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Everything posted by Cajuncharlie

  1. Thanks, jtolli! My IE 7.0.5730 at work could not get to any of the other lynx, but this works.
  2. Contract type? Sounds like T&M or Labor-Hour but can't assume. What is the specific question? Usually on this forum it's somebody else who asks. Discussions often take off on tangents, and it's hard at least for me to guess which ones will peter out quickly and which ones have proverbial legs, but my impression is that it's hard to get one cranked up without a clearly stated question.
  3. Even in these days of sophisticated automation, there are times when it takes days for an incurred cost to hit the system and become visible to more than the few who are directly involved with it, so the timing of the sweep has to allow for such trailing costs.
  4. Every place I've worked as a contractor, the practice has been to certify cost or pricing data after, and as of the date of, the handshake on price. Actual submittal of the certificate then follows a sweep.
  5. Often it takes a while for an incurred cost to wend its way through a company's books. In theory it could take twice as long if it starts at the subcontractor company, goes through that maze to the piece of cheese at the end that's the invoice to the prime, then has to go through a similar maze at the prime before it's billed to the Government. When did the prime incur the cost? Most likely it was indeed within the period of performance. Is it billable under the prime? Depends on when it was truly incurred. Modify the prime to extend the period of performance just to allow payment of a trailing cost? I hope not.
  6. Looks like another case of the law of unintended consequences, where a clause intended to fix a perceived problem creates a new problem. Unfortunately it also looks like the only way to deal with something like this is to game it by throwing a few hours in the pot so you can get credit later for the occasional few hours of UCOT. It does not sit well to have to game a situation just to receive credit for work performed.
  7. No joy. Got the usual certificate error, but our system gives certificate errors even for some websites of our company's software providers, then allows access. I will put in an IT work ticket and see what happens.
  8. Oyster, can't even get that far. Edited to insert: On the PC, can't get there, but on the BlackBerry, no sweat. Don't know if it's the Army firewall, my company's firewall, or the combination of them. Too weird! But on the PC, both the short link and long link get me this: Internet Explorer cannot display the webpage Most likely causes: You are not connected to the Internet. The website is encountering problems. There might be a typing error in the address. What you can try: Diagnose Connection Problems More information This problem can be caused by a variety of issues, including: Internet connectivity has been lost. The website is temporarily unavailable. The Domain Name Server (DNS) is not reachable. The Domain Name Server (DNS) does not have a listing for the website's domain. If this is an HTTPS (secure) address, click Tools, click Internet Options, click Advanced, and check to be sure the SSL and TLS protocols are enabled under the security section. For offline users You can still view subscribed feeds and some recently viewed webpages. To view subscribed feeds Click the Favorites Center button , click Feeds, and then click the feed you want to view. To view recently visited webpages (might not work on all pages) Click Tools , and then click Work Offline. Click the Favorites Center button , click History, and then click the page you want to view.
  9. Bob, See Randy's post above. I can get there by BlackBerry, but not by PC. Don't know if I'm blocked by DAU's firewall, my company's, or the combination of the two. Too weird.
  10. Good question. I was sure I had it, but my old bookmark is to a bad link, and "I've searched the world over" without success, just another bad link at http://www.acq.osd.mil/dpap/cpf/contract_p...ce_guides.html: "The Guides are posted at the Acquisition Community Connection (ACC), under the Contracting ACC Practice Center, here." Wikipedia's link to the Acquisition Community Connection shows a padlock and an https URL. Of the two co-authors, a search on the AFIT site yielded no hits; and a search on the FAI site circled back to the URL pasted above, with a bad link. Glad I downloaded them in December 2005 because they seem to be hiding these days.
  11. Can't get there. Can't even get to the first part of the URL, ending in .mil. Suspect there is more going on in the cyberbackground since the URL is secure (https).
  12. No vote from me because the answer would depend heavily on the facts and circumstances giving rise to the doubling of the contract value, and even then there can be a lot of room for interpretation. On one hand, being within the "general scope" as required for directed changes by all versions of the 52.243-x Changes clause is not that high a bar. On the other hand, doubling in value passes a traditional rule of thumb threshold for a cardinal change.
  13. From a 7/27/11 email. Used to get lots, but none since this one. Maybe you can find a better link from this one. The Naval Sea Logistics Center, Detachment Portsmouth is pleased to present a series of one-day training seminars on the use of the Contractor Performance Assessment Reporting System (CPARS). The seminars will cover the CPARS module of the system, which is used to assess contractor performance on contracts for systems, services, operations support, and information technology. The training seminars will be offered on August 23, 24, and 25, 2011 at the National Institutes of Health Clinical Center, Bethesda, MD. The CPARS training seminars are open to all attendees free of charge. Please visit http://www.cpars.gov/allapps/cpartrng/CPAR...thesdaAug11.htm for additional information or to register for the training. As space is limited, please register by August 17, 2011. You will be notified of additional CPARS seminars via email as they become available. Online training is also available at the CPARS web site. CPARS has been designated as the Federal solution for reporting of contractor performance information. Whether you are new to CPARS or are looking to expand your knowledge of the program, the CPARS training seminar offers an exceptional learning opportunity. Benefits of the program include facilitating government-contractor communication, motivating improved contractor performance, and preparing contractor report cards to be used in support of Government source selections. Topics to be covered during the seminar include CPARS policy, workflow process, automation, new features, and helpful hints for using the system. Both Government and Industry personnel are strongly encouraged to attend. Please note that this training covers the CPARS module only. The Architect-Engineer Contract Administration Support System (ACASS) and Construction Contractor Appraisal Support System (CCASS) modules (covering contracts for architect-engineer and construction) are addressed in separate training.
  14. Farparts, I feel your pain, as I suspect many of us do. Once upon a time, in a land far, far away, I worked for a private foreign company where my boss was a retired local Air Force Brigadier General, with USAF training, and many years of contracting experience dealing with original equipment manufacturers, major aerospace companies. In dealing with our internal customers, he had an expression: "We will support you, in the proper way." In the private company where I work now, thankfully back in the US of A, most of our internal customers and senior executives rely on us contract administrators, managers, and directors to keep them out of trouble with the compliance folks or auditors, colloquially to "keep them out of jail." Then there is the old saw, "If you don't think you have enough time to do it right the first time, what makes you think you will have time to go back and do it over?". Hope this gives you some ideas of an approach to people who have no patience with administrative procedures required by law or regulation.
  15. A subcontractor to a Government prime is usually performing that subcontract in support of a Government contract, and this could be confirmed if the wording of the subcontract includes specific reference to the prime. Also bear in mind the word "exclusively" in the FAR paragraph means that to fit the definition of subcontracts excluded from the review, the scope of your subcontract you received from your prime customer would have to be in support of no other effort but the prime contract. For the second question, "Government contracts that are competitively awarded... or ... commercial..." means prime contracts. So if your prime customer's contract from the Government was (1) competitively awarded and is FFP or FPEPA type, or (2) was awarded for commercial items using FAR Part 12 procedures, a review of the prime's Purchasing System would not normally include the subcontract the prime issued to your firm, provided the scope of that subcontract is "exclusively" within the scope of the prime. Otherwise, the scope of the prime's CPSR would include the prime's records of the prime's subcontract to you. Others may have more learned responses, but this is my $0.02 worth from past CPSRs and a careful reading of the FAR.
  16. Having worked overseas for many years, for both US and foreign contractors including overseas subsidiaries of US companies as well as truly foreign owned companies, and dealt with them both as a prime and sub on US government projects on both sides of the table, my thoughts are mixed. My views are limited by my personal experience, but I do have some, including work in contingency situations. Adding another level of contracting bureaucracy above the working level in country would be useless, or worse, for the reasons that Vern noted, among others. How would the contract specialists and officers on the ground be helped by having more bosses? The proposed requirement for foreign contractors to consent to US jurisdiction is problematic. Many foreign contractors, at least before the boom days in Iraq and Afghanistan, disregarded the bulk of the terms and conditions and homed in on the basics: what must I do or provide, and how will they pay me. They generally considered that host country common law would prevail because they could bring disputes to host country forums, which often had a dim view of any jurisdiction but their own. More recently such forums have begun to give more weight to the express terms agreed by the parties, but that view must overcome a long tradition of belief that the foreign (non-host country standard) parts of a contract don't count.
  17. "Where can I find the rules...?" In our company, such rules are in our disclosed cost accounting practices. "Are there issues to be aware of?" Consistently following disclosed cost accounting practices might be one, or in the absence of a disclosure statement, consistency in cost accounting. To repeat a cliche, a good motto is charge where you work and work where you charge.
  18. If you want or need more control over subcontract pricing, use the Subcontracts clause from FAR 52.244-2. Is that what you were missing?
  19. I'm looking now at a major federal construction contract with no final completion date. It happens. (It does, however, have some milestones and a 20-page schedule specification.
  20. Excellent advice from many, but here are a couple of points to offer a different perspective from the school of hard knocks. The word "accelerate" is dangerous when talking about what should be framed in terms of a recovery plan. "Accelerate" is not in the clause, and carries immediate connotations that may tend to invite a claim. Bear in mind that a contractor with performance problems will be looking for every opportunity for relief that does not hit the bottom line, and may be likely to cast blame, sow confusion, and take advantage of every poorly worded client communication. Directing a contractor to "recover and maintain schedule progress" more precisely describes what is contractually required, carries no risky or potentially inappropriate tone, and does not need to be turned off. Another danger is to direct the contractor how to recover. Even though the clause allows it, directing means and methods should be a last resort. It's more prudent to offer examples of actions or approaches that the contractor should consider in formulating the contractor's recovery plan. These things can be discussed as possible choices for the contractor to make, but the tendency to step in, take charge, and tell the contractor how to fix his schedule problems should be resisted. Directing means and methods of recovery buys a piece of responsibility for the recovery plan and schedule progress or lack of it, which responsibility should remain clearly with the contractor. My $0.02 worth.
  21. Just to clarify, 52.215-22 is the solicitation provision that requires certain information with a proposal related to pass-through charges and puts offerors on notice of the rules; -23 is the corresponding contract clause dealing with the same subject and lays out the rules that apply during performance. Provisions and clauses are not identical, although the distinction is not always clear or understood. The commercial world sometimes calls provisions "instructions to bidders" and "information for bidders." Others may have better definitions or examples, but I believe this covers the basics.
  22. I will probably continue to provide "irrelevant" information on the theory that sharing information in response to a muddled queston is better than stepping back and telling somebody there is not enough information to provide a meaningful answer. In this case, it was a principle that has been accepted by government reviewers, so at least there would be something to go by. Also please note my continuing advice to RTFC (read the f-f-f-full contract) and reminders that I'm a four corners of the contract kind of guy, which in hindsight I might have repeated here, although that was covered by agreeing with Joel (all of his post, since no exceptions were mentioned).
  23. On ways to improve the relationship, although I am no longer a government employee, strongly recommend a meeting or teleconference between Legal and Contracts to discuss items under review. Even before Legal reads all the way through a review package, Contracts can provide background and context to help Legal more quickly grasp the situation and better understand issues or concerns. Contracts can provide a summary of issues or concerns, and steps to resolve or mitigate them. Legal can ask questions or raise points that Contracts either may not have considrered, or can brief Legal on how they were addressed. The process should include an opportunity for real dialogue that makes the difference between individuals working with the same documents and individuals working together on those documents.
  24. Agree with Joel. Where I work, our practice is to charge only contract-specific training to a contract, whether reimbursable or FFP (FFP would be an internal accounting exercise, but that's how we charge), and it has to be very specifically required by this particular contract. Training, for example, in Microsoft Office, or Primavera, etc. would be charged to overhead.
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