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About p5tMike

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  1. Your questions have definitely added to my list of concerns. Payments based on system information is definitely not something I want to bring into play (would be absent a proper demand for payment and likely Prompt Payment Act issue). The scuffed knee scenario is on-target with my concern - reliability of data provided to contractor for invoicing - whether accurate, shorted or fluffed. In the spirit of risk - I'm concerned that providing data is a risk to be avoided and should be lessened by only reconciling a claimed set of values.
  2. Thank you. Error on my part - should have read -33, not -32 in that payment clause reference.
  3. Ji20874 - The question of timely is another struggle I didn't mention. -->I'm thinking that tying a NLT date into the billing language is appropriate, but concerns of recourse if/when NLT date gets busted. -->The rates would be per a unit of measure other than hours, more of a "production" type of structuring based on cost per code values (numerous codes, with significant variation in values). -->Yes, regarding customary - after posting the question here, I received information that the practice is the same in the commercial marketplace. Retreadfed - (kudos to the screenname,
  4. Looking to see if any experts can get me in the right direction. I have a service acquisition where billing doesn't appear it can "normal and as usual". The contractor would do it's work in a Gov't facility, using Gov't space & equipment. However, the workers (medical) are not involved in tracking aspects of work performed. Instead, the work performed is maintained (coded) by Gov't in Gov't systems that cannot be accessed by contractor. Thus, it appears that contractor would only be able to invoice according to data fed to them by the Gov't. I'm struggling with - 1) can this be done?
  5. It's FFP type Retreadfed, and correct, the language doesn't specifically state the issue; and Vern - you are correct I was quoting some standard verbiage from delegation formats. Thanks all for the information. I think I have enough to rely on now regarding the matter. Again, thank you all. Mike
  6. A typical delegation includes a statement saying "the COR CANNOT "make any agreement with the contractor requiring the obligation of public funds......." and ", or in any way obligate payment of funds by the Government"". I interpret that signing time cards are inconsistent with both of those 2 stipulations.
  7. Thank you Vern, PTaylor and BowtechDan - each of you confirmed my position on the practice. Now, to make such a widespread practice stop - it won't be an easy tasking at all.
  8. Vern - no, the contract doesn't require to sign time cards. The label is shown in the attached. The companies are essentially requesting the Government perform their administrative/supervision/payroll function from what I observe. Retreadfed - they are non-personal, as stated in the award documents. PTaylor - my position is that the signature obligates the signer to verification of time. But worse, in my opinion, it eliminates Government ability to argue if outside observers, i.e. other physicians, etc., make claim on non-attendance. Additionally, my position is that the signing
  9. Can anyone provide information regarding risks related to a Government employee signing a timecard (as if the Government employee were a supervisor)? I'm finding instances where Contracting Officer's Representatives (CORs) have been signing timecards for doctors or related contractor-provided personnel (whether they are an employee of the contractor, or acting as a subcontractor). The then-signed timecards are then sent to the company by the contractor employee. I'm concerned about risk, but I'm not finding any significant supporting information about the does-and-don'ts about this practice
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