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    The Accordion
  1. Quick Reaction Capability - I can see that relating. We'll see.
  2. Bending the Cost Curve: "A targeted initiative that can be accomplished within current Air Force budget programs" and "different than past initiatives in that the Air Force is looking at very specific, albeit large, programs": http://www.defense.gov/news/newsarticle.aspx?id=123974. Excerpts: 1. The initiative aims to improve dialogue with industry, “so we can better understand how processes, procedures, and some of the choices we make can inadvertently contribute to rising costs, the stifling of innovation and slow processes." 2. "We think that by gathering data from a range of sources, it should be possible to identify instances where small changes in capability have large impact on cost." 3. “Under our new PlugFest Plus approach, we will put in place a mechanism whereby a vendor could walk away with a contract just a few weeks after an event." 4. “What we’re really after here is a data-driven approach to spending.”
  3. Who would enter the "zeroes"? My experience in relation to timekeeping and DCAA leads me to the conclusion that more important than having time filled out every day is that the employee certifies that time. I have known DCAA auditors to be understanding of off-site employees having their time-sheet filled out by an admin as long as it is approved after the fact by the employee. Your explanation that these are part-time employees who have not started work that week should be sufficient.
  4. I work for a prime contractor. One or more of these offerors may have chosen to go sole/single source with a "commercial" subcontractor. It could be that procurement at the offeror was prevented from competing the subcontract by engineering or the program office. If you are not satisfied with the analysis performed by the offeror's procurement (e.g. no subcontract competition), you may run into a wall with the offeror's procurement. Like Don explained above, you can use your leverage of competition at the prime level to encourage the offeror (i.e. the program office and upper management) to re-consider any sole/single source commercial decisions.
  5. Do you agree with the prime contractors' conclusions that the proposed subcontracts would be commercial? Are the proposed subcontracts for items of supply or services?
  6. Yes, Thank You, Vern. I would cut FAR 15.404-3( b ) for sure. Based on this paragraph at least some auditors think that prime contractors have to "comply" with the FAR to perform price/cost analysis (outside of a contract provision). I would also cut DFARS 244.402(a). Based on this paragraph at least some prime contractors mistakenly assume they have final authority to determine subcontract commerciality irrespective of what the government contracting officer says. DFARS case 2000-D028 shows otherwise on the first page at the bottom of the middle column (http://www.federalregister.com/Browse/Document/usa/na/fr/2002/5/31/02-13358).
  7. FAR 15.408, Table 15-2 I.A.(8) asks the offeror to disclose if its proposal is not consistent with FAR 31 cost principles. FAR 52.215-12(a) requires prime contractors to require subcontractors to submit certified cost or pricing data in accordance with Table 15-2. However, I have never seen a subcontractor disclose that its FFP proposal is inconsistent with FAR 31 cost principles. Any inconsistencies are handled in negotiations. When I first saw the above question, I thought, "Table 15-2", but then I thought about what could happen if there was not a standard format. GAO issued an interesting report in April 2014 on "Reexamining Regulations" http://www.gao.gov/assets/670/662517.pdf. My concern is that Table 15-2 is part of those regulations being re-examined with the Better Buying Power initiatives and government budget constraints.
  8. Is your concern that G&A is only applied to material handling by Company B? Provided the company discloses that its value-added base includes material handling (but not direct material), there should not be a problem with the above accounting.
  9. Have a good week-end, Vern. I hope you enjoy putting up with people like me as much as I enjoy learning from you and other posters on WIFCON. Thank You.
  10. I think it would be a false claim if the contractor somehow claimed on its invoice that it had actually repaired 450 vehicles (when really it was only 350 vehicles). But if the contractor disclosed that it had only needed to repair 350 vehicles and still submitted an invoice for $400,000, I do not see how (at least yet) that would legally be a false claim. If the contractor submitted an invoice for $400,000 without disclosing the number of vehicles repaired, the government might try to prove some kind of wrong-doing under those circumstances. All these scenarios would arise after contract award.
  11. I think metteec is getting the conversation back on track after my detour. Vern, I agree with you that my statement about your opinion on moral obligation was broad. I assumed that if you made an absolute statement about moral obligation for one scenario, that statement would apply absolutely to all moral obligations. Again, thank you for the clarification and additional opinion.
  12. Without an explicit argument on your part, I don't think there is very much more to discuss about your original statement. I disagree with your implicit argument and your opinion about moral obligation. You made an absolute statement about moral obligation in the last part of Post #2 without qualification. However, your most recent post makes it clear that you meant all of your original statement to be qualified as simply your opinion. Thank you for the clarification. I agree with you that there is no legal obligation for the contractor to disclose the government's error back to the government.
  13. I agree. I am persuaded (convinced) that there is something more that people's opinions. I hope you were really saying that any moral obligation is a matter for another discussion (rather than a matter of opinion). Without absolute truth (wisdom) your argument (and mine) is circular.
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