Background: I work for an enterprise software company. For new software acquisitions under either our Schedule 70 or channel partners IDIQ vehicles, the government requires our implementation services which are typically 90 days or less in duration and where we use our best practice guides.

Our rates are calcuated against our GSA labor rates/categories.

Since there is no formal SOW written by the government, can these type of services be bid T&M or must they be FFP.

It depends on what the solicitation (RFQ or RFP) says. When in doubt, ask the CO at the issuing office.

Interesting you would use your Schedule 70 labor rates to calculate estimated labor costs for your channel partners ID/IQ contract vehicles. I hope your cost estimates are below the TINA threshold.

H2H

Are we still allowed to say TINA? Or must we say Truthful Cost or Pricing Data?

Imho the people who foisted these new names on us should have kept the old names, unless they are deliberately trying to confuse us. I plan to stick with TINA.

Yeah, this old dog has trouble learning new tricks. Or else it's more important to correctly communicate that to use the correct terminology.

Those are my rationalizations and I'm sticking with 'em.

H2H

See the bottom part of the second paragraph in this DAU article. What do you think? It looks like 10 U.S.C. 2306(a) is going to stay "TINA" for DoD.

https://dap.dau.mil/career/cont/blogs/archive/2014/05/12/title-41-changes-to-the-far.aspx