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Found 2 results

  1. Hi all, I am in the process of developing a PWS for an OTA. I understand an OTA allows for a lot of flexibility and not subject to all of the rules that a contracts is subject to. I have an AO saying that because of this flexibility, I do not need CDRLs, DIDs, or a QASP. This is performance based. How are we to monitor the performance without identifying the performance standaand expectations? I have not found any information to support not needing those documents. Help!
  2. I am looking for general information on inspection and acceptance of CDRLs. The effort in question is FFP, including all data, and includes delivery of 60-70 CDRLs. The effort includes FFP hardware, FFP services, and FFP Data. The pricing of the CDRL requirements was rolled into the other total FFP prices (like we have 1 FFP line item/CLIN that is NRE CDRLs, NRE testing, NRE tasking, etc) and 1 FFP CLIN (separately priced) for drawing package. Most of the CDRLs are marked with the code "DD" in block 7 (I/A at Destination), "A" in block 8 (approval is needed prior to final distribution), "ASREQ" in block 10, then "See Block 16" for Blocks 12 & 13. Block 16 (for almost all of the CDRLs) with additional language similar to the following 2 examples: 1. Block 12 & 13: CDRL shall be submitted NLT 90 DAC. Government requires 10 working days for review/comments/approval. Contractor shall address any Government comments/questions within 10 working days of receipt; or 2. Block 12: CDRL shall be delivered to the Government within 180 DAC. The Government will have 30 days to review, accept, and/or comment on the deliverable. After the Government reviews and comments on the deliverable, the contractor shall incorporate Government comments/submit change pages into the final electronic deliverable. Block 13: Final Deliverable shall be delivered to the Government 90 days prior to contract end date. Question: Contractor believes that Government is only entitled to one round of review and comments & once those are received, Contractor reviews, adjudicates and/or incorporates required changes and submits the final deliverable within timeframe noted for Contractor on the 1423 Form; and since data is FFP, Contractor assumed only 2 submittals for each CDRL (Draft & Final incorporating Govt review & Comments). Government believes that the language in Block 16 stating "Government requires 10 working days for review/comments/approval. Contractor shall address any Government comments/questions within 10 working days of receipt" (and does not spell out final deliverable) means that the Contractor cannot limit the number of reviews conducted by the Government. And for those CDRLs that do specifically reference a Draft & Final Deliverable/Submittal, Government believes that because Block 10 (Frequency) is coded with "ASREQ" that the Contractor is required to submit revisions of those CDRLs whenever the Government requires them. Hypothetically, Contractor submits draft CDRL and comments are received from the Government. Contractor incorporates comments and submits the revised CDRL as the Final submission IAW 1423 Form. 30 days later, Government provides additional comments from their review of the Final submission. As a courtesy, Contractor adjudicates and revises the CDRL again and re-submits 2nd Final. Government submits comments in response the 2nd final submission. Contractor rejects comments stating that the CDRL 1423 form provides 1 comment/review period from Government, then submission of final, which has already occurred. Government is now rejecting the CDRL delivery due to "grammar, format and spelling mistakes" OR Government is stating that Block 10 requires contractor to submit "ASREQ" or as required and the Government is now requesting an additional submission. I have seen the other discussion on CDRL Review and Acceptance and I believe the circumstance differs as these CDRLs were priced as FFP, not CPFF. The additional rounds of Government comments and reviews has been doubled or in some cases quadroupled for the Contractor. This has been brought up to the PCO that these additional reviews should be considered out of scope, but now Government is refusing to approve CDRLs citing grammar, spelling or format mistakes (like there may be 2 line spaces between paragraphs instead of 1 or a couple words are in font 11 instead of 12, etc). And I understand that generally it would not be a big deal; however, when CDRLs are FFP and there are 76 different CDRLs......review of comments, changes, revisions, and re-submissions begin to add up. On some CDRLs, Government has already exceeded 5 or 6 Comment submissions (with a revision of the CDRL to each afterwards). Where can I find clear direction on CDRL Acceptance? If the Government doesn't submit within the time period stated, is approval deemed? If not, what is the acceptance criteria? If the CDRL meets all requirements of the DID called out, but there are a few grammar or format mistakes, is that a basis for rejection?
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