Contracting1

The SF 182 saga continues. This question is directed more towards those of us involved with DON Policy. The current GCPC policy (4200.99A) states regardless of dollar value when terms and conditions are used, a contract should be written. The question is: Can the instructor be paid using the SF 182 when the normally commercially available class will be given outside the United States and it's outlying areas? Or would you consider the travel piece now becomes some sort of a term and condition and a contract should be written regardless of dollar value. My first thought is it shouldn't matter where that curriculum or class is being taught, it's still a commercially available class and no other terms or conditions should apply and the SF 182 can still be used. However, recent discussion with some of my counterparts think otherwise as they believe the travel to somewhere outside the United States and it's outlying areas is something that no longer makes it commercially available and therefore requires terms and conditions. Any thoughts?

What if the SF 182 is used to pay for the contractor to come to your location instead of the Government employee going to theirs? Meaning, Government travel card is not an option.

Have a few more SF 182 questions. 1. Would you consider "commercially available" training to be conducted overseas, still "commercially available"? For Example: Company A provides this trianing/curriculum to the general public as well as the military. However, the military has asked Company A to conduct the training outside of the United States. Does this mean the training is no longer "commercially available" and the training should be done on contract vice SF 182? 2. The SF 182 has a block for travel. Does this mean that travel can be included with the training but the total expense cannot exceed $25k? I personally believe it would not be included in the form if it wasn't authorized. However, some are under the impression as soon as travel is included, it now requires terms and conditions and contract should be written.

I do realize the SCA doesn't apply in Japan. I'm more or less concerned with training requirements that take place in the states as I have been in discussion with my highers stating we wouldn't have been given the authority to use SF 182's up to $25k if SCA applied. I just couldn't find anything to support my reasoning. I think I have it now. Thanks all!

Ladies and Gents, You'll have to excuse me as I'm new to this site. I'm currently located in Okinawa, Japan and have come across a ligitimate question raised by a fellow contracting officer in the contracting community. The question is... Does the Service Contract Act apply to training when the training is ordered by use of the SF 182/GPC? If so, is it already incorporated into the document and if it is, where can I find it? If not, under what authority does the Government have the right not to use the SF 182 for training under $25k on and the Service Contract Act not apply? Any input would be greatly appreciated!