This series of FAR summaries is meant to take a meaningful portion of the Federal Acquisition Regulations to ensure an easy-to-understand approach to ensure that the reader comprehends the process of doing business with the government and that the government exercises a fair and reasonable approach to doing business with the general public.
FAR 44.202 Contracting Officer’s Evaluation
The FSS gives great in-house training on subcontracting plans. When I first got there they were delegated and when I left they were assumed by the Contracting Officer. So, I have done a few of these things. Thank God for that PowerPoint! They aren’t the easiest things to learn.
It’s cross-checking and Junior High math but written in hieroglyphics.
The CO ensures that a subK plan is good business judgement and makes sense to finish the project (FAR 44.202-1)(b). You aren’t allowed to cut your buddy in to get well off Uncle Sam if it isn’t really needed (FAR 44.202-2)(b).
Subcontractors can be designated in negotiations but designated negotiators don’t count as advanced notice (FAR 44.202-1)(c).
The CO considers the following at FAR 44.202-2(a):
Is a subK plan consistent with pricing, performance and policies?
Is the subcontractor’s additive available through the government?
Can the subcontractor be justified?
Does the subcontractor comply with prime contractor requirements?
Was adequate price competition justified or explained away?
Were subcontractor proposals properly destroyed?
Was a sound selection process developed and explained?
Was required pricing and data obtained?
Does the subK plan eliminate risk?
Is government or real property being considered?
Are prime contract requirements turned into subK plans/requirements?
Does the subcontract comply with cost accounting standards?
Is the subcontractor excluded or debarred?
These can be complicated, but longtime CO Monee Robinson is famous for saying, “Yard by yard it’s hard, but inch by inch it’s a cinch.” The same goes for subcontracting.
If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation.
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