GovCon 3rd Decade

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About GovCon 3rd Decade

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  1. There are many on LinkedIn, which is where all my clients have found me, but I would assume there might be many on this site as well.
  2. I would agree I have never seen language saying the new contractor has to pay the rate of the old contractor if it exceeds the wage determination rate published by the DOL, however, that is a good question since they are required to bring forward the employee's accrued paid leave to pay out when the time comes. So if it was accrued at a higher rate on the first contractor's books, does he get a windfall for that?
  3. Hi Vern - It just seems I am always hearing contractors trying to avoid CAS like it was the plague or rocket science, when personally I think is the easiest and most logical part of the whole FAR in my opinion, but I have yet to ever hear anyone say specifically what part of CAS it is that they are so desperate to escape from. Aside from having to complete a CAS Disclosure Statement, which is horrible old Government form, as they all are, it is actually much easier to fill out one of those, especially for an inexperienced contractor than it is to develop an indirect rate structure on a blank piece of paper. So, aside from the form and the fact that you are pretty much stuck with your first choice or have to complete the dreaded cost impact analysis to make a change (if you are unable to persuade them it is only an administrative change), which of CAS is it that everyone fears so much? I know contractors who purposely avoid growth to specifically to avoid the CAS threshold, which to me just seems crazy. If you can follow the rest of the FAR, CAS is easy. Maybe I have just been doing it too long, but I truthfully cannot think of a cost allocation method that would be better than any of the CAS. I would love to hear examples if anyone here actually has one to share. I also hear about the high cost of CAS, which I don't get either. Other than having to hire or rent a cost accountant or similar to set you up and provide instructions on what to put where, which is usually good to do anyway, it is pretty logical stuff. In my opinion, without a doubt, it is much easier to be CAS-compliant than to try to avoid it and win the argument, I think is what gets complicated and expensive. My soapbox.
  4. This won't be a popular opinion, but it seems to me if a contractor has mostly CAS-covered contracts, it would be difficult to pry one out and make it not follow CAS requirements. Personally, I think once you are modified CAS, it is much easier to just do full-CAS since it is usually just around the corner and better to practice ahead of time than be taken by surprise as most contractors are, during audit, learning CAS via CAS violations. Which CAS are you trying so hard to avoid following? It is just cost allocation, how do you want to allocate cost instead? I have never been able to get an answer to this question, but have never tried in this forum, and I know this forum has some die-hards like me who do not just disappear when the questions get tough, so i am thinking this is the best place to ask.
  5. M&S on B&P

    Joel - Thanks for the laugh. All - If you have not been to dcaa.mil lately, there is a new version of the ICE Adequacy checklist dated Nov. 2011, now 7 vs. 3 pages, but same stuff. I have also never had DCMA disagree with DCAA's decision on ICE or anything. I agree best bet is submitting ICE file with schedules in order, but I add several things to the ICE models that I do.
  6. M&S on B&P

    Thanks for the help, love your handle too. No worries on the ICE format, I have been doing these since the Lotus days long before ICE and make many adjustments to accommodate reality and my personal preference and have passed audits every time, I think it is substance over form, especially when the form does not accommodate the scenario. Things that bug me on ICE are not having pool, base and rate on same schedule (B/C) so mine do. Not showing rates on on costs by contract schedule (H) so I add onto mine and schedule (I) A/R does not split over/under billed between cost and fee, so I split but also show total. Add but don't delete.
  7. M&S on B&P

    Thank you for sticking with me on this. I hope you can see why I was struggling and how ultimately you have to break one rule to comply with another and the DCAA ICE evidently does not consider this scenario, which is not that unusual. Also wanted to say I love your logo!
  8. M&S on B&P

    Hi Joel - I did not want to not answer you, but I think you saw answer in later post, yes? What is DB=DataBase to me. Cheers! Teri
  9. M&S on B&P

    Ok, so not in G&A BASE...then #4 of #4 Last question was... Do those Unburdened B&P ODC's get included in B&P/G&A Pool (per DCAA ICE format) for allocation on G&A base? Do you see why I am asking this now?
  10. M&S on B&P

    Thank you for the follow-up, halfway there...Clear on A but not on B... A1) I do understand B&P/IR&D are just allocated on the same basis, just said that way to keep it short. A2) Thanks, I can do that. I will just override formulas in DCAA ICE Model. Won't be the first time to do. B2) Same answer as A1. No problem. I agree. But am saying again to be clear and to match DCAA ICE. B1) Not clear. ODC's are only burdened with G&A. So they either go in G&A/B&P POOL(s) or BASE?
  11. M&S on B&P

    Hi Vern - You have an excellent memory and yes it is the exact same question. I have a new client with the same issue and I still don't seem to be able to get a a complete answer. I totally appreciate those who have started an answer but no one seems to be able to get through the end. It seems that suddenly the concept of POOL vs. BASE evaporates. Maybe it is too long and I need to split into two and start in middle. A) So...Value-added G&A Base with M&S Pool, B&P Material is burdened with M&S... 1) Does the BP Material and its M&S Burden get added to the G&A POOL? 2) Does the remaining portion of the M&S Burden stay in the G&A BASE? Same Value-added G&A Base with M&S Pool, B&P ODC's belong in 1) G&A BASE with other ODC's? OR 2) G&A POOL with other B&P costs?
  12. When you have a Value-added G&A base because you have an M&S Pool to burden Materials and of course the B&P Labor with OH goes into the G&A pool to be allocated, does the M&S on the B&P Material also go into the G&A Pool? Then leave the remainder of the M&S burden in the G&A base with the other Overhead?
  13. FAR 52.222-43

    Joel - No problem, mine crashed so I don't see what I typed posted anywhere now. I understand any proposal uses estimated rates, no problem there, but it appears it would not matter what rates might be estimated since they cannot be recovered in billing since it appears there can be no escalation of direct or indirect costs proposed or billed, except for SCA wage or H&W rate increases which can only be burdened with payroll tax and workers comp on the increased base. No more OH, G&A or Fee on increased portions. No offense taken, I agree 100%, any contractor should understand the contract they are proposing on. I would never sign a contract I did not fully understand, but I was not there 3 years ago or even three months ago. I am an independent consultant hired to work on 2010 YE close in place of a terminated Controller. I am not doing proposals or billing, I am just trying to understand large losses on this contract for multiple years by looking at proposals and 52.222-43. Looking to confirm my understanding of how this should be done compared to what has been done and is still being done. (Also need to setup rates for 2011 and 2012, so that in mind as well). Was hoping someone might be able to fill in the piece I might be missing or share how they make this work to at least break-even or minimize loss since I just can't believe this is the intention. (Client did not even know there was a loss on prior years till I noted). Part 2 is not really a "sub", think consultant helping (prime) client with proposals whose costs are booked as G&A expense to client, indirect expense. Just ironic Govt thinks contractor does not incur/cannot bill G&A expense to process SCA increase proposals. Sorry to torture you with this.
  14. FAR 52.222-43

  15. EE Direct & Indirect

    Where can I find the rules to watch out for when I have an employee who normally works as Corp G&A performing Direct labor? He is fully qualified and there is no issue with labor categories or pay rate but he will physically be working on base vs. Corp office. I understand I want to have his Fringe follow his labor and occupancy if both spaces are not kept open and available to him to use. (in other words, I understand if someone else is sitting in one of his spots while he is in the other, occupancy allocates to the user). This is a temporary assignment to fill in for the regular person who will be away for multiple weeks at a time and more than once, but not a permanent change since this ee will ultimately return to his full-time Corp G&A position. Are there issues to be aware of?