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  1. Thanks for the response, Formerfed. We are hoping for the JV to have an 8(a) status to pursue 8(a) opportunities. I don't believe a CTA with a firm that is not an 8(a) would afford the same status. But it is possible I am missing something. If we form a CTA with the 8(a) protege as the "Team Lead", I am not sure if the CTA can pursue 8(a) procurements ?
  2. Thank you for the response. I already reached out to our SBA rep and he mentioned that the rules are changing and the process is less onerous in terms of documentation for SBA after 11/16/2020. And, I read the FAR clause you described, multiple GSA websites and material and also multiple posts on this forum and still didn't receive the answer. I sent a note to our SBA rep this morning asking the question directly - after reading your post. But if anyone on this forum has experience dealing with MAS schedule through a JV, I was wondering if they can chime in. Thats all. Thanks again
  3. Good afternoon. I am asking this question in the context of the recent SBA JV rule changes and also with the GSA MAS schedule consolidation happening in parallel. Context and background 1. We are a protege in a SBA-approved Mentor-protege relationship. The mentor is a firm that graduated from the 8(a) program and is a mid-size business now 2. Both the mentor and protege have our own GSA schedules and we are delivering on contracts awarded through the GSA schedule to each of the firms individually. 3. We recently decided to form a Joint Venture and have signed a Operati
  4. Hello, I need some help from the FAR and pricing experts. This has been an old topic on this forum and I found other threads on it - about how much G&A can be applied on subcontractor costs and not seem "excessive". This post I found is the most detailed and on-point in my mind - https://graniteleadershipstrategies.com/government-contracting-when-to-add-a-subcontract-handling-pool/ So, here is a situation. Lets say we are a small business prime with a significant G&A rate (we are in our growth phase). Can we apply a lower G&A on our subcontractors to be competitive on a C
  5. It is definitely a sad state of affairs. I am not sure what is causing this level of significant delay after the law has been signed back in 2013! I can only imagine the comments on the proposed rule must have been overwhelmingly strong and would encourage the FAR council to move forward. I found this FAR timeline image and it hurts me to say that it doesn't look like the change will be implemented until 2020 - are you guys reading this differently? The change from interim rule to proposed rule (again!) put us back by 18-20 months!! Image for the FAR Timeline
  6. Thank you Joel and Pepe - appreciate the response. The fact that it was published on the "FARsite" made be think if it applies to all contracts where FAR clause is included. I didn't know FARsite language applies only to DOD contracts. If the FARsite is not right place, where is the "system of record" for FAR? Also, does "class deviation" only apply if someone within the department sends a letter like the DoD one? I am trying to figure out who to hound next 🙂 EDIT - May be this is the place? https://acquisition.gov/content/52219-14-limitations-subcontracting
  7. Don, based on the fact that the FARsite has been updated with the class deviation, does this mean this language will apply to all federal contracts? Thank you
  8. You said the "most recent version" of the FAR but this class deviation was only incorporated effective 12/4/2018 (and thank you for pointing that out!). This particular sentence is what I am looking at - " Services (except construction), it will not pay more than 50 percent of the amount paid by the Government for contract performance to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count toward the 50 percent subcontract amount that cannot be exceeded;" What is the legal standing of a "Class deviation". Does
  9. No problem Neil and it is probably my mistake. Other than following this particular thread for purely selfish interests, my interest and knowledge in FAR updates is minimal and I probably used the wrong words. But this is what I was referring to - https://www.federalregister.gov/documents/2014/12/29/2014-29753/small-business-government-contracting-and-national-defense-authorization-act-of-2013-amendments " Specifically, the NDAA provides that a small business awarded a small business set-aside, 8(a), SDVO small business, HUBZone, or WOSB/EDOSB award “may not expend on subcontractors
  10. Thank you. This means that the new "proposed rule" published will go through its own publication life cycle (may be 6 more months?!) and departments/agencies can create such deviations in parallel. They already published this proposed rule earlier and received feedback - I wonder why they had to do it again!! Sigh!!!
  11. Thank you. Can you please be kind enough to translate this for me. What does this mean - "DOD Class Deviation"? I am assuming this applies to all federal contracts effective immediately or am I interpreting it wrong? But how is this different making the change the "final rule" instead of "proposed rule" ? Thanks again.
  12. Hello, Looks like there was an update on the "limitations on subcontracting" clause on the open far cases update on Friday. Can someone please help me interpret this? Does this mean they are issuing another proposed rule and will collect comments again (frustrating!). Should we look for this now on the federal register or will there be any more steps before it gets there? Thank you for the feedback. EDIT - I found this on the federal register posted yesterday with a reference to the FAR clause ("Introduction to the Unified Agenda of Federal Regulatory and Deregulatory Actions-Fall 2
  13. Just a quick update. I talked/emailed the House Small Business Committee to see if they heard from OMB (the letter states that they would like to get the response by 9/28). I received a response very quickly that they are still waiting to hear back from OMB. At least, someone is monitoring the situation. Also, does the change to "proposed rule" from "interim final rule" mean that they would be publishing the rule for public comments again? If that is the case, this another year long process!
  14. Thank you Jamaal. Halloween came early in the Xanadu household. I found this image on the FAR timeline. With the change from being "final rule" to "proposed rule"- did the process go back by 40 weeks? See the screenshot below about the FAR secretariat - they take 6.5 weeks! This is after OIRA clearance. Considering this became proposed rul nowe, did the process go back to the first Secretariat reference below and will be asked for public comments again (another 9 week process)? I thought we are past that!! BTW Admins, this image could help others too and might help if it a "sticky" post o
  15. "hopping mad" is an understatement! I was finally seeing some progress for the past couple of months but now, like the letter pointed out, they changed it to proposed rule from final rule. Frustrating. There was a cryptic update in the latest open far cases report from yesterday - " 09/25/2018 Proposed FAR rule to FARSEC for preparation of FR notice." whatever that means ! I have been venting about this in a separate thread and I just posted there. Got to admit - that was a very well written by the committee!
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