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ji20874

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About ji20874

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  1. Wage amount is irrelevant for determining wage application. Rather, it is the nature and purpose of the work and the employee that matter. If a brain surgeon was doing brain surgery work at $20/hr, it would not be SCA because brain surgery is not service work done by service employees.
  2. When FAR Part 12 was drafted back in 1995 or 1996, the drafters and others associated with them did not consider a building to be a commercial item or construction to be a commercial service -- so from that perspective, NO, FAR Part 12 does not cover construction. And Vern is right -- FAR 52.212-4 is wholly inappropriate for construction -- I actually think FAR Part 36 is good for construction. But FAR parts 13, 14, and 15 may all be used for construction under the general oversight of FAR part 36.
  3. Erin, You are asking important questions. If your discomfort is causing you to ask questions, and if you are learning, that is good. As you ask questions, you might realize that you may be carrying a lot of baggage unawares -- many 1102s do -- maybe you will be able to shake it off. One thing that has been important to me is the knowledge that even if an agency or office practice is inartful, inefficient, unnecessary, or even wrong*, at least I want to know the difference in my own mind. * Here, "wrong" isn't intended to mean illegal, unethical, immoral, and so forth.
  4. Thanks, retreadfed, for the pointer to the old language -- yes, that it exactly what I was thinking. Thanks, Vern, for the pointer to the old CFR text page -- I added that to my bookmarks.
  5. Retreadfed, I am intrigued, but you are asking for something that is beyond my capabilities -- I don't know how to find the 2012 version of 13 CFR 125.6(e)(7).
  6. formerfed, Isn't it good to have competitors who already understand all those things? They might have an advantage, but it need not be an unfair advantage. An outsider might have some other advantages, and it all works out in the competition.
  7. It is okay for non-1102s to serve as ordering officials. This works especially well for (1) purchases against FAR Part 13 BPAs and (2) orders against single-award indefinite delivery contracts, but can work in other ordering situations as well. It is WONDERFUL that you are using the GPC for purchases up to the SAT against pre-priced contracts! The card-holders may be non-1102s. When these purchases are made against schedule contracts or indefinite-delivery contracts, no pre-solicitation synopsis is required. When ordering against multiple-award IDIQ contracts, there is no need t
  8. Right. And the paucity of meaningful information from the original poster requires a lot of interpretation, supposition, and so forth from anyone here who wants to be helpful.
  9. I read, "...the idle charges for keeping the people on standby was paid..." -- but the contractor may have paid its employees on its own initiative to retain talent. Really, I don't know if that blurb means (1) the contractor paid its employees; (2) the Government paid the contractor; or (3) something else.
  10. My first question would be whether the stop-work order was actually issued under the clause at FAR 52.242-15. If NO, then the equitable adjustment provision of that clause does not apply. If the stop-work order was issued under some other authority, then one must look to that other authority to see if there is any remedy.
  11. I have done this for an RFP. The classic case is contracting for environmental impact statements. If the program has a reasonable amount budgeted for an EIS, it is best to tell offerors -- it will help offerors scope the content of their proposals and will allow for the best possible selection. If the budget estimate is too low, offerors will say so and the agency can adapt. If the estimate is too high, many offerors will propose lower prices and/or lots of value. In procurements like this, sharing the estimate even shapes the playing field -- some excellent companies will f
  12. Do you want the business? If so, participate in the process in good faith. Best wishes!
  13. Partial set-aside won't work, because partial set-aside contemplates multiple awards. Through this thread, we have been talking consistently about a single award to a prime contractor with directed subcontracting. If possible, we would like to do it as a set-aside.
  14. There is nothing untoward here -- just exploration. I have no objection to an individual deviation to apply the limitations on subcontracting only to the management portion of the work (the work that is actually performed by the contractor), rather than the pass-through subcontracting where the prime contractor has no discretion. If we don't do something differently, then we'll have to do this as an unrestricted acquisition even though small businesses certainly can do the management work -- and that is the reason for this discussion. We want to set the terms of the contract so that sma
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