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March 2007 |
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From
the editors of CCH's government contracts products, here are summaries
of the important recent developments in this practice area for the past
month. Complete coverage of these issues, and many more, appear
in the Government Contracts Reporter and related products. Legislative and Regulatory ActivityExecutive Order Subjects Guidance Documents
to OMB Oversight DoD Suspends SDB Price Evaluation Preference Executive Order Sets Environmental,
Energy and Transportation Goals Labor Department Establishes Chief
Acquisition Officer The CAO will report to the Secretary of Labor and may receive day-to-day guidance and direction from the Deputy Secretary. The primary duty of the CAO will be acquisition management. The CAO will also have the duties specified by Section 1421 of SARA, including: advising and assisting the Secretary of Labor on business strategy and acquisition activities; promoting full and open competition and performance-based contracting; establishing clear lines of authority, responsibility, and accountability for acquisition decisions; developing and maintaining a DOL acquisition career management program to ensure maintenance of an adequate professional acquisition workforce; and serving on the Chief Acquisition Officers Council. The CAO will also be delegated with several other responsibilities, including: carrying out certain authorities and responsibilities of the Secretary of Labor under specific laws and related regulations, executive orders, and OMB circulars and memoranda; prescribing regulations, policies and procedures regarding solicitation, award, and administration of DOL acquisitions of goods and services; assisting and coordinating with other agencies and DOL officials to ensure acquisitions and related procedures comply with applicable laws, regulations, executive orders, and OMB guidance; establishing and overseeing an acquisition advisory board; and maintaining and publishing a list of DOL contracting and grant officers that identifies the limits on their authority. DOL SO 2-2007 also delineates the responsibilities of several other DOL officials, including the Director of the Office of Small Business Programs, the Director of the Center for Faith-Based and Community Initiatives, the Assistant Secretary for the Office of Disability Employment Policy, the Solicitor of Labor, the Chief Information Officer, the Assistant Secretary for Administration and Management, the Chief Financial Officer, and DOL Agency Heads. For the text of DOL SO 2-2007, effective February 5, 2007, see ¶70,375.10. BIS Imposes New Export/Reexport Controls
on North Korea Pursuant to new EAR 746.4(c), BIS will review license applications for the export or reexport of luxury goods to North Korea under a general policy of denial. BIS will generally deny applications to export and reexport luxury goods such as luxury automobiles, yachts, gems, jewelry, other fashion accessories, cosmetics, perfumes, furs, designer clothing, luxury watches, rugs and tapestries, electronic entertainment software and equipment, recreational sports equipment, tobacco, wine and other alcoholic beverages, musical instruments, art, and antiques and collectible items including but not limited to rare coins and stamps. A new Supplement No. 1 to EAR Part 746 will provide further detail regarding the illustrative list of luxury goods set forth in EAR 746.4(c). BIS will continue to generally deny applications to export and reexport arms and related materiel controlled by the CCL and items controlled under the multilateral export control regimes, including items specified in UN documents S/2006/814, S/2006/815 and S/2006/853. Even though a license is already required to export and reexport to North Korea all items controlled on the CCL for nuclear nonproliferation and missile technology reasons, BIS will also require a license for these items, except for items classified under Export Control Classification Number 7A103. These licenses will be reviewed under a general policy of denial. Applications to export or reexport other items on the CCL will be reviewed in accordance with the licensing policy set forth in EAR 742.19. BIS will generally approve applications to export or reexport non-food, non-medical humanitarian items intended for the benefit of the North Korean people, such as blankets, basic footwear, heating oil, and other items meeting subsistence needs. BIS will also generally approve items in support of UN humanitarian efforts as well as agricultural commodities and medical devices not deemed to be luxury goods. Applications to export or reexport computer laptops and luxury automobiles will be approved if the items are being transferred to organizations legitimately involved in humanitarian relief efforts, other internationally sanctioned efforts, or efforts in the interests of the U.S. government. BIS will also generally approve applications for agricultural commodities (as defined in section 102 of the Agricultural Trade Act of 1978) and medical devices (as defined in section 201 of the Federal Food, Drug, and Cosmetic Act) that are not deemed to be luxury goods. BIS will review on a case-by-case basis applications to export and reexport all other items subject to the EAR. Items not requiring a license for export or reexport to North Korea prior to this final rule that are on dock for loading, on lighter, or laden aboard a carrier to a port of export on January 26, 2007, may be exported or reexported without being subject to this rule if the items are exported or reexported before midnight as of February 9, 2007. Exporters holding valid licenses for export or reexport to North Korea prior to January 26, 2007, are authorized to continue shipments pursuant to the terms and conditions of their licenses. GSA Authorizes Use of FSS Program During
State/Local Disasters FMR Amendment Clarifies Building Accessibility
Standards GSA Increases Reimbursement for Privately
Owned Vehicles
Court and Administrative Board DecisionsIllegal Kickbacks Also Violated False
Claims Act The court concluded a preponderance of evidence established the contractor's progress payment applications were false and knowingly used by the contractor to obtain payment of fraudulent claims in violation of the False Claims Act. The contractor's practice of submitting unpaid premiums resulted in two district courts entering judgments of criminal conduct and major fraud against the contractor. The contractor's controller also testified statements of payment were false. In addition, the court incorporated its prior opinion holding the contractor violated the Anti-Kickback Act (49 CCF ¶78,435). Because FAR 52.203-7(a) defines a kickback as an act of fraud, the Anti-Kickback Act violations also violated the False Claims Act. An additional consequence of the contractor's fraud was the forfeiture of its claims under the Forfeiture of Fraudulent Claims Act. Morse Diesel International, Inc. v. U.S., FedCl, 51 CCF ¶78,699. Indian Incentive Program Firms May
Subcontract to Non-Indian Firms However, the plain language of DFARS 252.226-7001 established the contractor's entitlement to the IIP payment. DFARS 252.226-7001(b) states a contractor shall give Indian organizations "the maximum practicable opportunity to participate in the subcontracts it awards, to the fullest extent consistent with efficient performance of the contract." Neither the government nor the SADBU were able to identify any statutory or contractual provisions that would supersede this language to preclude the IIP payment. In addition, portions of the comment/response field published with the final rule (¶70,016.245) that implemented the most recent version of DFARS 252.226-7001 expressly suggested the regulation did not restrict participating Indian organizations from subcontracting work to non-Indian firms. Here, the Indian-owned firm administered the subcontracts, and supervised, inspected, and bore ultimate responsibility for the subcontracted work. The contractor was therefore entitled to an adjustment equal to five percent of the amount paid to the Indian subcontractor. C.F. Jordan, L.P., ASBCA, ¶91,914. Override of Fee Determinations Breached
Contract Given the contract's specificity in designating the AFDO, the court concluded the government's contention more than one person could serve as the AFDO lacked merit, and the word "acting" did not support the government's argument the "Manager" encompassed anyone performing some of the manager's functions. In addition, the contract did not provide for concurrence by DOE's headquarters and, although the Secretary of Energy's authority over personnel decisions would have allowed him to replace the manager, it did not excuse the government from performing the terms of the contract. Moreover, because the contract required the award to be determined subjectively by the AFDO, the Secretary's mandated award could not be sustained on administrative-deference grounds. The fee determinations of the manager and his successor served as the benchmarks for measuring the contractor's damages. The Boeing Company v. U.S., FedCl, 51 CCF ¶78,695. Reissuance of RFQ No Basis for Reimbursement
of Costs The Comptroller General denied the request for costs, finding reimbursement was not appropriate because the protest was not clearly meritorious. As an initial matter, the GAO attorney advised the parties at the status conference he did not consider the protest to be clearly meritorious. A response to the protester's comments was requested and a hearing was contemplated because the merits of the parties' positions could not be determined from the existing record. The government had maintained it could not provide performance requirements because the end-user did not have them, and argued it was procuring a commercial item and the description of the agency's needs contained sufficient detail for the preparation of quotations. The protester had argued the end-user's lack of knowledge on where the system would be used did not preclude it from developing minimum performance criteria or relieve the government from providing sufficient information to compete intelligently. Since further development of the record was necessary, the protest presented a close question, and was not clearly meritorious. Alaska Structures, Inc., 22 CGEN ¶112,309. Justification for Default Terminations
Scrutinized The contractor fared better with respect to the second contract. The board found late performance on certain routes was not grounds for termination because the parties recognized the contract schedule did not include sufficient time for performance but failed to establish an adjusted schedule, a government official instructed the contractor to empty an additional collection box with assurances he would not be "written up" for being late, and two late route completions were identified "for information only" and should not have been listed as chargeable irregularities. The government also failed to show combining mail from separate trips was a problem during the months leading up to the termination, and the contractor's initial refusal to pick up mail from the additional collection box had been resolved. Although the contractor' lateness and omission of trips on a few dates were technically defaults under the contract's Termination for Default clause, the relatively few deficiencies were not significant compared to the number of trips required under the contract. In addition, the contractor's failure to pay invoices under the fuel program was not a basis for termination because the government was able to withhold from the contractor's payments and the last incident of an unpaid invoice was seven months before the termination. Derrick Van Greene, PSBCA, ¶91,905. Major Contract AwardsVion Corp. - $700 Million. The VION Corporation, Washington, D.C., received an indefinite delivery/indefinite quantity firm-fixed price performance contract with the award of the Enterprise Storage Services (ESS) contract. The maximum ceiling amount of the contract is $700,000,000. The goal of the ESS project is to obtain a reliable, responsive, and cost effective information storage infrastructure family of "on-demand" enterprise services for the specified operating environment at DISA and/or DISA approved processing locations. The period of performance is for a five year base period with three one-year option periods. The Defense Information Technology Contracting Organization, (DITCO) Scott AFB, IL is the contracting activity. Government Contracts Report Letter No. 1894, February 7, 2007. General Dynamics - $400 Million. General Dynamics NASSCO, a wholly-owned subsidiary of General Dynamics, Falls Church, VA, has been awarded a seven-year contract for the maintenance and emergent repair of San Diego-based LHA and LHD class amphibious assault ships. The contract includes options to be exercised by the U.S. Navy through fiscal year 2013. The value of the contract, if all options are exercised, could total approximately $400 million. Under the contract, NASSCO will perform 12 scheduled maintenance availabilities aboard USS Tarawa (LHA 1), USS Peleliu (LHA 5), USS Essex (LHD 2), USS Boxer (LHD 4), USS Bonhomme Richard (LHD 6) and the Makin Island (LHD 8), once the latter is commissioned and homeported in San Diego next year. Government Contracts Report Letter No. 1894, February 7, 2007. Lockheed Martin - $294 Million. Lockheed Martin Missiles and Fire Control, Orlando, FL, is being awarded a $294,000,000 firm-fixed-price contract for production of the Joint Air-to-Surface Standoff Missile (JASSM). This contract allows for purchase of USG requirements and potential foreign military countries as may be identified during the life of this contract. This work will be complete March 2008. Headquarters 308th Armament Systems Wing, Eglin Air Force Base, FL, is the contracting activity. Government Contracts Report Letter No. 1894, February 7, 2007. Northrop Grumman - $268 Million. Northrop Grumman Ship Systems, Pascagoula, MS, is being awarded a $268,099,114 cost-plus-award-fee/cost-plus-fixed-fee modification under previously awarded contract (N00024-06-C-2304) to exercise an option to complete the detail design of the DDG 1000 Zumwalt Class Destroyer. The mission of the DDG 1000 Zumwalt Class is to provide affordable and credible independent forward presence/deterrence and to operate as an integral part of the Naval, Joint, or Combined Maritime Forces. The total value of the detail design effort is $307,511,633. The Naval Sea Systems Command, Washington, D.C., is the contracting activity. Government Contracts Report Letter No. 1894, February 7, 2007. Bath Iron Works - $257 Million. Bath Iron Works Inc., Bath, ME, is being awarded a $257,473,700 cost-plus-award-fee/cost-plus-fixed-fee modification under previously awarded contract (N00024-06-C-2303) to exercise an option to complete DDG 1000 Zumwalt Class Destroyer detail design. The mission of DDG 1000 Zumwalt Class Destroyers is to provide affordable and credible independent forward presence/deterrence and to operate as an integral part of the Naval, Joint, or Combined Maritime Forces. DDG 1000 will provide advanced land attack capability in support of the ground campaign and contribute Naval, Joint, or Combined battle-space dominance in littoral operations. The Naval Sea Systems Command, Washington, D.C., is the contracting activity. Government Contracts Report Letter No. 1894, February 7, 2007. Raytheon Co. - $212 Million. Raytheon Company, Waltham, MA, has been awarded a $212 million contract by the Missile Defense Agency for the manufacture, delivery and integration support of one Terminal High Altitude Area Defense radar, also called the AN/TPY-2 radar. Under the terms of the contract, Raytheon Integrated Defense Systems will manufacture one AN/TPY-2 radar. The AN/TPY-2 is a high-power, transportable X-Band radar designed to detect, track and discriminate ballistic missile threats. Raytheon IDS designed and built the AN/TPY-2 radar for the Ballistic Missile Defense System and the Terminal High Altitude Area Defense weapon system. Government Contracts Report Letter No. 1896, February 21, 2007. United Technologies - $170 Million. United Technologies, East Hartford, CT, is being awarded a maximum $169,785,585 firm fixed price contract for engine lines. Using services are Navy and Air Force. Date of performance completion is Feb. 15, 2008. Contracting activity is the Defense Supply Center Richmond, Richmond, VA. Government Contracts Report Letter No. 1896, February 21, 2007. Lockheed Martin - $166 Million. Lockheed Martin, Bethesda, MD, has received a $166 million contract to provide 44 High Mobility Artillery Rocket Systems (HIMARS) to the U.S. Army and 16 to the U.S. Marine Corps. Work is scheduled for completion in February 2009. HIMARS can accommodate the entire family of Multiple Launch Rocket System (MLRS) munitions, including all variants of the Guided MLRS rocket and ATACMS missiles. Designed to enable troops to engage and defeat artillery, air defense concentrations, trucks, light armor and personnel carriers, as well as support troop and supply concentrations, HIMARS can move away from the area at high speed following missile launch, well before enemy forces are able to locate the launch site. Government Contracts Report Letter No. 1894, February 7, 2007. Computer Sciences Corp. - $151 Million. Computer Sciences Corporation, El Segundo, CA, won a contract to provide systems engineering and integration support to the Department of Defense's Missile Defense Agency (MDA). CSC estimates the value of the contract, which has a one-year base period and four one-year options, to be $151 million if all options are exercised. This contract follows an agreement CSC signed with the MDA in 2002. Under the terms of the new agreement, CSC will continue to provide scientific, engineering and technical assistance for the U.S. Ballistic Missile Defense System, which is designed to intercept and destroy enemy ballistic missiles and defend the U.S., its deployed forces and its allies. Government Contracts Report Letter No. 1895, February 14, 2007. Raytheon Co. - $144 Million. Raytheon Co., Waltham, MA, was awarded a $144,040,148 modification to a cost-plus-fixed-fee contract for FY07 PATRIOT engineering services. Work is expected to be completed by Jan. 9, 2009. The U.S. Army Aviation and Missile Command, Redstone Arsenal, AL, is the contracting activity. Government Contracts Report Letter No. 1894, February 7, 2007. McDonnell Douglas - $137 Million. McDonnell Douglas Helicopter Co., Mesa, AZ, was awarded on Jan. 31, 2007, a $136,900,000 modification to a firm-fixed-price contract for procurement of war replacement AH-64D Apache Longbow aircraft. Work will be performed in Mesa, AZ, and is expected to be completed by April 10, 2011. Contract funds will not expire at the end of the current fiscal year. This was a sole source contract initiated on Jan. 31, 2007. The U.S. Army Aviation and Missile Command, Redstone Arsenal, AL, is the contracting activity. Government Contracts Report Letter No. 1895, February 14, 2007. McDonnell Douglas - $114 Million. McDonnell Douglas Corp., Long Beach, CA, is being awarded a $113,700,000 cost-plus-fixed fee and firm-fixed-price contract modification. This is a contract modification to the C-17 Globemaster III Sustainment Partnership (GSP) contract to incorporate the CY07 Global Reach Improvement Program (GRIP) Follow-On Retrofit Projects. The CY07 GRIP Non-Block, Block 14-16 and Block 17 Follow-On Retrofit Projects incorporated retrofit efforts for the following projects: Block 14-16: 1) Mobility 2000 (M2K) Airline Operational Capability and Printer, 2) Secure Enroute Communications Package-Improved (SECOMP-1), 3) Communication Open Systems Architecture (COSA), 4) Weather Radar Replacement, 5) Stabilizer Struts System Redesign, Block 17: 1) Formation Flight System (FFS), 2) Required Navigational Performance-Improved (RNP-I) and High Frequency Data Link (HFDL), 3) Combat Lighting, Non-Block: 1) 400lb Troop Seats 2) Defensive System (AAR 47) (Group A Kits/Install only), 3) Extended Range/On-Board Inert Gas Generating System (ER/OBIGGS) II 4) OBIGGS II. This work will be complete July 2009. Headquarters Aeronautical Systems Center, Wright-Patterson Air Force Base, OH, is the contracting activity. Government Contracts Report Letter No. 1895, February 14, 2007. Raytheon Co. - $101 Million.
Raytheon Co., Waltham, MA, is being awarded a $101,089,119 firm-fixed-price
contract for the third full rate production (FRP-3) of 376 AGM-154C Unitary
Joint Stand-Off Weapon (JSOW-C), special tooling and special test equipment
(ST/STE), technical and financial data, an inert unit for ordnance testing,
containers for the missiles, performance characterization test, and cost
reduction initiatives. Work is expected to be completed in February 2009.
The Naval Air Systems Command is the contracting activity. Government
Contracts Report Letter No. 1894, February 7, 2007. |