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I've been handed a recently awarded GSA schedule contract, 00 CORP, which has some labor categories which are mapped to wage determination occupations. The documentation refers to to the wage determination 2015-4281, which is for Alexandria, Virginia. It does not refer to a revision number. The revision number in place now is #16, and it was in place a few days ago at the start of the schedule contract. I'm wondering how to interpret this when revisions #17 and #18 come along. Presumably they will have higher wages and H&W benefits. What will be the impact on the schedule labor rates? For example, Accounting Clerk I now has a wage of $19.10 and $4.22 in H&W. If in revision #17 this goes to $20.00 and $5.00, what is the impact on the schedule rate?
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Hello - We are adding a subcontractor to a project that is under GSA. The subcontractor does not have a GSA schedule, so we are planning to map their hours to our approved LCATS. The biggest question is what rates should be included in the subcontract? Does the sub charge us our rates, or do they charge their rates? If the subs rates are lower than the rates we are mapping them to and we charge the government the higher rates are we opening ourselves up for an audit risk? Thank you for your assistance!
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What are your thoughts on GSA's announcement to consolidate all 24 GSA Schedules into a single GSA Schedule? How will this affect industry contractors? How will this affect contracting officers and the contracting process? https://www.gsa.gov/about-us/newsroom/news-releases/gsa-announces-transformation-of-multiple-awards-schedules https://federalnewsnetwork.com/acquisition/2018/11/long-overdue-reforms-coming-to-gsas-schedule-program/ https://www.federaltimes.com/acquisition/2018/11/27/gsa-to-consolidate-24-multiple-award-schedules-into-one/ https://fcw.com/articles/2018/11/27/gsa-consolidates-award-schedules.aspx
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It is my understanding that GSA schedule contracts and orders at to be used to buy commercial items on commercial terms. Is that correct? If so, how is it that orders are allowed to contain non-commercial terms? I have government unique security requirements in mind, but anything unique to the government would seem to apply.
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Can anyone recommend one over the other? The pros, cons of both. I have a requirement for IT advisory services, which is available through both vehicles. I have experience with GSA not NITAAC. Thanks in advance.
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Wifcon Community - I am seeking critical feedback for my planned evaluation approach. I want to ensure that I have my ducks in a row before approaching Legal with this. This method is based upon a mix of Vern's past posts and the Sevatec holding. Thank you in advance for your assistance. OBJECTIVE: To utilize an evaluation scheme that is more streamlined, intuitive, and flexible than trade-offs, without increasing protest risk. If this works as intended, I would apply it (or some variation) to most of my future service procurements competed under FAR 8.4, 13, or 16.5. CONTEXT: Competitive BPA call pursuant to 8.4. Four FTEs to provide consulting and management support services. Utilizes PWS and exceeds SAT. EVALUATION METHOD: Factor 1: Quote acceptability (compliance w/ T&Cs, in-scope, etc.). (Pass/Fail) Factor 2: Personnel qualifications. (Pass/Fail) Factor 3: Risk - Combination of personnel experience and contractor past performance. (I advised against including PP being that this is a BPA call, but my customer insisted.) Factor three will be evaluated through direct comparisons of quotes. Quotes will be ordered from lowest to highest performance risk. Price will not be a factor, since the Government is willing to pay up to the ceiling rates. Award will be made to the contractor that passes Factors 1 and 2, presents the least amount of performance risk, and quotes a F&R price.
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GSA IT 70 Price Proposal FACTS: Small Business withdrew its IT70 offer because the GSA KO refused to accept anything less than its lowest, historical cost plus fixed fee (CPFF) rate in the BOA negotiation. The Small Business does not have any past or current business with commercial customers, so all historical business is with the federal government under broad agency announcement (BAA) or Small Business Innovation Research (SBIR) CPFF contracts. The company does not have a history of time and material (T&M) or labor hour (LH) type contracts. The company develops its cost rates based on the actual salary of an employee combined with the DCAA-approved provisional billing rates (e.g. Overhead, G&A, etc.). Together the company combines the cost rate and the provisional billing rate to create a fully burdened rate. Taking the SW Engineer I category and using hypothetical rates, there could be a span of say $60 - $80 depending on the individual employee's salary and his/her fully burdened rate. For purposes of the GSA IT 70 submission, the company created a blended T&M rate based on its labor categories and historical fully burdened cost rates. However, the GSA KO said the only rate that would be accepted as the BOA negotiation would be its lowest, historical cost rate of say $60/hour. Issue/Concerns: If the company is only allowed to negotiate from its lowest cost rate, it will lose money on every task order. By the time of its first task order award, the lowest paid employee in the labor category has likely received a raise and/or the employee may have already left the company. Moreover, if the company is forced to start negotiations from its lowest cost rate, it will never have room to offer further discounts without taking recurring losses. Question: Why can't the company offer a fair and reasonable, blended T&M rate for SW Engineer I that represents the fully burdened cost rates that the company has charged? The company is not trying to hide its history and clearly shows its math on all its calculations. Moreover, to determine fair and reasonable pricing, the GSA contracting officer may consider many factors, including pricing on competitor contracts, historical pricing, and currently available pricing in other venues. When taken in its totality, the rates that the company proposes are in line and even well below its competitors in similar NAICS categories.
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Hello, I am having a disagreement with people in my office regarding BPA orders off of a BPA off of a GSA contract. So we established a BPA off of a GSA contract (Using Part 8). The orders placed against that BPA are sometimes for services for a 3 year period. Like a report that takes 3 years to compile. In accordance with FAR Part 17 do you have to have options on a BPA order? Or have approval for a multi-year contract? Thank you!
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Would like to hear some feedback on anyone who has used GSA OASIS, specifically for A&AS to see what were your successes and failures. Is it a preferred method? Ease of use? Does your local policy make it mandatory? Thanks in advance!
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Morning All! Had a question around use of labor categories in a BPA won as a GSA CTA. Let's say the CTA has 2 members, each with their own GSA schedule (same schedule for both). One firm has labor categories on it's schedule that the othe does not. During the bid process, BPA labor categories were created and mapped from each member's schedules. Ultimately then, the BPA includes labor categories that are not on one CTA member's schedule. If a task order released under the BPA dictates labor categories, and only one CTA member has those labor categories on their GSA schedule, could the other CTA member also use that labor category? If yes, how would that be reported to GSA (since it's not on their schedule)? If no, could one CTA member sub to another to use the labor category? Hope that was clear to follow, thanks in advance for any help!
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We have an "item" on our GSA IT-70 schedule for a government-site training class. It has a part number, description (syllabus), and duration (1 week). It also specifies that travel is not included. The cost for the class is about $12k. Additionally, there will be travel expenses (hotel, airfare...) separate from the GSA item. Here is the challenge: 1. Fed customers want to pay with GPC; however, some do not want to see the GSA item and travel costs itemized but want a single total with the training class descriptor.This would show our GSA product billed at a higher amount (not acceptable). The travel is not incurred by a government employee (thus requiring the Gov travel card) but is an actual cost reimbursement for contractor travel to facilitate the training (ancillary). Although the gov can't pay for federal employee travel on GPC, can they pay contractor travel costs itemized on an invoice along with the GSA line item for training? 2. A general question on this: can the government purchase the training before it takes place and pay for the travel after the fact. I've seen where, under the tuition exception to advanced payments, that this could be deemed acceptable but I'm not sure. I would appreciate any insights!
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The answer to my question is paritally within the topic "GSA Schedule CAGE Code Challenge" but not quite on point. Many of the larger companues have more than one CAGE and DUNS combinations. Somwehere along the line I picked up the attititude that if the GSA Schedule was awarded to Willy Coyote Inc. with a CAGE of 12345 and DUNS of 222 333 444 any orders placed by Roadrunner AFB against that schedule had to match the aforementioned. Now that CPARS validates the CAGE on the GSA Schedule CAR/FPDS/NG with the CAGE on the order, we're having a few issues becuase the award cites to a different CAGE than what is in FPDS and the contract specialists are running into a hard stop error when they try to a CPAR. My suggestion is to modify the CAGE code on the order to match what is on the schedule. Once the order is in FPDS with the correct CAGE it will update CPARS and all should be good from that point on. For what ever reason many of our awards use different CAGE codes than are on the schedules. Before I get any 'Deer in the head lights looks' and the urge to pummel someone, can anyone point to a reference that says what CAGE & DUNS combinations to use on a GSA order? Commons sense doesn't count as a reference. Thanks,
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I am competing a requirement amongst GSA IT Schedul 70 contract holders. The requirement is combination of Firm Fixed Price and Labor Hour. In discussions with one of the other Contracting Officers here, he mentioned to me that I would be required to get subcontractor proposals in order to determine the reasonableness of the Prime Vendor's rates (i.e. determining the prime's profit, etc.). This is not something that I have done before, nor in my time working in private industry have I submitted subcontractor proposals with my GSA quote. I would consider doing this if it were a sole source award, but with competition I dont think I need to do this. Especially, if we are not evaluating the labor categories against actual individuals. Am I wrong here?
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The Government has a requirement for physician services. It has been determined that GSA Schedule 621 I has small and large schedule holders capable of meeting the Government's requirement. To the meet the agency's small business goals, the Contracting Officer intends to set aside the acquisition for small business concerns. The estimated value of this acquisition is $300,000. The Contracting Officer is now being challenged on the set aside. Those opposed to the set aside have stated that physicians being provided by the GSA staffing firms (found on schedule 621 I) are 1099 independent contractors, and are in effect, subcontractors. As such, there is no way that the small business schedule holders could comply with the "at least 50 percent of the cost of contract performance incurred for personnel" requirement of 52.219-14 Limitations on Subcontracting. Therefore, a total small business set aside is improper; the requirement must be solicited on an unrestricted basis. The Contracting Officer contends that it is standard practice in the medical staffing industry for physicians to be 1099 employees. However, that does not automatically make them subcontractors for purposes of determining compliance with 52.219-14. Taking into account the totality of information (See 13 CFR 121.106 a)), the physician should still be considered an employee of the concern. The concern dictates where the physician reports, when and how long he or she works, and what responsibilities they will have while working. Therefore, the physicians should not be considered subcontractors for the purpose of determining compliance with 52.219-14. Thoughts?
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I have read through this forum and searched for answers on this topic. While there have been several discussions surrounding this topic, I haven't quite found the answer that I'm looking for. Question: We issued an RFQ on GSA eBuy for a labor hour type task order. There are two subcontractors, one with a GSA schedule (sub 1) and one without (sub 2). The prime provided backup documentation/quote from sub 1 which clearly shows their GSA schedule labor categories, GSA schedule rates, proposed discounted rates and proposed totals for the work being performed. For sub 2, the prime provided current invoices showing sub 2's current open market hourly rates and labor categories for the work being performed. However, on the prime's quote they applied their own GSA schedule labor categories and rates to the subs which are approximately 3% higher than the sub's proposed discounted rates. Is this allowable? We are seeking to move forward with award without negotiations. From what I've read, most people seem to say that if the subs fall under the prime's GSA labor categories than the prime can apply their own rates. This is based on the information found here http://www.gsa.gov/portal/content/202257#3 and FAR 52.212-4 (ALT 1)(e)(1)(ii). Does this apply if a sub. has their own GSA schedule and their rates are cheaper?
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For an award following Far Part 8 procedures, but where a competitive range was established, and notices eliminating offerors from the competitive range were sent out, do I then have to send award notices to those offerors who were already elminated? FAR Part 8 states and timely notification should be sent to unsuccessful offerors. However, the previously sent notices could be considered this notification.
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I have researched this topic and would like to confirm that the protest limitation of $10M on orders issued on an IDIQ still does not apply to contract vehicles covered by FAR subpart 8.4. The case law I am seeing is dated and current case law is not forthcoming with regard to the value of the orders. Thank you.
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I know you can ask for discounted pricing from GSA Scheduled contractors but can you actually negotiate with them? Let's say we put out an RFQ and we get quotes in, can we then start negotiating with one of the vedors? How does one "negotiate" better pricing with GSA vendors?
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GSA eBuy RFQ -- Limited to SIN Vendors? I posted a RFQ on GSA e-Buy recently, under SIN 899-1 (Environmental Services), released to all 667 SIN 899-1 schedule contractors (we don't have a preferred source and we're really interested in competition) -- a firm asked me if it could provide a quotation even though its schedule wasn't listed under SIN 899-1 -- I haven't faced this question before, and I can't find a good answer in FAR Subpart 8.4. Is a RFQ citing SIN 899-1 open to all GSA schedule contractors? Or only those who are listed under SIN 899-1? This is a requirement for services requiring a statement of work. We wondered among ourselves which SIN to use, and we picked 899-1 because it is the closest match, not for any desire to limit competition or exclude other GSA schedule contractors. [Oh, my -- I misspelled vendor in the thread title, and I don't know how to correct it!]
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We recently had an assistance visit from GSA, during which time the auditor flagged one of our contracts for overpayment. It is a FFP contract, base + 3, under a GSA schedule. The contract has a 3% escalation for each option year - unfortunately our GSA schedule has no escalation. We typically discount off our published rate but in this instance did not. Neither our contract nor our invoices contain any rate or hour information - we were simply funded a total FFP and invoice equal monthly installments. The only place that indicates any rate information is a cost buld-up found in the file (contract started 4 years ago and no one who worked on it is currently at the company), no indication that this was the final cost proposal submitted to the government. The contract CO or COR has never flagged and all invoices have been paid. A large portion of the work is being performed by a subcontractor. Based on the above, do we have an argument against the overcharge claim? We would be looking at paying back several hundred thousand dollars as we are in the last year of the contract. We do have a clause in our subcontract that would allow us to recoup any money repaid to the government, but I would assume the sub will fight us on it. A related question would be how difficult is it to mod our GSA schedule prior to any option period? Could we add a rate escalation clause and other labor categories in the middle of the contract? If so how long does that process typically take? And could any rate escalation be retroactively applied? Thank you for your help in advance, sorry if any of these are basic questions as I am new to contracting
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Good Morning. I have long consulted WIFCON when researching questions/topics, but this is my first post as a registered member. Glad to be an official part of the community! My company is planning on breaking up our existing structure and creating several subsidiary organizations all tied to a parent organization. They will be independent subsidiaries, not divisions or departments. Some people in our company believe that the subsidiary organizations will all be able to continue to use the same GSA Schedule (currently on 70 and MOBIS) that will be help by the parent organization (ie, multiple subsidiaries all using the same schedule). Others believe that, since a subsidiary is supposed to be independent of the parent, our current GSA schedules will have to be novated to one of the subsidiaries and each subsidiary will need to obtain their own schedules (ie, no sharing of GSA schedules among parent or subsidiaries). We plan on reaching out to our GSA contracting officer in the future, but I'd love to know if anyone has had any experience with this situation.
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Good Morning. I have long consulted WIFCON when researching questions/topics, but this is my first post as a registered member. Glad to be an official part of the community! My company is planning on breaking up our existing structure and creating several subsidiary organizations all tied to a parent organization. They will be independent subsidiaries, not divisions or departments. Some people in our company believe that the subsidiary organizations will all be able to continue to use the same GSA Schedule (currently on 70 and MOBIS) that will be help by the parent organization (ie, multiple subsidiaries all using the same schedule). Others believe that, since a subsidiary is supposed to be independent of the parent, our current GSA schedules will have to be novated to one of the subsidiaries and each subsidiary will need to obtain their own schedules (ie, no sharing of GSA schedules among parent or subsidiaries). We plan on reaching out to our GSA contracting officer in the future, but I'd love to know if anyone has had any experience with this situation.
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I have a FFP BPA, 8(a). The use of a GSA schedule by my prime (use of Government sources by Contractors) appears to be the only way to obtain the material required at the best price. (The GSA firm WILL NOT provide GSA pricing to my Prime without a letter of authorization from me, the KO) Does anyone have an idea why FAR would only permit authorization to use sources in the performance of cost reimbursement contracts or other types when the a substantial portin of the contractor's contracts are cost reimbursement? I am just re-entering the world of using GSA contracts - bear with me on this one. FAR 51 states " 51.101 -- Policy. (a) If it is in the Government’s interest, and if supplies or services required in the performance of a Government contract are available from Government supply sources, contracting officers may authorize contractors to use these sources in performing -- (1) Government cost-reimbursement contracts; (2) Other types of negotiated contracts when the agency determines that a substantial dollar portion of the contractor’s contracts are of a Government cost-reimbursement nature; or..."
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I work for a wholesale company that is considering applying for a GSA contract. The most favored customer clause in the schedule is a major concern for us because we have recently (last 6 months) begun selling products to a very small group of local customers at a significantly higher (30% higher) discount than our standard in an effort to help stimulate our local economy and specifically local small businesses. The sales to these customers represent less than 10% of our sales. Because we have now sold products at the steeper discount, does that mean that we must give at least the same discount as part of our GSA offer? If yes, could we immediately discontinue offering our products at that discount to avoid listing them as our most favored customer? What historical time frame does GSA consider at in reference to MFC? Thank you for your help!
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TOPIC: Purchase Order under GSA FSS Contract: Open Market Items BACKGROUND: The primary item (camera) which has a cost of roughly $94,000 is exclusive to a particular manufacturer, and this is justified using a limited source justification. However, there are several items for this requirement not on the GSA FSS of the company which offers the camera. The total cost of these incidental items (lenses) is roughly $14,900.00. Initially it was thought that all the required items were on the GSA Schedule, which would have allowed for a sole GSA Contract Buy. However, after conducting additional research, it was determined that the required lenses for this camera (CANON) are not on the GSA Schedule, however the company is working on getting the lenses on the schedule at some point in the future. I am aware of FAR 8.402(f). As a fairly new contract specialist, I am still somewhat confused as to what additional administrative procedures are required for the addition of these open market items under the current GSA Contract. As I mentioned previously, the projected amount indicated through a previous quotation is $14,900.00 for the lenses. I am planning to provide additional justification which warrants the inclusion of these lenses, as incidental items critical to achieving the SOW in the required timeframe without additional costs. I need to know of any additional contracting procedures and references that should be relied upon for this specific procurement situation? Being that these open market items are quite low in value, I'm unsure of what additional contracting requirements apply in order to effectively place them under the GSA Contract with the exclusive camera. Any information you can provide in regard to this issue is greatly appreciated and will be researched further. NOTE: The open market items will be clearly marked on the contract and quotation as open market items. All responses welcomed in regard to this topic. Thanks, -Pete-