Background: Defense contractor is providing services and products under "Commercial" definition via FFP subcontracts. Currently, the Finance/Accounting system is not set up to accurately provide direct and indirect rates for cost plus contracting. (GL doesn't notate unallowables) An accounting type has created what are believed to be reasonably accurate DCAA-like rates. (insert reaction here)
Current situation: Bidding via a prime to provide Modified versions of a Commercial item. Modification exceeds $700k (90% labor). DoD Contracts Specialist requests labor detail for cost justification. I VERY clearly & repeatedly state in both verbal and written form that we can only provide DCAA-like rates, as noted above. Since our DCAA-like rates exceed our standard published commercial labor rates by 10%+ resulting in a cost type proposal exceeding the price proposal by 10%+, the Specialist signs off.
Problem: DoD Contracts Specialist requests that I sign a TINA cert. Morally, I have no issue with signing off on our FFP proposal price, based on our Commercial labor rates. Given that our DCAA-like rates were provided merely to provide a rough estimate against our commercial labor rates, the accuracy, or lack thereof, should not give me pause. Correct?
Thank you.
BC