govtacct02

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?

Are you intending on claiming the executives' salaries in allocations to Government contracts/subcontracts?

Thank you all.

Appreciate everyone's input. Here are some answers: Can’t tell if the change you reference is with regard to a proposal on a not yet awarded contract or an existing contract. This is an existing contract. Are you asking because the FAR Part 15 reference is directed toward issues of certified cost or pricing data? Yes. Question is regarding disclosure requirements when financing is only element changed. Base contract was competitively awarded. Is the CO directing the change to the financing or is the contractor simply requesting for some reason? Contractor is requesting it. You have not identified the contract financing that is being changed and to what. Different financing or none at all? It would involve acceleration to payment schedule. If a current contract what stage, in general terms, is the contract in currently? It is a few months into a 4 year period of performance. Knowing a little more about the above may help with a more specific response but quick thought is if the reference to FAR Part 15 is not connected to matters of cost or pricing data then I would submit yes it porbably is an art specific to the contract at had in that it is a proposal to change the contract and that adequate information specific to the contract would be shared to evaluate the consideration be contemplated. That is what my initial thoughts were. But would like some feedback, understanding that it is not Legal Advice.