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Nicole1986

ISR/SSR Reporting under IDIQs/TOs

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Hello all- 

Is Individual Subcontracting and Summary Subcontract Reporting (ISR & SSR) required for open Task Orders under Indefinite Delivery/Indefinite Quantity (IDIQ) contracts that have expired? I have an active task order under an IDIQ that expired years ago, and there are still subcontracting costs. Do I still need to report these or can I submit my final ISR/SSR reports and treat the subcontract reporting requirements as over since the IDIQ is technically over? 

Thanks!

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If the IDIQ is expired or technically over, why are you performing work? Why have you concluded the IDIQ is expired or technically over? What facts would you be reporting about the Task Orders? If you added the prior IDIQ related reporting facts to the facts you would report under the Task Orders, would that be the total cum reporting facts required to be reported by the contract clause for work under the IDIQ?

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I have determined the IDIQ end date because there was a 5 year period listed in the schedule. I am not sure why the federal agency issued a task order under this IDIQ after it expired (this was before my time at the org), but the Task Order references the IDIQ in the "Contract No." field of the schedule. And to answer your question abotu how I would report, yes, I would add the subcontracting costs from the Task Order to the cumulative numbers reported in the past for the IDIQ.

I have seen this on multiple occasions with our org's IDIQs and other Indefinite Delivery Vehicle (IDV) schedules - there are task orders that extend beyond the IDV end date. 

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We had an IDIQ contract that expired Sept. 8, 2018 and our USG customer awarded a Task Order Sept. 6, 2018 with Period of Performance to Sept. 2023.  Wording in the IDIQ is: "Pursuant to FAR 16.505(c) and 10 U.S.C. 2304b, the total ordering period of this contract, shall not exceed five years. The period of performance for individual orders shall be specified in each awarded order."                                               

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On 10/25/2019 at 1:50 PM, Nicole1986 said:

Hello all- 

Is Individual Subcontracting and Summary Subcontract Reporting (ISR & SSR) required for open Task Orders under Indefinite Delivery/Indefinite Quantity (IDIQ) contracts that have expired? I have an active task order under an IDIQ that expired years ago, and there are still subcontracting costs. Do I still need to report these or can I submit my final ISR/SSR reports and treat the subcontract reporting requirements as over since the IDIQ is technically over? 

Thanks!

I think what your company does, Nicole, depends on your company and the ACO view of the Task Order terms and conditions. If your company has determined that it has a contract for Task Order work but that work is not work under the IDIQ, then no ISR &SSR reporting is required unless there are ISR & SSR reporting requirements included in the Task Order as a separate contract apart from the IDIQ. I think that would not be a very reasonable business approach. One reason being, what are the terms and conditions? If your company has determined that the Task Orders are treated as being under the IDIQ (in essence that your company and the government can not deny that it is to be so treated even if the government may have made a contractual omission or mistake), then you should report ISR & SSR in the same way it was reported for other Task Orders that more clearly were issued under the IDIQ.

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3 hours ago, sjanke said:

We had an IDIQ contract that expired Sept. 8, 2018 and our USG customer awarded a Task Order Sept. 6, 2018 with Period of Performance to Sept. 2023.  Wording in the IDIQ is: "Pursuant to FAR 16.505(c) and 10 U.S.C. 2304b, the total ordering period of this contract, shall not exceed five years. The period of performance for individual orders shall be specified in each awarded order."                                               

Was that an option? Did your company accept the Task Order? Did the government offer its view about the Task Order POP? It appears that FAR 16.505(c) applies to advisory and assistance services only and there are exceptions to the 5-year limit. Was the IDIQ for advisory and assistance services work? 

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We accepted the Task Order and wanted it.  It includes providing some services and an option to provide additional product.

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It is for advisory/research services. There were no ISR/SSR reporting requirements at the Task Order level. What I wound up doing was submitting a final report, and stated in the notes section that our organization has interpreted that the reporting requirements are over, given the IDIQ has ended. I also pointed out that there was one open task order, but I have intepreted it to be a logical follow on and not subject to reporting under the IDIQ. The government accepted my report. 

 

Sorry for the double post, tried to delete but not sure how. 

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On 10/28/2019 at 5:08 PM, Neil Roberts said:

I think what your company does, Nicole, depends on your company and the ACO view of the Task Order terms and conditions. If your company has determined that it has a contract for Task Order work but that work is not work under the IDIQ, then no ISR &SSR reporting is required unless there are ISR & SSR reporting requirements included in the Task Order as a separate contract apart from the IDIQ. I think that would not be a very reasonable business approach. One reason being, what are the terms and conditions? If your company has determined that the Task Orders are treated as being under the IDIQ (in essence that your company and the government can not deny that it is to be so treated even if the government may have made a contractual omission or mistake), then you should report ISR & SSR in the same way it was reported for other Task Orders that more clearly were issued under the IDIQ.

It is for advisory/research services. There were no ISR/SSR reporting requirements at the Task Order level. What I wound up doing was submitting a final report, and stated in the notes section that our organization has interpreted that the reporting requirements are over, given the IDIQ has ended. I also pointed out that there was one open task order, but I have intepreted it to be a logical follow on and not subject to reporting under the IDIQ. The government accepted my report. 

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Thanks for the info, Nicole!

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8 hours ago, sjanke said:

We accepted the Task Order and wanted it.  It includes providing some services and an option to provide additional product.

good business decision, sjanke!

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