Re: FAR 52.222-50, Combating Trafficking in Persons in NASA contracts Carol Blum 04 Jun 2007 09:20 EST
Unfortunately, Robert, that isn't true and it's what makes the clause so onerous. The FAR clause applies to all contracts except commercial service contracts. Some universities have been successful with NIH getting the contracting officer to affirm, in writing, that the provisions of the clause ONLY apply to employees directly engaged in the project (it limits the scope and the tasks of education, written attestations, etc.). This approach relies on the ambiguity in the definition of employee that's embedded inside the FAR clause. This request for interpretation should be accompanied by a request for a pledge to modify the requirement when the final FAR clause is issued. That pledge to modify is equally important to get in writing to ensure that any changes (and limitations in scope and requirements) are reflected in current contracts. Carol -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Bloomberg, Robert Sent: Monday, June 04, 2007 9:50 AM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] FAR 52.222-50, Combating Trafficking in Persons in NASA contracts The clause only applies to SERVICES contracts, not to R&D, which, as a University, I presume you are doing. Also, the Govt calling it a service contract does not per se make it one. -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf Of Monique Anderson Sent: Sunday, June 03, 2007 10:40 PM To: xxxxxx@hrinet.org Subject: [RESADM-L] FAR 52.222-50, Combating Trafficking in Persons in NASA contracts Colleagues - The University of Maryland is working on negotiating a NASA contract and we have met terrific resistance on modifications to the subject FAR clause, 52.222-50 Combating Trafficking in Persons, either deletion in its entirety, or deviations (ONR, NIH, any other agencies so far?). Have any of you run into this clause in NASA contracts and successfully negotiated it out? Successfully included a deviation? If so, which NASA center was it and what was the outcome? Many thanks for your assistance. Monique Monique Anderson Assistant Director Office of Research Administration and Advancement University of Maryland College Park, MD 20742 (301) 405-6272 phone (301) 314-9569 fax xxxxxx@umresearch.umd.edu ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================