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NewbieFed, As you engage on this matter, remember that you must discern that there is a difference between IGCE, IGE, estimate, should-cost, and so forth -- some precision is terminology is helpful. Your OP asked about an IGCE, and that is the question I addressed. Can you tell the difference? If you are still looking for the "Independent" element of an IGCE, ask yourself why you are wanting it. For a example, if market research of automobile dealer quotes tells me a certain vehicle's price estimate is $45,000, why in the world would I insist that your program office develop an "Independent" estimate? Remember, you cannot find a FAR citation requiring an IGCE for a non-construction procurement. So, do you want really insist on an IGCE (without a regulatory basis), or do you simply need a reasonable estimate for approval thresholds and clause prescriptions? If the latter, why aren't contractor quotes adequate? But as I said earlier, regardless of what is written, if your reviewers are simple-minded and wrongly taught, as you were, they may still demand an IGCE even without any supporting citation. Best wishes.
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"I've gone through what I believed were the relevant parts of the FAR - FAR 13, FAR 8, FAR 16, FAR 7, etc. and did not find anything requiring an IGCE." Well, then, you have your answer. Reading is powerful! Yes, you were wrongly taught (at least for the FAR level). Prospective contractor quotes are ideal for estimates for approval levels and clause requirements -- the gold standard! Your price reasonableness exercise will begin only after you receive prices in response to your solicitation, and you will have many tools to determine price reasonableness at that time -- so you need not be worrying about price reasonableness now. If you still want to force your program office to do some extra work to make your reviewers happy, read up on should-cost analyses (not IGCEs) and see if that will meet your need. But regardless of what is written, if your reviewers are simple-minded and wrongly taught, they may still demand an IGCE even without any supporting citation. Best wishes.
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"I was always taught..." Perhaps you were wrongly taught? If you are making an assertion that an IGCE is required, you should be able to find a citation supporting your assertion. If there is no citation, well, then there is no requirement. I think you were wrongly taught, if you are talking about the FAR level. Of course, I cannot speak to all the agency supplements (or to your agency supplement, since you haven't identified your agency). Besides, why do you want an IGCE? What useful purpose will it serve? If you need some estimate for approval thresholds and clause selection, it seems to me that contractor quotes are sufficient for that purpose. I encourage you to read the FAR for yourself.
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The contract is already formed and agreed to. If you want something different for a task order, will you try to negotiate that with the contractor? Maybe the contractor will agree, maybe for an additional price -- but if the contractor won't agree, are you asking if you can unilaterally impose the requirement with the next task order?
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Prove the Objective Truth of this Quote
ji20874 replied to WifWaf's topic in Proposed Law & Regulations; Legal Decisions
Joel, Are you trying to make a case for a change? Fine with me if you are, but I don’t think Wifcon.com is where you need to make your case. -
GSA is offering something for the optional use of other agencies. Any agency not liking GSA's ordering guidelines can establish its own no-cost contract. If GSA's ordering guidelines say considering past performance is required, then it is required -- and it's required because the ordering guidelines say so. To me, the OP's demand for a FAR citation seems inappropriate.
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Atlas says, "52.246-2 is present and I understood the requirement to perform periodic inspections as required by the government. Again, I do not read anything in there that says they have full run of the facility at any time (e.g. they have access to those areas necessary to inspect at a negotiated time)." FAR 52.246-2, para. (c), says, "The Government has the right to inspect and test all supplies called for by the contract, to the extent practicable, at all places and times, including the period of manufacture, and in any event before acceptance. The Government shall perform inspections and tests in a manner that will not unduly delay the work." Atlas, I think you may err in your thought that the Government must negotiate with you for inspection times. Doesn't the clause that you agreed to allow the government, as the buyer, to have largely unfettered inspection privileges?
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Carl is right, that the AFARS only requires IGE for procurement actions over the SAT. But even then, the AFARS text provides some appropriate flexibility -- for example, the text speaks of "...enough detail to verify..." and "...sufficient narrative and analytical detail..." -- perhaps the people you are dealing with have an understanding of "enough" and "sufficient" that differs from yours? I hope with professionalism and appropriate discretion you can solve your problem. You might note that the AFARS does not require "detailed" IGEs -- you are introducing the word "detailed" as an adjective for IGE. The AFARS merely requires an IGE with "enough detail" and "sufficient narrative" -- do you see the difference? For a very routine buy, there could easily be a dig difference between "enough detail" and "detailed IGE."
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Multi-year and Multiple Year Funding FAR Part 17
ji20874 replied to Maquoketa's topic in About The Regulations
Don, Thanks for asking your question. I gave too much benefit to the original poster. Based on OP’s answer to your question, he or she has no business in FAR 17.1. -
Multi-year and Multiple Year Funding FAR Part 17
ji20874 replied to Maquoketa's topic in About The Regulations
I recommend a conversation with your agency’s procurement executive of HCA (head of the contracting activity). Persuade him or her or your approach directly if possible. The statute behind FAR 17.1 uses the following text: “…funds are available and obligated for the contract, for the full period of the contract or for the first fiscal year in which the contract is in effect, and for the estimated costs associated with a necessary termination of the contract…” -
Government Mandated Travel Accommodations and Rates
ji20874 replied to ReadTheContract848's topic in Contracting Workforce
If we knew what the XYZ guidelines were, we might be able to be helpful. But still, even if the XYZ guidelines do not require staying on base, do they allow for staying on base? If so, maybe the agency's direction is "in accordance with" the guidelines. -
Certainly, what you are suggesting is doable. There is no rule to prohibit it, and there is no rule to require continuous service with no breaks when exercising options. You can set up the contract to meet your needs. For example, can you easily imagine a janitorial services contract for a school with annual POPs from August to June, with each option period starting in August? Why are you concerned that it might not be possible?
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Really? We know that all offerors will have their recent past performance in CPARS? I disagree. Offerors with excellent past performance for non-federal clients (and therefore no CPARS records) should be encouraged to participate in the federal procurement process. Banning them because of no CPARS seems like professional malpractice.