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IFF on ODCs


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I know that IFF is not due on ODCs and travel on GSA Schedule orders if they are not included on your Schedule, but can someone point me to the case law or provision that states this? I can't seem to find anything in the GSAM or other regs that states this. How was this determined to be the case? Thanks!

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Guest Vern Edwards
I know that IFF is not due on ODCs and travel on GSA Schedule orders if they are not included on your Schedule, but can someone point me to the case law or provision that states this? I can't seem to find anything in the GSAM or other regs that states this. How was this determined to be the case? Thanks!

Did you try reading the IFF clause in the schedule--552.238-74? It tells you what reportable sales include. IFF applies to reportable sales. The standard version in the GSAR says:

Reportable sales under the contract are those resulting from sales of contract items to authorized users unless the purchase was conducted pursuant to a separate contracting authority such as a Governmentwide Acquisition Contract (GWAC); a separately awarded FAR Part 12, FAR Part 13, FAR Part 14, or FAR Part 15 procurement; or a non-FAR contract. Sales made to state and local governments under Cooperative Purchasing authority shall be counted as reportable sales for IFF purposes.

That appears to exclude sales of non-schedule ODCs. The GSA website about 72A Quarterly Reporting, http://72a.gsa.gov/ifffaq.cfm#16, answers a FAQ as follows:

17. Is the IFF applicable to additional contractor expenses such as travel on service contracts?

The IFF is a simple application of the rate to the sale. If a contractor makes a sale of contract items under a Federal Supply Schedule contract, the IFF applies. However, if the contractor doesn?t record compensation for additional expenses as a sale under the GSA contract, then the IFF should not be applied.

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Did you try reading the IFF clause in the schedule--552.238-74? It tells you what reportable sales include. IFF applies to reportable sales. The standard version in the GSAR says:

That appears to exclude sales of non-schedule ODCs. The GSA website about 72A Quarterly Reporting, http://72a.gsa.gov/ifffaq.cfm#16, answers a FAQ as follows:

Thanks Vern--- do you know if there has been any cases on the topic? There seems to be disagreement regarding the interpretation of the clause. I too read the clause to limit IFF on "Schedule" items and know that it is understood as well by GSA that non-schedule items do not incur IFF, but I was wondering if there was something directly point to that effect.

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Guest Vern Edwards

I searched and found a total of 14 court and board decisions that mention the IFF, mostly board of contract appeals decisions going back to 1999. Not one dealt with your issue. Please don't ask me to type out a list. If this is a serious issue for you, then I suggest that you retain an attorney. Good luck.

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