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VinceS

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About VinceS

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  1. My company has an approved accounting system and for the last few years have received approval letters (with no adjustments) to our provisional rates. We also submit our Incurred Cost proposal each year. Our DCAA has a backlog and they are currently reviewing 2013! This is another issue that is detrimental to us as a small business. If we need to wait until rates are approved for this particular contract (which ends in Sept 2017), we could be waiting many, many years. Our normal practice is to bill provisionals for the upcoming year and do a "true up" at the end of the year. This helps us get as close as possible to what we believe will be our final rates. The prime contractor is an extremely large business. We met with them earlier this week and I requested that they just call an audit on us (Government or 3rd party as we will not provide any proprietary information directly to them). Thank you for all the feedback.
  2. Appreciate the feedback H2H. FAR 52.216-7 is in the subcontract.
  3. The terms of the subcontract state that we will provide DCAA approval letter. Based on FAR 42.704, I was not aware that DCAA would not review/approve our rates, which leaves us in this bind.
  4. I am currently a CPFF subcontractor under a Government prime contract. My company cycles on a calendar year and each January we update our provisional indirect rates for the upcoming year as well as calculate our final rates for the previous year. These rates are then provided to DCAA for review/approval and used for billing purposes under any CR contracts. This year, DCAA has stated that since we do not have a CPFF or T&M prime contract ourselves, we do not have a requirement to submit our PBR and they will NOT review our 2017 provisional rates. Our Prime contractor will not accept our updated rates for the CPFF subcontract since we do not have approved rates. As a small business, if we continue to bill using the provisional rates of 2016 (which were approved), we will be operating at a loss for 2017. In accordance with FAR 42.704 (c), billing rates may be prospectively or retroactively revised by mutual agreement between DCAA and the contractor. Without DCAA agreement, how is a subcontractor able to invoice for rate adjustments?
  5. Thank you for the feedback gentlemen. The criteria regarding the incentive still remains vague and we have a meeting set up this afternoon but I think you are on the right track Vern. It appears it will be performance driven. Appreciate you taking the time to discuss.
  6. That was the first question I asked H2H. What is the criteria for the incentive? The answer was vague, so I am trying to figure out my plan for pricing this. I was curious to know if others out there had encountered this before. Thanks for the feedback.
  7. Is there such a thing?! We are a small business subcontractor responding to an RFP with a large business prime. We previously provided a T&M proposal, as requested. We just received a revised RFP to now price TIME & MATERIAL / Incentive Fee labor rates, which requests a T&M rate with a base fee and another T&M rate to include an incentive fee. I have never heard of this contract type. Has anyone ever encountered this? Is there information out there? My google searches have not returned any results. Thank you for your time!
  8. Thank you for your assistance. I appreciate it!!
  9. Thank you Don. We do have that clause in our prime. I just wanted to be certain that any contract type could be utilized, regardless of the business size of sub or their accounting system standings.
  10. Are there any restrictions on the contract type that I issue to a subcontractor? My prime contract is a CPFF for services. We are bringing on a very small business (KO approved subcontractor) and I know they do not have an approved accounting system. I have searched around and have seen that an "approved" accounting system is not actually required but more of an indicator that the contractor is responsible. The subcontractor has only performed on T&M contracts in the past and would like to stick with that. Do I have any restrictions on issuing them a T&M subcontract? Does FAR 16.1 apply or is that just used for government to prime? Thank you!
  11. GAP in extending POP

    I just heard back from the prime and you comment about 'effective date' is accurate. They state that there is a new effective date. However, they are still trying to modify our existing Task Order with two seperate POP's but not seperating out the funding. I am arguing that if we have to track this seperately. Am I wrong? History: It has happened before but the gap was backdated and our risk period was covered. They did request that we not proceed, however, we took the risk and will now eat those two days. This is a T&M Task Order
  12. Background: I am a subcontractor working under a particular Task Order for several years. The end customer just recently delayed the extension of the period of performance for our effort. The POP expired on 30 Oct and the end customer didn t modify the contract until 3 Nov. Now our prime contractor sent us a modification stating that the POP expired on 30 Oct and the current POP begins 3 Nov. This is all within the same task order on the same line. And the funding is in one lump sum. I am not privy to the govt mod to the prime, but I just assume is was an extension of the end date. Question: Is it possible to have two (2) POP s within one task order for the same effort with only one bucket on money? I would assume that if they are not going to bridge the gap, we would either need a new line on the TO or a completely new TO, correct?
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