govtacct02

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:

Has anyone had experience with a having to determine 'adequate consideration' under FAR 32.005, when the change involved only a change in non-commercial item contract financing terms? (Presume no other changes are being made.) As I read FAR 32, it seems like determining adequate consideration is somewhat of an art. Would the contractor have to provide a FAR-15 compliant proposal in order for the CO to determine whether the consideration was "adequate"?

Thanks.

Happy Belated Birthday Bob! Thank you for all you do to provide this valuable resource ! Hope it was a good day!

SpartanHead, I would add to the previous comments that since you are new to your company, you could benefit from an appointment with your Government Accounting department. They can explain the cost structure, the burdening sequence, and alert you with any other items that are pertinent to your position there. I always make a point to spend time with new people and provide them with all the tools they need to be compliant!

Thank you. I understand.

The question I have is:

As a contractor, can the SOFARS solicitation provision 5652.215-9011 compel me to submit a DD Form 1547 "Record of Weighted Guidelines Method Application" with my proposal to the buying command?

I am having trouble reconciling this with the prohibition in FAR 15.404-(c )(5) from obtaining breakouts or supporting rationale for [a prospective contractor's] profit or fee objective. Thank you.

An editable SOFARS provision reads as follows:

5652.215-9011 Proposed Profit/Fee (2005) Section L

As prescribed in 5615.408®, insert the following provision, Editable

Offerors are encouraged to submit a completed DD Form 1547 "Record of Weighted Guidelines Method Application" to support the proposed profit in accordance with DFARS 215.404-71. The DD Form 1547 and supporting documentation are/are not required. If submitted, the DD Form 1547 and supporting documentation shall be included in the cost volume of the proposal.

The solicitation we received highlights "are required".

15.404-4 -- Profit stipulates:

(c )Contracting officer responsibilities.

(5)The contracting officer shall not require any prospective contractor to submit breakouts or supporting rationale for its profit or fee objective but may consider it, if it is submitted voluntarily.

Fitz and the Tantrums - a little poppy but catchy - sounds a bit like a cross between Hall & Oates, classic Motown, and The Style Council.

Anything by Pat Metheny

Flamenco guitar (Ottmar Liebert, Strunz & Farah, Jesse Cook,et al), bossa nova (Getz/Jobim/Gilberto), or afro-cuban (Buena Vista Social club, et al)

My company has foreign affiliates (Poland) that will have to have training on FAR Cost Principles. Is anyone aware of a resource (besides a foreign based branch of a U.S. consulting/audit firm to obtain the FAR in Polish?

It does not help. The payment clause says that the contractor gets paid at the hourly rate for every direct labor hour. The hours worked were indisputably direct and we documented each hour. The contracting officer has not said that the hours were not direct labor, and acknowledges that we documented the hours. So those are not issues. She is saying that we can't be paid for the OT hours because we did not pay the employee by the hour and did not compensate him for the OT hours. It's not clear to me what cost accounting has to do with this. I just want to know if the contracting officer's interpretation of the payment clause is correct. Is there something that I don't know?

Please see the Wifcon Thread at the URL below. This should help.

http://www.wifcon.com/arc/forum410.htm

In this thread, Vern said:

"The T&M payment clause, FAR ? 52.232-7, paragraph (a), is very clear that if the contractor devoted a direct labor hour to the performance of the contract work, then it is entitled to payment at the hourly rate stipulated in the contract schedule. The clause does not condition payment on what the contractor paid or did not pay the employee who did the work. Under a T&M contract, payment for labor is not based upon incurred cost."

Can someone direct me to any guidance regarding whether the Service Contract Act applies to CONUS Contractor Employees who are working on a project OCONUS. I am curious if these contractor employees can earn overtime premiums when working Overtime OCONUS - over 40 hours/week.

Any guidance would be appreciated.

Please see the DOL website for FAQ's about the SCA applicability.

http://www.dol.gov/whd/regs/compliance/web/SCA_FAQ.htm

Edit: If they want to pay for advertising, they know how.

Bob Antonio

10 U.S.C. 2306( d ) and 41 U.S.C. 254( B ) impose statutory limitations of 15% for fee on experimental, developmental, or research work performed under a cost-plus-fixed-fee contract.

I work for a government contractor, and have been asked whether a CPFF supplies and services contract that includes development activities must be funded with RDT&E funds (for the development activities) to permit proposing fee in excess of 10% on those development activities.

Thanks for your help.

On September 14, 2010, Dr. Ashton Carter, Under Secretary of Defense for Acquisition, Technology and Logistics, issued a memorandum on the subject of Better Buying Power for the Department. In that memorandum, the Director of Defense Procurement and Acquisition Policy was directed to develop a cash flow model to be used by all contracting officers contemplating financing other than customary progress payments, such as Performance Based Payments (PBP). In addition, guidance was to be developed that ensures that the improved cash flow opportunities provide benefit to both industry (at both the prime and subcontractor level) and the taxpayer.

The tool is at this website:

http://www.acq.osd.mil/dpap/cpf/Performanc...d_payments.html

Has anyone had any experience using this tool, or any thoughts about differences in profit % to expect as a result of using the tool?

Thanks.

That is correct. It's the team designation. You need the FAO Org Chart to link the A/R to the Supervisory Auditor who oversaw the work.

Thank you all for your help.

Can anyone tell me what the alpha code in a DCAA audit report number that follows the fiscal year represents? I can't find it in the DCAM.

For Example:

1234-2011A2700001

I know what all the other parts of the audit report nubmer represent, such as FAO and activity code.

Thanks.

Can someone explain "ACRN" and "CASE" (QBI QAY WAY QDE QBC QZO etc) to me? I've searched but I'm not finding any info.

Thanks much

Dave

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Can someone explain "ACRN" and "CASE" (QBI QAY WAY QDE QBC QZO etc) to me? I've searched but I'm not finding any info.

Thanks much

Dave

Do you perhaps mean "CAGE" instead of CASE - as in Commercial and Government Entity (CAGE) Code?

I am assuming for this further answer that that the mod was issued to implement the technical change, stating that the equitable adjustment would be issued later. I dont know if that is accurate from what you said.

At any rate, I'd estimate what it would have cost to perform the original work, based upon the best info available at the time that the work would have been done ($a). I'd try to determine what the changed work cost to perform, if possible, If not possible, use the best info possible to estimate the cost of the new/changed work when it was or will be done ($.

Further assumption - there was no agreement on the adjustment at the time.

Your assumptions are correct.

I am assuming that the absolute value of the modification exceeds the contract's threshold for submission of cost or pricing data and no exception applies. The cost or pricing data used for deleted work is based upon the current estimate of what the deleted work would have cost. It isnt necessarily based upon the original, certified C&P data. Lots of stuff usually happens after the C&P data was certified, like revised sub quotes, a better understanding of the work, etc. Does that answer your question?

Qualification - the above answers are based upon "glittering generalities". There are all sorts of specific circumstances which deviate from the general rules. Recommend buying the Nash and Cibinic Books on "Government Contract Changes" or "Administration of Government Contracts"

The absolute value of the mod exceeds the threshold for submission of cost or pricing data, and no exception applies, so the cost or pricing data must be certified. The problem is that the technical change to delete the work was agreed years ago. I am told that the statement of Work was changed and the contract was modified but the Estimated Cost was not reduced. The giveback proposal for the deleted work is being done only now.

Can anyone explain how the "would have cost" rule would work in the context of a deletion in scope in a CPFF contract that occurred 2 years ago, and a technical modification of the contract was agreed to then (customer worked with engineers who did estimates of the change, but provided no cost or pricing data), but the proposal deleting the dollars is not being prepared until 2011? There were no actuals, and the work deleted is not severable.

Do we have to get cost or pricing data updated as of 2011?

Does the language in FAR table 15.2 referring to deleted work that says "(2) Include the current estimates of what the cost would have been to complete the deleted work not yet performed (not the original proposal estimates), and the cost of deleted work already performed." mean current estimates as of the date when the mod occurred, or as of 2011?

Thank you.

When conducting negotiations is it appropriate to furnish the contractor with the Government's Objective Spreadsheets (they are marked FOUO)? I've been in Pricing for a long time and we've never given the contractor the government's spreadsheets and we are now being asked where the regulatory guidance exists for not sharing the government position. Can you help?

As a contractor, I've been involved in negotiations with certain DOD Agencies that shared their spreadsheets with us.

See the discussion thread below. Does this help?

http://www.wifcon.com/discus/messages/8525...html?1229794075

I was curious to see what the WIFCON community thought about the Exec Order published on January 18 requiring review of all Federal Regulations.

What do you think will be the outcome?

http://www.whitehouse.gov/the-press-office...executive-order