CuriousContractor_22

Thanks for your help @C Culham and @formerfed. The GSA site I used to think mentioned everyone needed the same SIN. Might be wrong. I will reach out to GSA to triple check.

Does anyone know if all members of a Contractor Team Arrangement (CTA) under GSA MAS must hold the SIN a procurement came out under? We heard that only the CTA team leader required the GSA MAS SIN and all other CTA team members just needed a GSA schedule even if they did not have that SIN. There is a debate if this is correct since some believe all members of the CTA must hold the GSA MAS SIN the procurement came out under. GSA's site on CTAs did not seem clear on this so any help would be great.

Thanks, @Neil Roberts. This is superb. I appreciate it. Is it reasonable to assume the subsidiary should give their rates at-cost to their parent company and any fee/profit the parent company earns on the subsidiary is then shared with the subsidiary? Re: a teaming agreement or CTA where both have their own GSA schedules with terms and conditions, it sounds like that is a battle for the parent/subsidiary to hash out, right?

Hey everyone, new situation for me: a parent company and one of its various commercial subsidiaries are working together on a GSA MAS task order. The parent company is leading the task order but wants complement their bid with their commercial subsidiary's personnel. I was wondering: Would the parent company map their subsidiary into their GSA LCATs/rates? If the parent company is mapping subsidiary personnel into their rates, would the subsidiary be able to include fee/profit in its rates to the parent company? Or would the subsidiary have to provide rates to the parent company without fee/profit? If both the parent company and the commercial subsidiary have GSA MAS contract, could they enter into a CTA so that both can earn their own fee/profit? I feel like I'm overthinking this, so appreciate the help and guidance. Thanks all.

Very late to the party, but wanted to mention from industry perspective. My two cents: I am not against protests nor the GAO in principle since they do have value, but I am against protest trolls and terribly devised procurements. I have encountered protest trolls that love to whine to hold up the government and the awardee. I don't know how to hold these firms accountable since they often have deep pockets to litigate anyone into oblivion. Maybe DoJ handling it would help over GAO? The other underlying thing here is how the Government holds agencies accountable for having procurements that are a hot mess (case in point is CIO-SP4) or use terrible evaluation tools (GSA CALC). Can the Government fine itself aside from suggesting they pay for costs of an protester's protest fees?

Thank you @bob7947!

I know of sources like BLS, GSA eLibrary, USAspending, etc. but want to expand my resources. Are there other publicly available sources you all use for developing an independent cost estimate, especially labor pricing, indirects, fee/profit, FCCOM? Thanks!

Apologies @formerfed let me clarify first: yes, I meant T&M task orders under GSA Schedules. I have seen under the ANCILLARY SIN indications "markup" on ODCs negotiated on a vendors' schedule. This caught my eye and made me curious if fee/profit was acceptable on a T&M task order under GSA MAS as long as it is negotiated under something like the ANCILLARY SIN. @Retreadfed referenced FAR 52.232-7(b)(2), which states "(7) Except as provided for in 31.205-26(e) and (f), the Government will not pay profit or fee to the prime Contractor on materials" - this is what I was thinking about with the Government not allowing fee/profit on ODCs on T&M task orders under GSA MAS.

OP, I may have missed context. Is this related to establishing a GSA schedule, bidding on task order, establishing a BPA? Regardless, I would agree with what others have suggested here as well as mention that everyone approaches discounting differently and there may not be a one size fits all approach. Some choose to discount their schedule rates as low as possible and not discount further on orders while others provide heavy double digit discounts on some LCATs and modest discounts on others.

I know fee is not allowed on ODCs for T&M contracts, but can contractors negotiate fee/profit or some sort of markup on ODC special item numbers like ANCILLARY? Are there certain exceptions like if they are selling an off the shelf product?

Thanks for the insights and indulging my curiosity @General.Zhukov. I appreciate you and everyone's help walking me through this.

That makes sense, @General.Zhukov. It sounds like universities can comply with timekeeping for T&M/LH work and primes can be compliant but may require discussions with offices like the one you mentioned at Johns Hopkins. Even if they do not track time like a GDIT there are ways to work with them to track time on specific projects. Is that understanding right?

Your conclusion seems spot on, @C Culham. That "or" seems critical. How could a prime invoice the time a university spent if the university does not document their hours per person? Would the Contractive Officer or authorized representative be able to allow a prime to guesstimate? Is it safer to require the university to track their time per person in a spreadsheet?

Thank you for the input, @General.Zhukov! When working with IHEs with LH and T&M MAS contract orders , have you run into any issues remaining compliant with time keeping due to the issues I alluded to above? Or have they found a way to remain compliant despite not being required to record time daily in a time keeping system?

Thanks for the info on OMB Cir. A-21; I did not realize that it was replaced. The context on the adoption of the cost principles in 2 CFR 200 is very helpful. Thank you!