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  1. Quick Question, My company has a fixed-price contract with the government where we are paid agreed upon amounts for certain deliverables throughout the year. Today I received a notice from the Contract Officer indicating that if the shutdown lasts through October 15th, my company should stop work at that date in accordance with 52.252-15. Since this is fixed price, I'm not really sure I fully understand what we should do. If we have deliverables due in November does this mean we shouldn't work on them after October 15? I have to pay my staff either way, so surely they can work on them. I can understand that we should limit incurring any cost-reimbursable charges, but that's limited to travel in our case. I assume this is so that we can't come back to the government claiming that the shutdown caused us a lot of additional expense, but not having our staff work on the deliverables would seem to be more costly to us, not less.
  2. Can someone provide some insight on the following scenario? Assumptions 1. A federal cost-reimbursement contract or grant is coming to an end. 2. Severance is allowable on this contract or grant. 3. The contractor does not have a severance reserve, but rather treats severance as a current period expense. Scenario: Contractor severs an employee on the last day of the contract. The contractor has an agreement with the employee stating that severance will be owed to employee upon termination. The severance is disbursed on the next scheduled pay period which falls in the subsequent month. Contractor is on the accrual basis. For simplicity's sake, let's also assume that the employee has only worked on that one contract/grant. Question: Is severance obligated as of the last day of the contract/grant regardless of the fact that payment is actually disbursed in the subsequent month? My assumption is that severance is obligated as of the termination date and the contractor is merely liquidating that existing obligation. Accordingly, severance could be charged to that contract/grant given that it is otherwise allowable. Alternate Scenario: Contractor allows the employee to ride the bench for a couple weeks while trying to place him on another contract. Unable to do so, the contractor severs employment. Question: Given that the employee was severed subsequent to the contract ending date, could the severance payment still be charged to the contract/grant or would the contractor have missed its window?
  3. I work for a non-profit organization which has both federal contracts and grants. A couple of questions have come up recently regarding subcontractor classification in our reporting. It is a bit confusing, so I'm hoping someone can lay it down simply for me. 1. We use a modified total direct cost method of calculating our Indirect rate. Under A-122 we exclude all but 25k of subcontractor/sub-recipient costs from direct costs when calculating our indirect rate. We determine what is a subcontractor/sub-recipient vs. a vendor consistent with the definitions given in A-133. 2. When reporting our subcontracting for small business reporting purposes we use a broader definition of a sub-contractor that (at the risk of over-simplifying) basically includes any contracted good or service. Because we use the term subcontract in both instances, it is causing some confusion when reporting to management. I guess I just want to confirm that the term "subcontractor" has different meanings depending on the context. Does anyone have any suggestions of how I explain this to management? Thanks!
  4. Yikes. So if we are a subcontractor (subgrantee) to a prime grantee and only bill the prime on a cost-reimbursable basis (grants being cost-reimbursement) then we'd possibly trigger the Price Reduction Clause. Looks like I have a lot to look over. Thanks for the advice.
  5. Thanks Heretalearn. That is helpful. In regards to your 3rd point, are you stating that any subcontract we have with a non-federal entity (even if the prime contract is federal) can be considered commercial? If so, that increases the amount quite a bit. Regardless, we do have some other commerical work even though it is comparatively small. The problem is that even for that work we price out the projects by estimating the actual cost, loading it with overhead and indirect costs and tacking on a fee (our work is strictly service in nature). We don't maintain an active price list as we price out each job separately. I just don't fully understand how I can back up a price list (consisting of say.. an hourly rate based on position) when I don't currently invoice in that manner. Will the GSA allow me to demonstrate my past project budgets with fully loaded salaries mathematically correlates with the pricing list I generate?
  6. The company I work for is non-profit organization looking to apply for a GSA Mobis Schedule 874 Contract. I have been tasked with working through the Pricing Proposal. The issue I'm having is that while we have several relatively large federal grants and contracts, we have very limited commercial work. While I believe I can come up with a pricing schedule fairly easily based on our salary structure and cost loading, I'm not sure how I can provide the required pricing backup in the form of commercial invoices and contracts given that most of our current work is federal cost-reimbursement in nature. Does anyone have any suggestions on how I should approach this problem? Thanks!
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