers may establish separate contract line items for the functions; however, the separate line items must conform to the requirements of paragraph (a) of this subsection." (emphasis added)

So, it seems like the contracting officer can establish separate contract line items for other direct costs like transportation, provided it satisfies the listed requirements.  Or am I reading that wrong?

This is the direction I am accustomed to but the posts have made me want to have a better understanding. I can’t imagine we’ve been completely doing this wrong as an entire organization and haven’t been written up.

[Jenkins83]

31 minutes ago, C Culham said:

Sorry that you took my comments to be rude and sarcastic.   Was not my intent.  I was truly mystified as to why you kept raising the question when responses had been provided regarding the common use (FAR Part 15 and 31) of what a ODC is.  I now understand you were really asking about establishing CLINS to pay for a cost.  Now clarified I hope the additional posts help with your original post.

 

 

All is well. I just often want to know what other agencies are doing. 

[Guest Vern Edwards]

4 hours ago, Jenkins83 said:

I’m now wanting to dig further as I’ve been an 1102 for 8 years and a CO for 3 and I must say my organization has always established line items for travel and other direct costs hmmm.....

You don't have to dig very deeply. Credit it to lousy professional education.

I was taught proper CLIN structuring by the staff of the Contract Writing Office of the USAF Space and Missile Systems Organization in my first year on the job, 1974. Real pros. They literally beat it into me. Of course, that was in the days when contracting people understood contracts and knew why it would make no sense whatsoever to create a line item for a cost. It was when people understood what a contract "schedule" was supposed to be.

Go ahead and ask them why they do it. They'll have some half-baked explanation. They might even try to claim that it's okay.

[BowtechDan]

On ‎5‎/‎31‎/‎2018 at 3:37 PM, Jenkins83 said:

 The Air Force networks blocks certain sites they feel aren’t needed or appropriate. The sites are actual testing sites but out COMM department blocks them. 

Has anyone explained the issue to them? Maybe COMM needs to be aware it's a requirement.