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About Retreadfed

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  1. Its not how DCAA would view this practice, but what does the FAR say on this? Look at FAR 31.202(a) and see if charging these costs direct would comply with the guidance set forth there. To me, the key phrase is "in similar circumstances." One thing to remember is that 31.202 is a part of cost reimbursement and T&M contracts because of FAR 52.216-7.
  2. Carl, can you explain this? It seems you are saying that the parties need to agree on a constructive change before it can be implemented.
  3. What do you not agree with? You asked if it was permissible to base fee on travel costs. I answered that nothing in the FAR prohibits travel costs being considered when computing fee. If you disagree with that, give us a FAR citation that supports that conclusion. I also gave you my thoughts on why it made sense to use travel costs when computing fee. Maybe you have different ideas on that, but that does not negate the answer to your question.
  4. Sherrie, do you have access to an attorney who is familiar with CERCLA (Comprehensive Environmental Response and Cleanup Liability Act)? If so, I suggest that you contact him/her to discuss your potential liabilities as an arranger for disposition of the oil and what steps can be taken to mitigate that potential liability.
  5. Is 52.217-8 in the prime contract? Is it in the subcontract?
  6. Is this a BOA from (a) the government or (b) a higher tier (sub)contractor?
  7. Berniecia, you said this was for ship repair. Was the delivery date predicated on the ship's availability? Did the original contract have an over and above clause in it? If so, is the new work, over and above work that would be done in a new availability?
  8. Are you really talking about an audit or a program review by the IG? IG's call a lot of things audits that are not really audits.
  9. An ADA violation occurs when there are not sufficient funds to cover an obligation. This does not necessarily mean that there are not sufficient funds in an appropriation. A violation can also occur when an activity makes an obligation that exceeds funds allocated to it. For example, you make an obligation for $12K but only have an allocation of $10K, you likely have committed an ADA violation. In this regard, the person who commits the violation is the person who made the obligation, not the person who certified the funds availability, although this may be a mitigating factor.
  10. This happen sometimes. For example, the need for linguists in Iraq and Afghanistan has caused companies to hire people they otherwise would not hire. Further, employment of such people is frequently contingent upon them passing a language test with a certain score.
  11. Did contractor A file a termination settlement proposal in response to the T4C? If so, what is the status of the proposal? Was the T4C retroactive to the beginning of the contract or some other period prior to it being issued? Did it also file an REA to compensate it for the effect the T4C had on the cost of performing the other work?
  12. These two statements are inconsistent with each other. Can you clarify? Please note that I asked about a task order not the SOW in the contract.
  13. Just to be clear, are you saying that the government did not issue task orders to cover the minimum quantity stated in the contract for each period? Did the task orders which the government did issue cover the work at the facility where contractor B performed? Finally, does the contract have a clause in it that says what the contractor is entitled to be paid if the minimum quantities are not ordered? Such a clause would not be a FAR clause. As an aside, a requirements contract does not have a minimum amount the government is bound to order.
  14. File an REA for what and on what basis? What do you mean by "obligation monies"?
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