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  1. I concur with Vern. That process creates the appearance of an employer/employee relationship with contractor personnel. The government contracts for the overall service, not with individual contractor personnel. When individual contractor personnel have their time cards signed by the COR rather than the government reviewing and approving the contractors invoice in its totality, it gives the appearance of an improper personal services contract.
  2. One of the most significant risks would be exposing the government to liability as if the contractor employee were a government employee. A court would look at the totality of the circumstances in determining if a contractor employee should be treated as a government employee in a labor related litigation matter. All of Vern's questions are relevant. See Harris v. Attorney General of the United States, D.D.C. Civil Action No. 04-220-3.
  3. Vern, The Acquisition Center for Excellence in Chantilly,VA seems to be currently functioning and has what looks to be a full time staff (at least it appears that way from the "Contact Us" portion of their website). https://acq.westfields.net/contacts/ace.aspx I was also able to stumble upon some type of flyer from 2010 that would have you believe that there are ACE reading rooms in California, Colorado, and Texas as well. Not sure if those locations are still in existence. http://nrojr.gov/about/business/bus-2010-01.pdf I hope that helps.
  4. I also know of no such reference. Lets not forget however, that most of these systems (FPDS, CPARS, PPIRS, FAPIIS, SAM, etc) are interrelated, though they may be managed by different entities (GSA, NAVSEA, etc.). First, when placing an order against a GSA schedule look the vendor up in GSA e-library. For instance, if you search Booz Alen Hamilton, you will see that they have numerous GSA FSS contracts. Many of those are under different DUNS numbers. When you look up your vendor in GSA e-library be sure to find the particular corresponding contract, select the vendor and copy the DUNS number under which the contract was awarded. Next go to SAM and search by DUNS only. You will find the correct corresponding CAGE to that DUNS. If you do this when awarding TOs/DOs against a GSA FSS (and I assure you it only takes a minute or two), you shouldn't run into your particular problem anymore.
  5. Duke38, I concur with Vern's #11 response. I am curious whether the vendor clearly marked that the vehicle they were quoting was open market, or, if that was something you discovered when comparing the quote to the vehicles on their contract.
  6. Jamaal, Your query is slightly confusing. The FAR doesn't compel contracting officers to use PPIRS. FAR 9.105-1(c ) requires ("shall") contracting officer to consider information in FAPIIS when making a determination of responsibility. It also encourages ("should") contracting officers to use additional sources of information to support their responsibility determinations. Many of the examples you list would fall into the sources of information listed in the FAR at 9.105-1(c ). It's not a matter of what information a contracting officer "would want" to make a responsibility determination, its a matter of what sources a contracting officer "should" consider when making a responsibility determination. Also, terms of art are important when asking questions. I've never seen the FAR or an agency supplement refer to a determination of responsibility as a performance confidence assessment.
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