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Prime Contract Number


secaucus

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As a subcontractor, we receive DPAS-rated orders from a number of DoD primes. In some cases, we are a third or fourth tier subcontractor. We dutifully pass down the DPAS rating to our subs. No problems there.

The issue is that a number of our contracts with the primes do not provide a Govt prime contact number in their PO to us. Many of the buyers we deal with either aren't sure of the prime number or they indicate that there are numerous prime numbers because of the various funding sources. In most cases, they ignore our requests and we don't get the number.

However, our in-plant QAR continues to issue CARs because our POs to our subs do not flow down the prime number. Typically this is just on rated orders but not always. The issue has now intensified to the point where the QAR will not allow us to ship, even though it's a rated order.

Is there a regulation that requires primes to flow down the Govt prime contract number? If the prime does not provide, what recourse does a sub have?

Thanks

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Guest carl r culham

Quick read without researching the FAR in detial and related DoD supplements is that prime contract numbers, for the most part, are public information. In fact you can find most award notices, with contract numbers, on FedBizOpps. You might try asking the contracting agency that awarded the contract to the prime for the number.

Also I am surprised that you do not insist as subcontractor on having the prime number referenced in your subcontract before you even begin work. From my view this is just good business.

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Guest Vern Edwards
As a subcontractor, we receive DPAS-rated orders from a number of DoD primes. In some cases, we are a third or fourth tier subcontractor. We dutifully pass down the DPAS rating to our subs. No problems there.

The issue is that a number of our contracts with the primes do not provide a Govt prime contact number in their PO to us. Many of the buyers we deal with either aren't sure of the prime number or they indicate that there are numerous prime numbers because of the various funding sources. In most cases, they ignore our requests and we don't get the number.

However, our in-plant QAR continues to issue CARs because our POs to our subs do not flow down the prime number. Typically this is just on rated orders but not always. The issue has now intensified to the point where the QAR will not allow us to ship, even though it's a rated order.

Is there a regulation that requires primes to flow down the Govt prime contract number? If the prime does not provide, what recourse does a sub have?

Instead of asking for a regulation that requires primes to flow down their contract number to you, why don't you ask your QAR what regulation requires you to place the prime contract number on your rated orders to your subs? There is nothing in 15 CFR 700 that imposes such a requirement. On what basis is your QAR writing you up? Tell him or her either to show you a regulation or a contract clause or stop issuing CARs.

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Quick read without researching the FAR in detial and related DoD supplements is that prime contract numbers, for the most part, are public information. In fact you can find most award notices, with contract numbers, on FedBizOpps. You might try asking the contracting agency that awarded the contract to the prime for the number.

Also I am surprised that you do not insist as subcontractor on having the prime number referenced in your subcontract before you even begin work. From my view this is just good business.

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I recognize good business practice and we do ask and usually get the prime number of 90+% of the orders. There are instances where we are third tier subs and our customer doesn't know or doesn't care.

Having said that, there's a big difference between good business practice and mandatory flow down. If mandatory, what's the reference?

Thanks

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Consider what this may mean to a wide selection of involved parties:

?700.91 Records and reports.

(a) Persons are required to make and preserve for at least three years, accurate and complete records of any transaction covered by this regulation (OMB control number 0694?0053) or an official action.?

Many years ago, , , , and my first real ?run in? with the DPAS Regs. . . .

We in procurement were working on a REALLY HOT JOB, but we did not know it because; the customer ?did not exist? and the contract number was CLASSIFIED. And as such there was no contract number loaded into the system and, also as such, there was no DRAS Rating loaded into our system. ?Only Government Contracts can have a DPAS Rating? etc. . . .

We routinely worked on DO and DX jobs so this ?non-government, non-rated? job was solidly on the back burner. That is until the CUSTOMER started asking what was taking SO LONG. ?So long, why? This is a non-gov, non-rated job!?? Holy bat spit Batman!! We came to find out that the job was in fact DX, and otherwise spoken about in official circles as being the real ?Brick bat? thing. We received all of the ?special assistance? you?d never want to ask for. We had ?professional? instruction in regard to what to say and how to say it when we called up our suppliers to place orders and otherwise expedite existing orders. There were direct threats to impose the full force of law to get things moving.

When all was said and done the nice folks at Commerce, FEMA, and the Customer were kind enough to give all of us some all day, mandatory, remedial, training in the fine art of DPAS.

We later found out that the ?job? was in fact a major discussion point in the President?s morning security briefings and that our ?delay" was holding up a "mission" of the gravest type. I don?t want to know what it was.

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