C Culham

Deleted. I overlooked the cost reimbursement part completely. How is anyones guess.

Using the most appropriate NAICS is important as well as it would hopefully equalize the competition amongst those most interested as it would hopefully reach those contractors that are usually doing the kind of work represented by the NAICS. Remember contractors can setup SAM creating search agent criteria for notification of a particular solicitation based on NAICS.

To accomodate the offeror yes but should you? Remember it is up to you, as the Federal agency, to make a determination of what NAICS applies to the solicitation. Take a read of FAR 19.102(b). And a further thought. If the originally listed NAICS is considered to be the appropriate one and the supplier might qualify under it but does not have it listed in SAM have both you and the supplier considered FAR 52.204-8 paragraph (d)?

WIFCON Terms of Use Rule 16. Abbreviations are to be kept to a minimum--preferably none at all--so that others can interpret a post and respond to it intelligently.

Interesting discussion. But considering the reference one would think that "somtimes" is not applicable to the use of "shall" in the FAR because "shall" as an imperative is manifest in the FAR. I guess I disagree based on my past experience as a 1102, 1101, warranted Contracting Officer and even within the historic bounds of WIFCON over the years wherein shall as an imperative was debated and/or abused (maybe even by me). Everyone has their own view. I do wonder what "shall"s and "must"s will disappear. After all "shall" appears eleven times in this EO “Restoring Common Sense to Federal Procurement”

No. Why? My view is while there is an element of risk aversion the biggest reasons are individual bureaucratic discreation and the continued meddling of legislative intent. I was around when the FPR became the FAR and have always viewed it as Federal Contracting For Dummies or as the quoted resource states better regulation of how to do the job. Legislative meddling often tells the practioner how to do their job because of some special interest(s) or otherwise unknowing legislative staffer thinking they know better how something should be done. I point to a subpart of a FAR Part already mentioned 16.505 and mulitple award IDIQs and fair opportunity. FASA demanded it in 1994 because contractors felt locked out of single award IDIQs. My personal view a complication added to a contract type that was working just fine. I would add here, in light of previous post, that FAR Part 16 carries 14 references to the USC. I have not researched in detail but it would seem per my reference to FAR 16.505 and a total of 14 USC references that FAR Part 16 does have some statutory context. To individual bureaucratic discreation in my view agency management and their CO's are always looking for something to work around a FAR requirement rather than just taking it in stride and making it work. Think mandatory sources and the Committee for Purchase from the Blind and Other Severely Handicapped. I do not believe that the intention that 100% of all needs of an Agency that can be satisified by a purchase via the manadtory source of the Committee is actually practiced because of individual bureacratic manipulation that is fueled by intended or unintended bias. Additionally there is the complication of the FAR supplements that moved individual discreation to agecny discreation because they think they know better or otherwise have acquisitions that support their missions muddled by legislative intent. Yes, as already implied it turned a muddled huge FPR into Federal Contracting For Dummies. In the beginning it was welcome relief, today it is equal to the FPR when it was tossed aside. How is "change" implied? A reformed FAR will hopefully shed much that is not needed, including its supplements and policy intended as psuedo supplements, and get back to the basics that provides the opportunity to everyone to compete for the almighty Federal dollar in an easily understood Federal Contracting for Dummies.

No personnelist here but the quote intrigued me so I did a little research. GS 1102's have been in the excepted service. By example see the following link to a Federal Register notice of 2021 by OPM regarding positions in excepted service Schedules A,B, & C. There are references to 1102's in the notice. On point to the original poster regarding Schedule F by my research F was what I will call "created" in the first Trump Adminstration and is being reignited once again. Up until 2020 when F first appeared there was Schedule A,B,C,D & E. The references I found for my conclusions was an array found in doing an internet search which also pointed to the fact that creation of Schedule F is pursuant 5 U.S.C. § 7511 .

https://www.federalregister.gov/public-inspection/current Includes the following - https://public-inspection.federalregister.gov/2025-06904.pdf (aka Improving Performance, Accountability and Responsiveness in the Civil Service) which is to be published in the Federal Register tomorrow April 23, 2025.

Thank you

Okay CPSR then I suggest you consider this guidance as to what your entity may or may not want to do. Page 24 starts discussion on Debarred etc. https://www.dcma.mil/Portals/31/Documents/CPSR/CPSR_Guidebook_091021.pdf

Play on words? Certification as opposed to a disclosure in writing as to is or is not. Seems due dilegence is occuring. A problem if the intent is not to give a PO to a debarred etc. contractor but if it happens then reporting per the clause seems to be the fix in my view. Once reported let the dice roll as they may.

Is there a reference that you can provide that this was going to occur?

I guess it depends on the context of "problem". Would you not request such certification prior to issuing the PO in the quote/solicitation process and do due diligence to determine if the certification is correct? Could not that certification have a statement of something like "Upon issuance of a purchase order in response to this request for quotation you the seller hereby certifies that upon promise to ship the goods or by actually shipping the goods hereby cerifies that is not debarred........" Noting that the ideal with regard to the clause is for a prime/subcontractor to report that the prime/subcontractor intends to use a lower tier subcontractor that is debarred etc. and it is determined post issuance that the contractor is debarred etc. the prime/subcontractor in the case of a "surprise" post issuance finding of a debarement etc. would be left to either canceling the PO or reporting per the clause.

Rescinded and now be reignited. Here you go - https://www.whitehouse.gov/fact-sheets/2025/04/fact-sheet-president-donald-j-trump-creates-new-federal-employee-category-to-enhance-accountability/ @Dugtastic Anything is possible but it would appear from the Fact Sheet that the rank and file 1102 is not in consideration.

To bolster the responses with references that may be of interest. As noted most agencies have a policy relating to warranting. Many refer to it as the "Contracting Officer Warrant Program" or something close. You might take a look internal to your Bureau to see what you can find. You might also take a look at OFPP Policy Letter 05-01 "Developing and Managing the Acquisition Workforce." Here is an interesting quote from it. "The GS-1102 federal acquisition certification is not mandatory for all GS-1102s. However, members of the workforce issued new CO warrants on or after January 1, 2007, regardless of GS series, must be certified at an appropriate level to support their warrant obligations. New CO warrants are defined as warrants issued to employees for the first time at a department or agency. This requirement does not apply to senior level officials responsible for delegating procurement authority or those whose warrants are generally used to procure emergency goods and services." And from my experience. GS-1105, 1101, 1106 and from the series 0800 have had warrants.