WinterMute

I have several contracts that currently have DFARs 252.242.7005 Contractor Business Systems but are CAS exempt. Until recently, it was my understanding that since the contracts are CAS exempt, the CBS requirements are not applicable since 252.242.7005 states, "This clause only applies to covered contracts that are subject to the Cost Accounting Standards under 41.U.S.C. chapter 15, as implemented in regulations found at 48 CFR 9903.201-1." My leads have now instructed me to request from the contractor a disclosure statement for their purchasing and estimating system regardless of their CAS exemption. Regardless of CAS, the ACO would have to make a determination for approval vs disapproval which would then be input into CBAR. My question is whether this is the correct interpretation of the CAS and CBS clauses since it seems very backwards to me. I have always thought that CAS drives CBS which leads to a system review rather than doing a systems review then determining CAS. The contractor is also hung up on the issue since they know they are CAS exempt.

I am currently dealing with a REA regarding property. Contractor had notified the government of excess GFM that had no movement for over 12 months. The PA had notified the customer of the GFM and asked if they wanted it back. There was no response for over a year and the contractor stored all GFM for the entire period of time. Now they want to submit an invoice for the storage fee and the contract is about to be closed out. Would an REA be the best way to deal with this and if so, would we have to create a CLIN to adjust? Another small issue is that this contract is not funded with US monies.

Issue: Is a COR required for a service contract if it is a full delegation to DCMA? Background: A new service contract (FFP w/ O&A) was awarded and delegated to DCMA and the procurement office wants to appoint a COR IAW PGI 201.602-2 to be onsite at the contractor's facility with DCMA. The contract does not meet the requirements for exemption. However, since the contract is a full delegation to DCMA and FAR 1.602-2(a)(4) preventing duplication of duties, the COR's authority is extremely limited.

The KTR is getting trained by the unit to complete a task so IAW the contract, the KTR is trying to reimburse the unit for TDY cost to send someone there. I am trying to find out what vehicle we can use to reimburse the unit. Possible option is to cut a check but I am looking up the legalities of a contractor writing a check directly to the unit. I dont want a check to go to the US treasury as the unit would be losing funds.