Jump to content
The Wifcon Forums and Blogs
MAY-D-FAR-B-WIT-U

52.222-46, Evaluation of Compensation for Professional Employees

Recommended Posts

 

2 hours ago, Constricting Officer said:

While I have enjoyed the read, I am surprised the conversation went past this post. The issuing of a DO/TO is against something already negotiated. If I have learned nothing more from this "gathering of the minds," it is to keep things simple. We have MATOCs, FSSs and NASA's SEWP (to name a few) to ease the administrative burden of federal contracting. The guidance to be innovative (FAR 1.102-4 (e)) has lead to these vehicles being available and we should not make things harder on ourselves.

 

Yes,  the conversation went farther.  The original poster clarified, on Tuesday at 5:54 PM (CDT), that he or she was referring to a situation where 1) the agency encourages offerors to submit lower prices than the schedule prices and/or 2) the task order includes additional classifications of professional personnel that are not covered by contract established rates. 

My first reply, on Wednesday at 5:54 AM (CDT) was in response to that  clarification by the original poster. In the specific situations described in the clarification, the government would request task order proposals from multiple award task order contract/MACC/Schedule/pool members/etc. contract holders. If the vehicle is a single award task order contract, the government would also request a proposal, although There wouldn’t be competitive pressure to “wage slash”. 

 I am on the road today so cannot take the time to research the reference. However I believe it is DOD acquisition policy that, when using the GSA schedules or another ID/IQ contract vehicle, the government should encourage or request discounts from the schedule/ID/IQ contract rates. I believe that it is or was part of the “Better Buying Power” Initiative *.  

It doesn’t matter so much to me how it’s done but the government should be concerned about the possibility of wage slashing for professional employees when recompeting for existing services.

EDIT: here is one example of DoD policy concerning seeking discounts when using the GSA Schedules:

 https://www.acq.osd.mil/dpap/policy/policyvault/USA004263-15-DPAP.pdf

*This wasn’t necessarily part of “Better Buying Power”. Having refreshed myself somewhat concerning the Better Buying Power initiative, those policies do not necessarily make things easier for the acquisition force...

Share this post


Link to post
Share on other sites
5 minutes ago, Vern Edwards said:

the acquisition workforce is bound mind, hand, and foot to the FAR Part 15 Process Model, and they cannot free themselves.

Exactly and from top to bottom as in many cases bosses demand that the workforce make it so and prevent them using the innovation that the FAR allows!

Share this post


Link to post
Share on other sites
5 minutes ago, Vern Edwards said:

No. It was $500,000.

There was a point I was going to take my thoughts off line and go do something else so sincerely an apology for belaboring but in 1962 it was $100,000 I think....

https://www.gpo.gov/fdsys/pkg/STATUTE-76/pdf/STATUTE-76-Pg528.pdf

I will just sit back and read for a while and leave the too much specifics alone!

Share this post


Link to post
Share on other sites

The original 1962 threshold was $100,000. It was raised to $500,000 in 1982. Then it was reduced to back to $100,000 in 1984. Then it was raised back to $500,000 in 1991, and it's been increased from there. At present, the threshold is $2,000,000.

If you don't believe me I can provide statutory citations, or you can look up the history in Defective Pricing Handbook, 2018 Edition,  § 2.4, by David Z. Bodenheimer. Essential reading for those who want to understand the cost or pricing data law.

Share this post


Link to post
Share on other sites
1 hour ago, Vern Edwards said:

If you don't believe me

Always believe you, but not always agree!  Thanks for making the effort to give me the trail!

Share this post


Link to post
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now

×