Drew

Recent posts

• FAR Rewrite Underway

  "Okay, so what you want to know is whether making a past policy, like EEO, inapplicable to future contracts might prompt the government to also renegotiate existing contracts to which the policy now a

  in Proposed Law & Regulations / Legal Decisions · 1y ago

• FAR Rewrite Underway

  Nope, sorry, did not know that there were regulatory archives and that they would be referenceable and enforceable. This was a newbie question. I don't agree that these questions are utterly unjustifi

  in Proposed Law & Regulations / Legal Decisions · 1y ago

• FAR Rewrite Underway

  Can anyone hypothesize (predict? project? get a ouija board answer? put together a well-engineered ChatGPT prompt?) on what might be the effect on _signed contracts already in place_ if certain "claus

  in Proposed Law & Regulations / Legal Decisions · 1y ago

• FAR 2.O (The FAR "Overhaul")

  "We are going to release it now, oops, never mind, and now, nope to soon, and now, nope we take that back." << we talkin' about FAR overhaul or tariffs?

  in About the Regulations · 1y ago

• Materiality Thresholds for Source Decisions and Fair-and-Reasonable Price Analyses

  THANKS TO ALL!!!

  in Subcontracts & Subcontract Management · 1y ago

• Materiality Thresholds for Source Decisions and Fair-and-Reasonable Price Analyses

  Thanks for the caution, Neil.  I don't think we have risk of causing them extra work - it's more the reverse situation, like I describe in the original post above!  I believe we do have enough support

  in Subcontracts & Subcontract Management · 1y ago

• Materiality Thresholds for Source Decisions and Fair-and-Reasonable Price Analyses

  @Neil Roberts: Oh how I wish!  Yes, we've considered this closely over the years. Our primary CLins are FFP for labor, but the ODC and travel CLins are reimbursed-at-cost + a _de minimis_ material ha

  in Subcontracts & Subcontract Management · 1y ago

• Materiality Thresholds for Source Decisions and Fair-and-Reasonable Price Analyses

  Sorry, Neil, are you asking how we decided to award the subk?  We honored the rip-and-replace / cancel-rebuy constraint of the OEM publisher and "awarded" the license renewal to them.  But that's wher

  in Subcontracts & Subcontract Management · 1y ago

• Materiality Thresholds for Source Decisions and Fair-and-Reasonable Price Analyses

  We have a prime contract (IDIQ Task Order) that includes the Competition in Subcontracting clause (FAR 52.244-5).  We do not yet have an "approved" purchasing system (that is, one reviewed in a CPSR a

  in Subcontracts & Subcontract Management · 1y ago

• Subcontract (Purchase Order) for software license with term (duration) beyond the PoP of the Prime Contract

  @General.Zhukov:  @C Culham pointed me to the ADA Redbook.  Obviously haven't consumed it all yet (....and really don't think I will...), but I did grab this nugget:  Appropriations made for a defin

  in Subcontracts & Subcontract Management · 1y ago

• Subcontract (Purchase Order) for software license with term (duration) beyond the PoP of the Prime Contract

  @C Culham / [@Retreadfed](/u/retreadfed):  Thank you both;  you're affirming my perspective.  I will keep the Anti-Deficiency Act link handy as the discussions progress. As to FAR 52.216-22, it is pr

  in Subcontracts & Subcontract Management · 1y ago

• Subcontract (Purchase Order) for software license with term (duration) beyond the PoP of the Prime Contract

  We have a Prime contract (task order award on an IDIQ contract) through GSA which requires consent for subcontracts and purchases against a cost-reimbursable CLIN.  This is formalized in a Consent to

  in Subcontracts & Subcontract Management · 1y ago

• A SBIR Phase III IDIQ “satisf[ies]… competition requirements,” but are its sole-source FFP TOs subject to CPSR?

  All, thanks for your reasoning through on this question.  We're going to consider these FFP TOs as "in" the population of contracts that then decide the population of subcontracts subject to review.  

  in Subcontracts & Subcontract Management · 2y ago

• A SBIR Phase III IDIQ “satisf[ies]… competition requirements,” but are its sole-source FFP TOs subject to CPSR?

  First, thanks to everyone for this critical analysis.  An important part of this posting-and-response dynamic is refining the question and/or picking on the right points to argue from, and I appreciat

  in Subcontracts & Subcontract Management · 2y ago

• A SBIR Phase III IDIQ “satisf[ies]… competition requirements,” but are its sole-source FFP TOs subject to CPSR?

  Our company has multiple Phase III SBIR IDIQ contracts through GSA, each of which can be used by DoD components to award FFP, FFP LoE, or T&M Task Orders. The TOs are negotiated using Alpha contracti

  in Subcontracts & Subcontract Management · 2y ago

• Industry KPIs to justify hiring/growing company

  The basic catalogue of metrics I refer to when measuring a process include these: Then you want to identify the leading and lagging indicators on the processes that you're executing and measuring. 

  in Contracting Workforce · 2y ago

• Purchasing Manual Example(s)?

  Very helpful content, Patrick, thank you.  In our planning one of my colleagues also came across SpendLogic.  I think they've already reached out or are planning to.  Thank you!

  in Subcontracts & Subcontract Management · 2y ago

• Clarifying “Practical,” “Practicable,” TAs, and Alpha Contracting for SBIR Phase III SubK’s

  Wanted to append to this post further relevant research from WIFCON, just in case it helps anyone.  The Consent to Subcontract is actually the circumstance we're facing wrt the second set of questions

  in Subcontracts & Subcontract Management · 2y ago

• Purchasing Manual Example(s)?

  Does anyone have a contractor's purchasing manual they are willing to share?  Or, at least a Table of Contents from one?  I can find plenty of examples online from the government's perspective (agency

  in Subcontracts & Subcontract Management · 2y ago

• Clarifying “Practical,” “Practicable,” TAs, and Alpha Contracting for SBIR Phase III SubK’s

  @Neil Roberts and [@WifWaf](/u/wifwaf) Thanks for your additional input.  Appreciate the pointers and clarifications.   Will likely follow up in (a) separate post(s) after researching more of these ar

  in Subcontracts & Subcontract Management · 2y ago