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Everything posted by woops85

  1. No one on this website can answer that question. Call the DSS Help Desk and ask them your question. They are the ones who would have the statistics necessary to answer. If you give them the company name or CAGE code, they can tell you if the company has even started the process.
  2. Suggest you check out the NISPOM and the Industrial Security Regulation (ISR) that can be found at DSS's web site. Both documents spell out the requirements well for both a company that has Foreign Controlling Interests as well as for a person who is a foreign national. Start with the NISPOM (it's derived from the ISR and a little easier to read). If you don't find the right level of detail to answer your question, dive into the corresponding section of the ISR. Depending on why you are asking, the most important thing to know is that the process won't be quick in either case.
  3. Real world example - GSA's 8(a) STARS vehicle had 2 off-ramp provisions at the end of the base period. First one was if vendor could not re-certify that they were still an 8(a). Second was for vendors that had not received $100K worth of orders in the base period (3 year period). Option period was not exercised for vendors falling into these categories. Don't remember the exact number but want to say over 100 vendors did not get their options exercised.
  4. 2011 NDAA extended the sunset date for Defense Agencies until 2016. HR 899 and S 498 are looking at doing the same thing for civilian agencies.
  5. Vern - Any issue with obligating the rest of the award fee pool before the determination is made? I read this to say I have to obligate the full amount of the base fee portion on a CPAF but that it doesn't prevent me from obligating anything above the base fee before the determination is made. Doing assisted acquisitions and I think we've been funding the full award fee pool so , in part, the funds don't appear to be "parked" in our system during financial audits. (can't find any written record of the reason we do it this way)
  6. Not the author but I've seen what you are talking about. GSA recommends it because we have a PIN (Procurement Implementation Notice) that says we cannot do set-asides under FAR Part 8, but instead have to apply a preference for the appropriate small business class, if that's what is desired. In order to give the preference, you have to evaluate it so it becomes a factor that no one can be found unacceptable under. Personally I disagree with it being the primary evaluation factor and I haven't seen it used that way in my office. Usually we have language that says something like "between proposals that are found to be technically equal, and reasonably the same in cost, preference will be given to the vendor with the higher rating in the Socio-Economic Factor". Reasonably the same in cost gets defined (often as within a certain percentage of each other based on anticipated value of procurement) in the RFQ. The rating system in teh socio-ecomonic factor is usually Excellent if you are in the targeted group (SDVOSB, WOSB, 8(a), etc); good if you are a small business but not in the Excellent Group and Acceptable if you are anyone else. To date, no one's complained about it to either the Agency or GAO if that's a measure of validity.
  7. In my office, we are required to use e-Buy to post all solicitations based off a GSA vehicle. But like Napolik said, check your agency supplement and other guidance. The difference between having three vendors say they are willing to submit a proposal and having three vendors submit a proposal can be re-releasing your solicitation.
  8. I'm with DCAA on this one. The phrase is "excessively prolong travel", not "excessively long travel". If it's 20 hours of travel time, regardless of which class of ticket you have, then the contractor cannot use that reason to justify the business class ticket. Making me more comfortable on a long flight if I don't have a physical or medical need isn't sufficient justification in my opinion.
  9. try telling that to GAO during an ADR call. Seriously though, problem was that RFP wasn't clear that there was need for clearance on day 1. and some work could be done without it - just made it awkward because folks had to be limited and escorted. But re-evaluated. Better proposals were still better
  10. Govt has the option to sponsor the awardee for the TS clearance. Since prime already has Secret, the timeframe to get a TS would be a little shorter but would still require all the prime's key management personnel to get individual TS. Can you justify not sponsoring prime? If clearances are required on day one because ability to work would be limited without it, you can require TS of the prime at time of proposal (or award). GAO has previously ruled on a pre-award protest for overly restrictive RFP requirement that if agency can show the need for the clearance, then it's not overly restrictive. But sounds like maybe you are beyond that stage already. If you did not mention evaluating the TS in your RFP, be careful about using it as a determining factor in your decision. We recently lost a protest in ADR and had to re-evaluate, when the KO used lack of facility clearance as part of the trade-off analysis (viewed as performance risk) and went with higher rated, higher priced proposal.
  11. @Joel - Ref the cost-plus-percentage-of-cost - even if the fee shows a NTE dollar amount? But I do get your point
  12. Marine_1 - Your KO may have decided to be overly inclusive because he's writing off of a GSA Schedule. The clauses in the schedule solicitations are meant to cover every scenario that anyone could think of coming up under that schedule. And some of them are pretty broad in what they cover (the schedules themselves). I know around here there was great debate a few years ago about if certain clauses - such as 52.217-8 and 52.217-9, applied to orders written under a contract if they were not in the order themselves.
  13. How is contractor justifying that? Wasn't the fixed fee based off a percentage at some point? Granted that fixed fee may have become a fixed dollar amount which if the G&A dropped actually results in a slight increase in the fee percentage but the dollar figure would not change. Example - $1M in estimated burdened cost with the fixed fee negotiated at 10%. Was written into contract as fixed fee being dollar amount of $100K. Indirect rates drop so new estimated burdened cost is only $950K but based on way contract was written fixed fee remains at $100K (now 10.5%). If contract had been written to say fixed fee was 10% of estimated burdened cost not to exceed $100K then fixed fee paid out would wind up being adjusted to $95K.
  14. Our office routinely publishes a range in Section L - instructions to Offerors. Range can be either dollars or hours but not both. As part of the cost proposal, we ask vendors who are outside the range to explain why - maybe the are proposing efficiencies in out years or they see some level of risk that we don't. We've found the range helps us eliminate the folks trying to lowball their way in and the explanation helps us figure out if we've missed something (a risk or an opportunity for savings). Some of the COs use the IGCE figures as low end of range while others put it in the middle or at high end. That's their individual call as is whether hours or dollars make the most sense.
  15. At GSA, when we receives funds from our clients, the funding is placed in the revolving fund and it is our line of accounting that funds our task orders. Part of the Interagency Agreement is that we follow their money rules, even though the funds we are actually obligating are ours. Once we've paid a vendor invoice, it's part of our job to make sure that when we turn around and bill the client, the client funds we are billing against are valid under client rules for the invoice we paid. Vern - I'm certainly hoping your guess is right. But I guess this summer's "fun" will be waiting for it to happen so we can get a decision to serve as precedent.
  16. All - Based on my reading of the NDAA, the sunset date for task orders issued under ID/IQ contracts that are valued at over $10M has been extended for DOD, but not for civilian agencies. I saw where Title 10 was modified to change the sunset date but saw nothing similar relating to civilian agencies. If someone else has found where this applies to civilian agencies (in the 2011 NDAA or another document), please let me know. Assuming that no change has been made for civilian agencies, I'm looking for opinions on how this would apply for assisted acquisitions. Specifically - if a civilian agency such as GSA, DOI or NIH, conducts a procurement on behalf of a DoD agency and awards a Task Order valued at over $10M, will it be protestable? Beccause regardless of what the Interagency Agreement between the two entities may say about following all the DoD business rules, protest jurisdiction is not an agency level negotiation point. Recognize that we probably won't know for sure until after the first award after the civilian side sunset date has passed, someone protests and GAO makes a call as to whether they have jurisdiction. But what do you think?
  17. Making sure I understand situation. POP ends 30 Sept. Subs send you their Sept invoices in Oct. Those invoices miss your billing cycle and therefore wind up on your November invoice, with appropriate indirect cost pools applied. Was the entire invoice rejected or just the indirects applied to the subcontractor costs?
  18. Your RFP went out? Or offers came in? If RFP went out but offers not back yet, post amendment to RFP and add it. If offers already back, the vendors may have included an assumption about out year pricing and escalation for those years. If they did, you may be covered. If not, ask them to clarify/revise. Just be careful that if you ask for revision (which puts you in discussions), you open discussions with all.
  19. Yes - put a caveat in your pricing section that the pricing for those years will be the rates in the order or the rates in the underlying schedule, whichever is lower.
  20. A CO can award a task order against the GSA Schedule that has option periods that extend beyond the current term of the vendor's FSS contract. However, the CO cannot EXERCISE an option if the underlying schedule has expired. Read the quote FormerFed posted carefully
  21. AF - Does the Govt in your example ahve same issue when the big guys do this? Because there's a least on big guy out there whose latest set of final rates is currently from 2002. When they get their 2003 rates and submit the invoice, I'm hoping it's a credit because otherwise the hunt is on for current year funds to pay it.
  22. FCW article at http://fcw.com/articles/2010/12/20/doe-fre...aspx?sc_lang=en. DOE press release http://www.energy.gov/news/9917.htm
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