govtacct02

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.

This is one that is under the purview of the DCMA to review due to dollar value, so it is a DCMA analysis of a proposal.

Yes, and I also looked at the DFARs PGI 215.404-1 Proposal analysis techniques, (c )(iii). This is a cost monitor requesting we reformat the actuals into a specific cost monitor workpaper format during a proposal audit, and there are no specific instructions in the solicitation as to how to format to respond to audit questions. My thoughts are that nowadays it is not such a good idea to push back.

Just curious - what do other contractors do when you are supporting an audit of a TINA-covered proposal and the auditor says you have to transmit actuals to them in their format, vs. the contractor's format, where there were no specific instructions in the solicitation to submit in a Government or Prime contractor specific format?