govtacct02

Thank you both.

When a foreign concern (UK; has a QMAC) is filling out the CAS Notifications and Representations and is claiming a foreign concern exemption , what is the compliant way to answer the question regarding the filing a CAS Disclosure Statement? Should they answer the question with information about their QMAC submission or leave the question blank since they do not have a CAS Disclosure Statement? Thanks!

We would have no way to provide that information to you without evaluating your particular situation...you have to go out for quotes...have you done that?

Thank you Bob. I read both side by side and the difference in the final one dated Jun 7 is that on the second page, the last sentence in the paragraph that starts "Effective immediately..." is revised as follows: "Contracting Officers shall implement this policy for all future solicitations that require a Certificate of Current Cost or Pricing Data [emphasis added] and, to the extent practicable, in currently open solicitations."

Here it is. USA000646-18-DPAP.pdf

Does anyone have a copy of the June 7, 1989 memo from Eleanor Spector entitled "Contractor Delays in Submitting Certificates of Cost or Pricing Data" that was referenced in Shay Assad's Policy memo (link posted on the WIFCON home page) ?

Yes, thank you.

Does anyone know where I can view a full copy of the CAS Working Group Interim Guidance Papers ? I had a link to a copy via DAU that was posted on this site years ago, however, that copy was missing pages at the end of WG Paper 81-25...and there is no longer a (publicly available) link on the DAU site. Thank you.

Here - Yes, you are correct, and also to respond to DOD activities that are using old guidance to make a CAS-related argument where rulemaking has not occurred. Thank you all.

I am looking for a reference I can cite that articulates when a Guidance memo/paper issued by DPAP or Defense Pricing expires. Can anyone help?

A CPFF subcontract (not construction) is being closed out (we are the sub) and we need to understand what the order of preference is : PO or subcontract document, with regard to period of performance. There is nothing in the subcontract to state order of precedence. The PO indicates the extended period of performance, and it added value to the subcontract. The subcontract was not modified when the PO was modified. Thanks.

You might want to read the Sikorsky COFC case on CAS 418 - selection of an allocation base for material handling that involved government property ($0 value on the books) was part of the debate. No. 09-844 ¶¶ 45-50; Sikorsky Aircraft Corp. v. United States, 105 Fed. Cl. 657, 674 (2012) (“Sikorsky II”)

As a follow up - my local DCMA office provided the adequacy review program, that includes conformity. If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had.

I am not a DCAA auditor. So srterral, I won't be able to take you up on your offer. Thank you anyhow. Joan - I do not see the term "conformity" in DCMA Instructions on CAS Compliance...or in Policy 120. Can you provide a more specific link? Thanks.

A few years ago, the responsibility for determining adequacy of a Contractor's CAS Disclosure Statement transitioned from DCAA to DCMA. Prior to that, when DCAA would review for adequacy, they followed a checklist of sorts to review the form part( vs. the Continuation Sheets) that contractors also found helpful. It is no longer in the DCAM, and I can't find something like it in DCMA instructions. Does anyone have an old copy of this tool that they would be willing to share? I am trying to use it for training purposes. Thanks.