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Everything posted by woops85

  1. Not DoD vehicles but usable by DoD (KO must get a Delegation of Procurement Authority in some cases) From GSA - Alliant SB - VETS (all are SDVOSB) - 8(a) STARS - Can do small business set-asides or preferences under GSA Schedules From NIH - CIO-SP2 (has some SB awardees) - Army's ITES-2S (from PM CHESS) has 3 or 4 SB awardees
  2. I need to clarify - I should have said "Various local misinterpretations of this policy exist"
  3. Original policy memo from DPAP is 29 Oct 04 and can be found at http://www.acq.osd.mil/dpap/cpic/cp/intera...cquisition.html. It's the various ways that the policy has been interpreted at the local level that introduce, IMHO, the prospect of wasting scarce acquisition workforce resources
  4. Philosophical Question - Do the various interpretations of Agency policies on interagency acquisition cause waste? For example - DoD policy states that you must prepare a written justification that doing an interagency acquisition (either a direct acquisition using another agency's vehicle or getting assisted acquisition support) is in the best interest of the program. Various local levels interpretations of this policy exist, ranging from the original "this means we can't use GSA Schedules anymore" to the recently heard "your assisted acquisition procurement can only have a Period of Performance of one year while a DoD contracting shop does a longer procurement for you". Let the opinions fly!
  5. Under certain PM CHESS contracts, such as ITES-2S, the primes are required by the vehicle's terms and conditions to use other PM CHESS contracts as primary sources for any Tools/Equipment buys. There is also a limit on the fee that a prime can put on the Equipment purchased. PM CHESS also does consolidated buys where they negotiate discounted pricing. It would be worth the client's (or your) time to call PM CHESS and speak with one of the KOs there about what they can/cannot do for your client. For $40-50M of hardware, saving even 1% in fee is worth the call. I've always found them very willing to help
  6. Since I'm not sitting in during the negotiations, I can't say if the way you phrased it is right or wrong. Perhaps the agreement was reached and the vendor shows it on their invoices as ODCs because their accounting systems can't handle billing it as labor without adding all the same burdens. But I'll ask them
  7. Thanks here_2_help for my daily laugh. I nearly fell out of my chair reading this.
  8. Good Morning - our shop manages several contracts with folks stationed overseas who are entitled to COLA. For the T&M contracts, the KO negotiated an "overseas" labor rate since most of these are Schedule orders and the vendors' schedule specifically stated rates were for work in CONUS. For the Cost Plus type contracts, we tend to negotiate COLA/HOLA into the ODC bucket. Although it's a labor cost, we negotiate it to ODCs so the vendors cannot burden it with fringe, OH, etc - generally only G&A. Since the fringe burden tends to be in the 25% range and overhead can easily be 40% or more, this results in a decent cost savings that our KOs can achieve for our clients. The practice is not part of any written policy - just a shared practice among most of the KOs.
  9. Seen this happen multiple times esp for contracts supporting a software development project. Have one that does IV&V on the SW development effort. Client sent OMA since to them wasn't actually the development of the SW (which they knew should be RDT&E). When they did review with budget office to get funds for option, budget folks told them that IV&V could be funded with RDT&E. Since OMA dollars tend to be scarcer, they sent RDT&E for rest of contract. I think it was 2 years ago that Army budget folks started taking a really hard look at the color of money that folks were using to fund certain types of contracts. While the review was completed back then and guidance issued, it has taken a while for the word to get out to everyone
  10. If the percentage for the award fee pool was agreed upon during negotiations, but the pool was never funded, won't the IG say you were Anti-Deficient? As the KO, did you ever appoint award fee board members? I'm assuming what the contractor proposed was the Service Level Agreements that go into the award fee plan. I'd agreed at this point that best bet is to do the bilateral mod and go to CPFF. CPAF is a culture change for many organizations and the Government needs to be ready to exercise its obligations to make it work. Maybe the group will be ready when you put the next one in place
  11. Most non-competes are written in a way that the court won't uphold because they are too broad. BUT contractors performing acquisition support better be signing non-disclosure agreements or else we're going to spend all our time dealing with procurement integrity/perception/protest issues instead of making smart business arrangements.
  12. If an employee files a complaint with the Department of Labor and claims that they are not being paid at Wage Determination rates, DOL won't care what the CO did or did not do if they (DOL) decides the work is of a nature that meets WD standards. In previous life had a Schedule 70 contract providing various help desk/network services to Govt client. Included in the contract were 2 admin type positions which the company had classified as non-exempt employees because work was under Schedule 70. Situation arose where one employee wound up working extra hours to cover for the other - company paid person straight time IAW extended work week authorization, Person complained to DOL that they should have received time and a half. DOL determined nature of duties fit under wage determination labor category and company wound up paying overtime, increasing base rate (was just under WD standard) and paying back pay.
  13. I'm glad the details of none of the items were ever revealed such as propulsion system installation or ferry range...
  14. Assume this is a Cost Plus contract and you are waiting for final indirect rate adjustment invoices? Just went through this with a vendor and after explaining multiple times that when they eventually get their actuals, they will be paid with current year funds but these funds are good to no one come 1 Oct. Took about 3 times to explain it to the folks but they eventually understood. Another joy of the DCAA backlog - vendors being so far behind in getting the final rates that the funds have cancelled. If not a Cost Plus contract or cost-reimbursement CLIN, then just closing out a particular contract year - not sure what the right ctation is though
  15. HCA approved the original D&F in accordance with 16.601(d)(1)(ii) quoted above. Question is under 16.601(d)(2), does the HCA have to approve the ceiling increase or is it the Competition Advocate since increase is $1.5M?
  16. Have a T&M, 5 year contract under a GWAC where need to increase the ceiling about $1.5M based on increased workload required to incorporate new agency directives into SW workflow process. Original D&F for T&M was approved by HCA since 5 years. Have D&F for ceiling increase up at Competition Advocate who is insisting he cannot approve because, and only because, it needs to go to HCA since it's a 5 year T&M but can't give me a reference to back up his contention. Anyone else ever hear of this or can give me a citation to support his position? And of course, part of the funding they have to cover work is FY09
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