rsmith

Thanks. Mostly worried about the CPSR team saying this is not sufficient.

They do SAM.gov checks before issuing the PO but do not get a certification ahead of time , other than yearly reps and certs.

Per FAR 52.209-6 (c)The Contractor shall require each proposed subcontractor whose subcontract will exceed the threshold specified in FAR 9.405-2(b) on the date of subcontract award, other than a subcontractor providing a commercially available off-the-shelf item, to disclose to the Contractor, in writing, whether as of the time of award of the subcontract, the subcontractor, or its principals, is or is not debarred, suspended, proposed for debarment, or voluntarily excluded, by the Federal Government. If we put the certification on the PO for the supplier to sign , but the supplier doesn’t sign the PO the day it was issued, is that a problem?

Thank you! that's very helpful.

The contract says any OT premium above $0 has to be approved. Originally my thought was that premium represented the portion above straight time, but reading through it again I can see how any OT pay, even straight time could be considered premium.

Just that O/T premium is direct, however in this case we wouldn't pay a premium, just straight time.

We have plenty of uncompensated overtime that's properly accounted for. However, this is a special case of an unexpected surge in workload where people that typically don't work much uncompensated O/T are going to be required to work extra hours and we would like to compensate them for it.

I've read the regulations and DCAA's CAM regarding overtime, but most of it refers to premium pay. On a cost type contract, is there an issue with paying exempt employees straight time overtime? These are salaried employees that typically work 40-45 hours a week, however for a few weeks they'll have to work 50-60 due to a surge in activity and some people leaving the department.

Thank you for the insight. It's going to be fixed going forward. For ICS purposes I think it can be claimed and we'll just have to see what happens if DCAA questions it.

A mixture of both. The majority were consumed during contract performance, however some such as furniture(that was purchased for use at space provided at a gov't site) would become property of the government once the contract ends or if another contractor is selected for future year.

I am having someone go through all of the purchases to determine what the risk is. It's a tedious process because you have to search the AbilityOne catalog. I can't imagine it being over $50,000 though.

What I pasted is the exact clause in the contract and was in the RFP. Supplies and services identified on the AbilityOne Procurement List must be purchased from AbilityOne participating nonprofit agencies unless a written exemption is granted by the Contracting Officer. The Procurement List may be accessed at: http://www.abilityone.gov/.

Thank you for your reply. It is a CPFF contract. A certificate was not submitted for the year I am preparing the incurred cost for because it was competitive. The proposal did not take into account the mandatory source of supply and materials were proposed based on quotes from other vendors. There are no critical parts involved, most of the items that should have been purchased from AbilityOne are office supplies, some office furniture such as chairs and mats, toner cartridges, and cleaning supplies. Yes, these are typically overhead but are direct on this contract.

I'm preparing an incurred cost for a client and when briefing the contract, noticed the following clause: Supplies and services identified on the AbilityOne Procurement List must be purchased from AbilityOne participating nonprofit agencies unless a written exemption is granted by the Contracting Officer. The Procurement List may be accessed at: http://www.abilityone.gov/. When I glanced through the material purchases, there were plenty that are available through AbilityOne. Does anyone know whether there are any penalties for not complying with this contract clause? Could DCAA question any material that should have been purchased through them? I have not seen this before. Of course I'm having the process fixed going forward but I'm not sure how much risk they have for the prior year and a couple of months of this year. Thank you.