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Posts posted by govtacct02

  1. Are you a contractor or a government buyer?  What is the G&A base for the selling or buying entity?  (Total Cost Input, Value-added, single element?)  We need more information to be able to help you.   Also, it appears you are looking at the DCAA Contract Audit Manual.  CAS 410 can be accessed at https://www.acquisition.gov/chapter_99/part-9904-cost-accounting-standards.

  2. If you agree to a $-0-or reduced amount for indirect costs using Alt 1, you are still required to follow your disclosed or established accounting practices for allocation of indirect costs.  You cannot reallocate that cost to other contracts without this restriction.  So  in effect are voluntarily foregoing recovery of allocable, allowable and otherwise reasonable costs.


  3. We're having them conduct floor checks virtually. However, in this environment, not everyone they are floor checking has a camera on their computer and they've been trying to use FaceTime or similar app on a smart phone.   Our employees don't like getting an unannounced video call while working from home during this situation, especially with ITC concerns.  We've had some concerns about social engineering, too.


  4. 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?


  5. 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."

  6. 22 hours ago, here_2_help said:

    I suspect the question has to do with whether DPAP and other DoD activities can avoid the required regulatory rule-making process by issuing guidance and memoranda that interpret regulations, without actually incorporating those interpretations into the regulations.

    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.

  7. 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.


  8. 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.


  9. 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.

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