Don Mansfield

Good question. I think it depends on whether the engraving is a modification to a product meeting definition (1) of commercial product. I don't think modify is synonymous with change. The American Heritage Dictionary defines modify as "to change in form or character." Does the engraving change the form or character of the knife? I don't think so.

I missed that the over and above work was for "repair parts." That's not how I think of over and above work as contemplated by the DFARS.

I agree that's a great question. I don't have a thoughtful answer. As for the concern that AI is making us dumber, I'm not so sure. I observed my son using ChatGPT to write a paper for his high school class. There was definitely creative thinking as he continuously revised his prompts and critical thinking as he reviewed each new product to see if it was any good. I certainly didn't think he was cheating.

Good question. Maybe people are using ChatGPT to get their questions answered. We may have outlived our usefulness, @formerfed .

I think the OP is asking if he can fund the over and above work before it has been identified. I also question when over and above work--as defined at DFARS 252.217-7028--would be considered severable.

Has the over and above work been defined? Or do you obligate a lump-sum and reconcile after ordering the over and above work?

I don't understand the question. FAR 17.204(e) has to do with options. The OP didn't say the contract had options.

I give him credit for soliciting informal feedback on LinkedIn.

I don't know for sure, but I don't think purchasing "commercial coworking space" is leasing real property. It's more like purchasing hotel accommodations.

What do you mean by "new start requirement"?

No, and I wouldn't expect more than "read your contract." If the contract includes FAR 52.229-3, Federal, State, and Local Taxes, then the contractor could be compensated for an after-imposed federal tax. This includes duties (a tariff is a type of duty). Here's a good analysis: https://www.insidegovernmentcontracts.com/2025/03/the-trump-tariffs-and-federal-contractors-in-these-taxing-times-contractors-have-a-duty-to-know-these-five-things/

Do you mean something like Regus?

@Matthew Fleharty What is your opinion of DoD Instruction 5000.66, DEFENSE ACQUISITION WORKFORCE EDUCATION, TRAINING, EXPERIENCE, AND CAREER DEVELOPMENT PROGRAM? Do you think the instruction is to blame at all for the state of the DoD contracting workforce? Or are the problems all in the execution?

"After “the basics,” the recurring standard for workforce development is to spend merely 80 hours on continuous learning over a two-year period that consists of 4,160 work hours—at that rate, people spend more time at work going to the bathroom than studying their profession." 🤣

@formerfed That's just the line-out version. It doesn't show the additions. I can't attach the line-in line-out version here because it's too big, but you can see it here: https://www.linkedin.com/posts/donald-mansfield-181b6425_compare-docs-version-of-current-and-proposed-activity-7325645767174410240-oB6w?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAVVFfEBGwwV9lul0QXOYxogw54s42KVA9c

I think it's supposed to be STD ZD072. I don't know what the code means, but DLA uses it when referencing a Hazard Communication Standard notice in solicitations for batteries. The notice requires submission of Safety Data Sheets to the contracting officer. Is FAR 52.223-3 in the contract?

This particular entry is getting pounded by Russian bots. @Linda Day

I wonder how an offeror's proposal would differ using one authority vs. another. Would they have different proposals for different authorities (i.e., OTA price, FAR-based contract price, etc.)? That would interesting to measure.

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That jumped out at me, too. I'm going to submit a comment on the importance of that statement.

Now on Spotify.

Vladimir, please stop

One is a contract clause and the other is an activity. I think you need to work on your question.

Nice work

New EO: https://www.whitehouse.gov/presidential-actions/2025/04/restoring-common-sense-to-federal-procurement/