Mattt

You do have a point. Not to be rude, but DCMA no longer provides adequate contract admin and regularly declines contract admin. The services are own their own anymore for contract admin with no additional manpower.

The RFO release within the DoW (DoD) is a mess. The DFARS deviated the RFO on a rolling basis. When releasing an RFP, PCOs have to find the FAR parts that are deviated and update those clauses on the FAR and DFARS. The FAR parts that are not deviated, clauses from the old FAR are used. As of 17 Feb, the old FAR parts 2, 8, 15, 16, 42, 45, and 53 are still used. The other parts use the RFO and the deviated DFARS. Releasing an RFP right now is an adventure in the DoW. Using the RFO for some parts and old FAR for other parts is an absolute mess. Should have gone to RFO and new DFARS all at once. DPCAP and the policy makers do not have to deal with the consequences of their decisions. It is always execution that has manage and be responsible for policy decisions.

FAR 32.703-3(a) only applies to annual appropriations. 41 USC 3902 is the implementation of FAR 32.730-3(b) that authorizes agency heads to allow annual appropriations to cross fiscal years. Paragraph (b) and 41 USC 3902 only exists because of paragraph (a). If the appropriation is not annual then FAR 32.703-3 as a whole is not applicable. This makes 41 USC 3902 not applicable to an appropriation that is not annual.

This statement is not correct. IAW FAR 12.102(b), FAR 12 is used with FAR 13, 14, or 15. FAR 12 and 13 are used together when value is under $9M (FAR 13.500)(a)). FAR 12 acquisition values over $9M use FAR 15. FAR 12 cannot stand alone on procedures from pre-award to award It needs the FAR 13, 14, or 15 procedures as the vehicle to acquire the commercial item.

If you are referencing CMMC, it is ridiculous gov’t bureaucracy at its finest. CMMC is centered around protecting CUI. CUI is unclassified information. It is a waste of time and money.

Sam.gov also now maintains the database for DOL wage determinations and FASCSA orders. CPARS looks to be moving to Sam.gov. Sam.gov is ever growing. The issues I have with a fee for using Sam.gov is the gov’t uses SAM for its own internal purposes as much as for the public.

Here is another perspective based upon the OP scenario of the Offeror didn’t provide a price? Is the Offeror’s proposal non-responsive because not compliant with Section L in providing the required pricing information (obviously pending how the Section L was written)? For cost realism analysis of the Offeror, and the Offeror did price the material, was the evaluation team able to determine the cost realistic for the work to be performed, reflect clear understanding of the requirements, and consistent with the unique methods of performance on the material cost? If so, then met the criteria to determine probable cost. Otherwise, you are going into discussions.

Recommend reviewing FAR 32.703-3. Your agency most likely has guidance in its supplement at paragraph (b).

If you are in the DoD, new start may be reference to a new start program for RTD&E. Reference DOD FMR Vol 3, Chapter 6, paragraph 4.1.5.