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9 hours ago, Retreadfed said:

Carl, you are avoiding the issue.  If you contend that a fund citation must be included on the face page of an IDIQ contract, you must have some regulatory or statutory authority to support that contention.  All that I am asking is what is the authority that requires this?  I have been doing this for over 45 years, mostly with DoD, and do not recall ever having seen a fund citation on an IDIQ contract.  Has DoD been doing this wrong for all these years?  If so, based on what regulation or statute?

@Retreadfed   I am going to make this quick.   Please refer my post of June 5.   I am done with this specific debate with regard to the appropriation and accounting information on the face of the form.  

The fact remains that the appropriation and accounting data for an IDIQ must be known and available for obligation and recording.  Agencies have all ways of making it happen by either default or specific policy but the one fact remains an IDIQ minimum when obligated must be recorded.  There are work a-rounds, electronic systems, stubby pencil, you name it but it is done.  And for me it makes all the sense in the world under FAR conventions that the fund(s) used should be placed on the face of the IDIQ award unless some work around like awarding an immediate task order is used to accomplish the minimum.  Sensible under FAR conventions just like an agency putting their name in the "Issued Block" absent some regulatory or statutory authority.  It should be done. 

PS - Here is a DoD policy - authoritative or not you decide - but they got it right once!   

SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS https://www.acq.osd.mil/dpap/ccap/cc/jcchb/Files/.../SF 1449 instructions.docx CachedWhen Preparing the SF-1449 (Solicitation/Contract/Order for Commercial Items) the Contracting Officer will complete blocks 1- 30 with the exception of blocks 12, 17, 23, 24, and 30. Enter the Purchase Requisition Number (This number is usually assigned by the requestor and found on the purchase request.)

Again I am done with the face of the award form for an IDIQ, I hope you are too.

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Carl, instructions for completing a 1449 form isn’t authoritative.  If you want a good way of seeing how the entire government deals with IDIQ obligations, scan FPDS.  I quickly looked through many pages of listing and didn’t see any with money obligated on the basic award.

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7 hours ago, formerfed said:

Carl, instructions for completing a 1449 form isn’t authoritative.  If you want a good way of seeing how the entire government deals with IDIQ obligations, scan FPDS.  I quickly looked through many pages of listing and didn’t see any with money obligated on the basic award.

Good Lord!  I have a new appreciation for everyone.   I wish you would all think and read before you leap!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

I have not been hands on for something like 12 years after a 40 year career but I know this, your assertion to support a conclusion is out in left field.   Wanna try valid and honorable next?

The Federal Service Desk found here - https://www.fsd.gov/fsd-gov/answer.do?sysparm_kbid=ba5f91fb6f61a10003be658fae3ee4e0&sysparm_search=

(Emphasis added - I wish I knew how to use red bold font)

Answer :

FPDS-NG does not contain the following data elements. Contracting officers cannot put this information in FPDS-NG. Most of this data resides at the individual contracting office.

  • Subcontracting data from either the government or the prime contractors with whom we do business. The government does have a method to collect this data at www.esrs.gov. The two data sources work together.
  • Contract funding data outside of estimated totals and funds obligated on an action.
  • Contract accounting data.
  • Contract line item data is not in FPDS-NG. This includes specific information about the CLIN. There is no NAICS information at the CLIN level, no CLIN description, no CLIN funding data, and no appropriation data at the CLIN level.
  • No administration details including contracting officer’s technical representative names, wage determinations data, and details about the services via the contract number.

And formerfed please remember that it seems that most if not all, including myself, have agreed agency direction, absent direction otherwise, is authoritative. 

Definition of authoritative (https://www.merriam-webster.com/dictionary/authoritative)

 

1 : having, marked by, or proceeding from authority

Until you try again!!!!!!!

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Carl, you’re arguing against something I didn’t say.  What I said FPDS showed is all of the IDIQ contracts I scanned had no dollars obligated with the basic contract.  The money showed up on subsequent orders.  I know FPDS doesn’t show accounting and appropriation data but there’s no obligation with the contracts for the guaranteed minimum.

Accounting and appropriation data by itself without dollar amounts is meaningless because what does that do as far as obligation with showing the amount obligated?

I think this subject has been beaten to death.  I’m out and I learned something new too.

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1 hour ago, C Culham said:

I wish I knew how to use red bold font

On my laptop screen (but not on my mobile screen), there is a row of editing buttons at the top of the text input box.  It starts--

  • B     I     U ...

The next-to-last button (before "Size") has a Capital A, underlined, with a little down arrow the top-right corner.  That is where you can get different colors for text.

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19 minutes ago, formerfed said:

Carl, you’re arguing against something I didn’t say.  What I said FPDS showed is all of the IDIQ contracts I scanned had no dollars obligated with the basic contract.  The money showed up on subsequent orders.  I know FPDS doesn’t show accounting and appropriation data but there’s no obligation with the contracts for the guaranteed minimum.

AAccounting and appropriation data by itself without dollar amounts is meaningless because what does that do as far as obligation with showing the amount obligated?

Nice try.  Providing FPDS as a example is hollow.   I think neither you or I can help it if some one, or some ill designed system does not show the minimum as an obligation of an IDIQ.   Further it adds no substance to the crux of the discussion. 

For jollies here you go...........

IDIQs are reportable in FPDS.  (IDV)  https://www.fpds.gov/help/Reportable_Nonreportable_Contract_Actions.htm

IDIQs have a minimum obligation that is to be recorded.

IDIQs like any contract is to have their "obligation reported". (FAR 4.606)  And just in case if someone wants to bring up DoD then go here - http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/dfars/PGI 204_6.htm#TopOfPage 

ACTION OBLIGATION (Data Dictionary Element 3C)

This data element is required for all Awards and Modifications for both Civilian Agencies and DoD. It is not required for a Change or Delete/Void. Enter the net amount of funds (in dollars and cents) obligated or deobligated by this transaction. If the net amount is zero, enter zero. If the net amount is a deobligation, enter a minus sign at the beginning of the amount. See Data Dictionary Element 3C Use Case for appropriate data entry requirements.

Validation Rule 3C can be found at the following location: https://www.fpds.gov/downloads/FPDS-DES-SDD-validation_rules-DES.doc#_Toc204158310 

FPDS makes no exception to the validation rules for obligation amount for IDV. (Ref - FPDS Validation Document Competition)

3C       Dollars Obligated

Serial Number

Element/ Characteristics

Rule

Service Version

1

Format

Dollars Obligated must be currency - US Dollars.

1.0+

2

Award Type

The "Action Obligation" must be greater than or equal to $0.00.

1.0+

3

Reason for Modification

The "Action Obligation" must be less than or equal to $0.00 when the "Reason for Modification" is "Terminate for Default."

1.0+

4

Current Contract Value

The sum of Dollars Obligated for all transactions with the same PIID* must be less than or equal to the sum of Current Contract Value for the same transactions.

1.0+

5

PIID

If Dollars Obligated is less than $0.00, then the total of all dollars obligated for the same PIID* must be greater than the amount for this transaction.

1.0+

 

However FPDS allows it to be optional on the basis of an agency who uses a TO/DO to accomplish the minimum at award will not record the minimum for the IDIQ but as an amount (even above the minimum) for the TO/DO.  See page 225 of "GSA Federal Procurement Data System-Next Generation (FPDS-NG) Data Element Dictionary"   https://www.fpds.gov/downloads/Version_1.4_specs/FPDSNG_DataDictionary_V1.4.pdf (specific matrix not quoted here)

Try again!

 

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On ‎6‎/‎1‎/‎2019 at 6:20 PM, ji20874 said:

Well, you might not be able to figure it out, but the rest of our readers can.

Not this reader.  My opinion is that you are making artificial distinctions between "obligating" (or is it "funding"?) and "recording" (or is it "obligating"), based on a process time lag that may be milliseconds or...never...

Are you suggesting that people are making awards without fund cites?

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One has to appreciate the difference between creating an obligation and recording that obligation.  They are different — one happens in a contract, the other happens in the books of the agency.  Once one understands the difference, he or she will be able to figure it out.

Yes, it is very possible to create an obligation (such as by awarding an indefinite-delivery contract) and then to record that obligation without putting a funds cite in the contract — it happens all the time, legally and honorably.  

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