Subcontracting with CPFF

[JC_One]

Good Morning,

This is my first post, we are a small IT firm and may have our first subcontract using CPFF where we are the Prime.  I was wondering if there are standard forms we should be asking our sub for.  This is what I know that I can ask for :

1. DCAA certified rates

2.  Letter of both an approved purchasing/accounting systems.

3.  Organization Conflit form

4.  Reps and Certs - does anywhere have a template that covers everything - do we need one ? 

5.  Flowdown Clauses ? 

Any help would be appreciated and welcome since I am not sure what I need to have ready 

 

Jennifer Caruso

 

[Patrick Mathern]

Hi Jennifer -

You will get a far more complete answer from some of the other folks in this forum, I focus my efforts on cost and price analysis.  From that perspective, you will want to determine whether what you're buying qualifies as a commercial item/service (as defined in FAR 2.101).  If it does prove to be commercial, it will simplify your flowdowns and possibly the cost/price analysis requirements.

If it's not commercial, you'll want to know if your subcontract will be >$750K.  This will have implications for cost vs. price analysis.

Questions to you then:  does this qualify as a commercial item/service and is it >$750K?

Patrick

[JC_One]

No it is not over 750K and I will have do some research as to whether it is commercial defined under FAR 2.101  

[here_2_help]

JC_One,

From my perspective, your focus should be on people, not forms. Do you, a small IT firm, have the people in place who understand how to award and manage a CPFF subcontract? If not, get them. Now. You will not regret it.

Second, processes. Do you have the processes in place to manage a CPFF subcontract? What will you do if you get a notification that the SubK has burned through all its funding early and is about to stop work? What will you do if you get a letter from the SubK stating that its billing rates are increasing? What will you do if you get a letter, years from now, stating that its final rates have been approved and here's an invoice for additional indirect costs? Are you prepared to review each invoice from the SubK each month in order to ensure that unallowable costs are not being billed and paid?

That's just off the top of my head.

If the answers to any of the above questions is NO or I DON'T KNOW then you need help. A consultant may be a good place to start.

Hope this helps.