Don Mansfield

You think the DAR Council doesn't coordinate their FR comments with the Director of DPC?

Completely agree.

Why not submit a nonmonetary claim? If the contract said that a certain type of work would be competed exclusively among the awardees of Pool X, but the contracting officer instead competed that work among the awardees of Pool Y, then that would probably be a breach of contract--right?

So the financial systems can't accommodate bulk funding (FAR 13.101(b)(4))?

How about "lab supplies as-a-service"? In other words, you pay a contractor to maintain prescribed stock levels over a period of time.

1. A profit exceeding 10-15% is not necessarily unreasonable. The Weighted Guidelines method is required in some instances for the Government to arrive at a prenegotiation objective, but it does not limit what a prospective contractor can propose. It has as much relevance to the negotiation as the method the prospective contractor used to develop their prenegotiation profit objective. As far as what the contracting officer said about the board, that may be true. But that doesn't mean you have to lower your profit. The Government will need to decide if what they need is worth agreeing to what they consider an unreasonable profit. Is the Government ok with your bottom line price? 2. See FAR 31.205-7 regarding the inclusion of contingencies in cost estimates.

17.205 is preaward.

DoD uses the clause at DFARS 252.204-7022, Expediting Contract Closeout.

@chadinark If you want to demonstrate knowledge of the FAR, then I would recommend getting a CFCM from NCMA.

No need for a written determination and I see no benefit in doing one. Condition yourself to avoid red tape whenever possible.

Well, ASN(RDA) relieved STRL from the burden of the making the determination. How do you think they would react if you did it anyway?

I'm confused, too. It doesn't make sense. Having said that, I think the deviation relieves STRL from having to comply with FAR 7.107-2 for contracts < $50 million.

Yes, you can--by conducting discussions and getting revised proposals.

Why would these be FAR/DFARS clauses? Why wouldn't the prime use its own payment clause?

I think I wasn't clear. I was referring to the list of FAR/DFARS in the subcontract--not all clauses.