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Member Since 08 Dec 2008
Offline Last Active Nov 27 2015 10:24 AM

Posts I've Made

In Topic: Official FAR Site

17 April 2015 - 02:39 PM



The only reason I caught those differences is because there was some debate at my agency as to whether a Limited Source(s) Justification should be labeled a "Limited Source Justification" or "Limited Sources Justification".  Yeah, I know it is minor, and there are much bigger things to worry about, but it was just something that came up one day, and I discovered the difference between the two websites.  It does make you wonder if there are other differences however, and if maybe they may be more significant.  I know of no one who uses the acquisition.gov website for FAR research, and everyone I know uses the Air Force site.  Even when I went to DAU training, they gave us the reference to the Air Force site.

In Topic: Official FAR Site

17 April 2015 - 12:59 PM

Has anyone noticed any discrepancies between the acquisition.gov and FARSite versions?


The FARSite version has two paragraphs for (d) under 8.404.  The second (a deviation) may result from DoD Class Deviation 2014-O0011 at 8.403, but I'm not sure.  Further, the wording and inclusion of that deviation is odd for the FAR (versus DFARS).  Is the FARSite inappropriately and/or unclearly inserting DoD information into the FAR?

I don't know if I would call them discrepancies, but I have noticed differences.  For example, compare FAR 8.405-6.  On the Air Force site it is titled, "Limited Sources".  On the acquisition.gov site it is titled, "Limiting Sources".  Similarly, see FAR 8.405-6©(2)(i) which, on the Air Force site, says, "...and specific identification of the document as a “Limited Source Justification.”"  On the acqusition.gov site it reads, "...and specific identification of the document as a “Limited-Sources Justification.”".  Those are just a couple of small variances I have noted.  I like the Air Force site better, as the font is larger, which is easier on my old eyes.

In Topic: Prohibiting Contractors From Proposing as Prime and Subcontractor

06 March 2015 - 09:02 AM

Thanks for the input Jacques. Based on the research I did, I could find nothing that prohibited restricting a prime from also being a sub to another prime in their proposal. But you did bring to light some interesting information with FAR Subpart 9.6. You bring up a good question regarding, "Can a sub team with multiple primes?" I also asked myself that same question yesterday. While doing my research I did find some GAO case law regarding subs teaming with multiple primes. These cases generally involved the requirement for Certificate of Independent Price Determination (FAR 52.203-2), and allegations of price collusion. I think Don asked the question that gets right to the point; What would be your justification for including the restrictive provision? My recommendation to my boss was that we not do it, unless we have some valid reason to do so, which I do not know about.

In Topic: Prohibiting Contractors From Proposing as Prime and Subcontractor

05 March 2015 - 11:33 AM

Thanks for the input Retreadfed.  This requirement is for IT support services. We expect ro receive numerous proposals, so I do not expect that we will receive a proposal from a vendor as a prime, who would also be the sub on a large number of the other proposals. Therefore adequate price competition should not be an issue. 


I asked my boss why would we want to prohibit a vendor from submitting as a prime, and also be a sub on a different vendor's proposal, and her response was , "why would we not want to prohibit it?"; find some justification to prohibit it.

In Topic: Prohibiting Contractors From Proposing as Prime and Subcontractor

05 March 2015 - 11:13 AM

Thanks Joel. We have thought about the conflict of interest issue, but isn't that a contractor issue for them to sort out, versus something the government needs to be concerned with?