CPAF Question

Started by HeyGuy · May 22, 2014 · 4 replies

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    HeyGuy

    May 22, 2014 · 12y ago

    Original post

    Vern and the rest of the gang,

    This is my first post/question but I do read these boards regularly and they are quite helpful and informative. Thank you.

    Here is my question.

    I am preparing a solicitation and the majority of this contract (about 95% of it) will be CPAF. This contract is set up with several SLIN's within the overall CPAF CLIN structure (i.e. CLIN 2 is the base period with AA being Task 1/funding source 1, AB being Task 1/funding source 2, AC being Task 2/funding source 1, etc, etc. However, one or two of these are SLIN's (and again, they still fall within the general CLIN structure and only consist of at most 5% of the contract) will not have award fee metrics. Do I have to make these SLIN's cost plus fixed fee (CPFF) lines? What if we were to add a small task directive CLIN? Do I have to make that CPFF?

    I don't see anything in the FAR that stops me from keeping the structure CPAF (for the entire contract) and I see nothing that stops me from putting $0 in award fee for the lines that do not have metrics and negotitate a base fee in those areas.

    I just don't see the point in calling this a hyrid contract, withholding "fixed fee" on lines, etc, when 95% of the contract has metrics and the other 5% does not. Our group is back and forth on this whole thing. Any thoughts would be appreciated. Thank you.

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    Guest Vern Edwards

    May 22, 2014 · 12y ago

    A CLIN should be the sum of its SLINs. Looking at DFARS 204.7104-1( b ), which is about separately identified SLINs, I don't see any regulatory prohibition against differently priced SLINs. So I think that under one CLIN you can have a CPAF SLIN, a T&M SLIN, and a FFP SLIN, etc.

    I don't know whether your automated contracting writing system will let you do that, but I don't see any regulatory prohibition.

    Such a contract would be a combination of contract types, not a "hybrid."

  3. D

    Don Mansfield

    May 23, 2014 · 12y ago

    DFARS 204.7103-1( b ):

    All subline items and exhibit line items under one contract line item shall be the same contract type as the contract line item.

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    Guest Vern Edwards

    May 23, 2014 · 12y ago

    Oops! Thanks, Don. Okay, make them separate line items instead of sublime items.

    (Mea culpa, but why on earth didn't they put that down 204.7104-1, in the discussion of establishing sublime items?)

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    Cajuncharlie

    May 27, 2014 · 12y ago

    Was "sublime" items a Freudian slip? :D

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