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About kdiekemper

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  1. Oh and here_to_help you are so correct. It's going to be interesting. ACO's and DCAA have not been responsive to assistance requests in this reqard - so should be interesting. Contractors do not have the same hammer that the Government does. Boy was that an eye opener going from a "Contracting Officer" to contractor employee.
  2. To answer the question on what's in our subcontracts. We include requirements from the allowable cost and payment clause to include the submission of the indirect cost proposal in all cost reimbursable subcontracts. The issue we are continually wrestling with is even if we do a review of the ICP and determine rates or we review the accounting system and using the guidance from DCAA on accounting system reviews and determine adequacy we can still be hung out to dry. It's real easy if the subcontractor has cost reimbursable prime contracts. Not so easy if they don't. Competing contractors d
  3. We do determine adequacy either through a previous DCAA review or through our own review. But the issue is really is the responsibility for the ICP. DCAA says its the prime contractor unless they have previously done one. Yet the FAR speaks to agency. Is the prime the CFAO for a sub?
  4. We as a prime contractor have been wrestling with who is responsible for reviewing a subcontractors final indirect cost rate proposal and determining the rates. It's an easy thing if the subcontractor has an approved accounting system but what if he doesn't and you are awarding a T&M subcontract. FAR 42.202(e)(2) states "The prime contractor is responsible for managing it subcontracts". Does this mean every function described in 42.302(a)? Further when you get to T&M subcontracts there is no requirement to flow down the T&M payment clause 52.232-7 nor is there a requirement to
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