Task Order Issued Against GSA's Existing IDIQ Contract

The Defense Department allows for incremental funding of FFP contracts through the use of the clause at DFARS 252.232-7007, Limitation of Government's Obligation.  Other agencies may have similar approaches, or may be in the wild west of government contracting.

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Additionally, can a task order have a period of performance beyond 5-years?

Check the terms of the GSA contract.  Usually they are, at least with GSA awards

ji20874 & formerfed: Your responses are greatly appreciated. I did come across DOD's clause at DFARS 252.232-7007, as well as clauses from other agencies. I didn't want to raise my concerns about the various flaws I've discovered with this task order requirement without having supporting information, because I'm new to this agency.

I provided some information that might be helpful.  However, I do not suggest that everything is proper in your situation.  There is a lot of sloppiness across the Government in this matter.

ji20874: I do agree that there are a lot of sloppiness across the Government. I am just trying to find the best way to approach this. It is going to be a bit of a challenge.

On 2/10/2022 at 12:41 PM, 1102_InquiringMind said:

Please help me understand how FFP CLINS can be incrementally funded...

@Inquiring MindWhat don't you understand? You appear to think it is improper. If so, why do you think that?

On 2/10/2022 at 12:41 PM, 1102_InquiringMind said:

Additionally, can a task order have a period of performance beyond 5-years?

You seem to doubt it. Why?

Why do you think those practices are "flaws"? Is it because you've not seen them done before?

What rules do you think those practices violate? Please cite them by specific reference. Chapter and verse.

Maybe your thinking is based on misapprehensions or limited experience. We don't know anything about you and can't know that until you explain yourself. It's hard to explain something to someone you don't know and who has not explained their thinking.

Vern,

I’ve been in the 1102 field for a little over 3 years and am looking for feedback on this WIFCON platform. I don’t think that incrementally funding FFP CLINS are improper; I just haven't seen it done at the agencies where I've worked. Furthermore, the agencies for which I have worked included language in their FAR supplements indicating when FFP CLINS can be incrementally funded. As far as thinking that "those practices are flaws", I was referring to some of the flaws I noticed while analyzing the task order file. Sorry for not explaining my reasoning; contracting is a very challenging field to master, and I am still learning.

@1102_InquiringMindWould you like some reading materials on incremental funding? The FAR coverage is both sparse and somewhat confusing.

Vern,

Any reading material you could provide on incremental funding would be greatly appreciated. Thank you.

@1102_InquiringMindWarning: This is a very confusing topic. FAR coverage is inadequate and FAR 32.703-1 is a little misleading. Take a look at these for a start.

GAO, Budget Issues: Incremental Funding of Capital Asset Acquisitions (2001), https://www.gao.gov/assets/gao-01-432r.pdf

Congressional Research Service, Defense Procurement: Full Funding Policy—Background, Issues, and Options for Congress (2007), https://www.everycrsreport.com/files/20070615_RL31404_399717ad5f8fab73080113e940e7c8b8bcf4d52c.pdf

Congressional Research Service, Navy Ship Procurement: Alternative Funding Approaches - Background and Options for Congress (2007), https://www.everycrsreport.com/files/20070615_RL32776_be6219cb88e53694e139151d5bc6802888ded554.pdf

Vern, thank you! I will take a look at these for a start.

@1102_InquiringMindJust a heads up: budgeting people and contracting people often use the term "incremental funding" to refer to different but related procedures.

Vern, thanks for the heads up!👍