As stated in FAR 12.207(b') T&M/LH contracts may be awarded under commercial services (of course, meeting all the stipulations); however, it appears the offeror must still propose strait rates (i.e. separately identified rates to the entity or affiliate performing the services) as required in soliciting services, under FAR 52.216-31, "the offeror to specify whether the fixed hourly rate for each labor category that applies to labor performed by-- (1) The Offeror; (2) Subcontractors; and/or (3) Divisions, subsidiaries, or affiliates of the offeror under a common control." Now, with that nonsense said, 71 FR 74672 explains the intent of the FAR council's conformity with commerciality when the council stated there is to be single schedule "...without listing the subcontracts when the contractor's established catalog or market price includes the price of its subcontracts..." (My attempt to simplify the term "single schedule" for blended or non-blended catalog price/rate.)

To what extent is this clause used for if the market factors already constrain unreasonable prices; thus, there is no need to identify it separately. The use in which the clause (i.e. FAR 52.216-31) reads, it conveys the need for separate rates. First, when is this clause applicable? Second, what protection if any does it offer the Government in identifying who is performing the work and if blended or non-blended (i.e. strait) rates are proposed? To answer my own question, maybe the Government wants to know specifics for repricing future orders under indefinite delivery contract through FFP rather than T&M/LH.

Maybe I'm missing the point and the "and/or" allows for identifying the players participating or associated with the rates and not specifically identify the entities or affiliates strait rates. I find myself in circles on this matter, so if you have wisdom to share, please expound.

You may dispute my use of the word "strait" in this context, but I was only playing on words to mean strait at cost from the entity or affiliate performing the task/job.

I doubt you meant "strait." I suspect you meant straight. Unless, of course, "strait" was part of your play on words. Always check spelling when pontificating.

I am looking for someone that can enlighten me on the clause 52.216-31 purpose and use since commercial rates would necessitate a single prime schedule. What am I missing? My limited research has provided me with little comfort on its use. I?m struggle with the way it?s worded in connection with commercial ideology.

Why doesn?t it mention the use of blended rates like 52.216-29? Maybe there is no need to spell it out because any commercial item implies market controlled factors.

For the instructions about the appropriate use of FAR 52.216-29 and 52.216-31, see FAR 16.601( c )(2) and (e).