Currently we're debating which funding type is most appropriate for funding modernization of a current capability's supporting system. Recent changes to some software platforms reduce the amount of actual development and relies more on setup which in my mind would dictate using PMC for the delivery of an operational capable system. Per multiple sources (DAG/FMR/FAR), Procurement appropriations are used to finance investment items, and should cover all costs necessary to deliver a useful end item intended for operational use or inventory. With that being said if vendors offer a part number for the resources to setup an application then I may need to use a combination of PMC for the setup of some of the functionality and RDT&E for something like a custom interface or a combination of RDT&E and PMC for the functionality that requires both a setup and custom software development.
It must first be re-stated that AbilityOne is a mandatory Government source subject to the prioritization shown in FAR 8.002. If the Government has an issue with performance on an AbilityOne contract, the FAR also outlines the prescribed steps for resolution at FAR 8.705-4/8.711. Ultimately, the contract will remain in the AbilityOne Program as long as another participating nonprofit agency exists to replace the non-performing/defaulting agency.
That being said, FAR 8.706 outlines the process for the Government to receive a purchase exception that would allow the Government to go outside of the AbilityOne Program. It isn’t likely that the exception would be issued without solid justification. In my mind, solid justification would be connected with changes to the requirement and/or documentation to show that participating agencies are unable to satisfy the requirement per FAR 8.004. Outline the impact to price, schedule, or quality in the justification.
An incorrect NAICS code won’t impact a contract currently being performed until the follow-on/re-compete. A change in NAICS code without a change in the requirement won’t exclude that incumbent. By adding the new NAICS code to their profile in the System for Award Management (SAM), they’re back at the front of the line per the Procurement List. The mandatory Procurement List for services relies on work descriptions instead of individual NAICS codes.
Per the Compliance Manual on the AbilityOne website, 75% of direct labor hours must be performed by people who are blind or significantly disabled. This direct labor ratio does not differentiate between prime and subcontractors.