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Corduroy Frog

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About Corduroy Frog

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  1. Why doesn't the customer simply issue a mod changing the PoP? Am I missing something here??
  2. Thanks to the respondents. It appears that the E.O. only applies to certain contracts, not all contracts. My assumption was wrong.
  3. On Labor Day, 2016, President Obama issued E.O. 13706, outlining a requirement for all federal contracts to observe/allow 7 days of annual sick leave per year. There were differences between sick leave and vacation, for example non-recognition of liability and inability to carry unused balances from one year to another. Most companies had amalgamated Vacation and Sick Leave into a single benefit - called "Personal Time Off." The Executive Order completely unraveled that concept by requiring separate recordkeeping for Vacation and Sick Leave. Emphasis all in the first line. Don't t
  4. Most emphasis is being placed on Sections 1102 & 1106. But from deep in the bowels of this thing comes Section 3610. I don't understand it and I can't seem to get a plain English version. DoD has hopped on this thing and issued a memorandum. If DoD does it, I don't know what's stopping other agencies. The general perception on my part is that contractors must credit the costs resulting from loan forgiveness and pass on: the cost benefit to the govt for cost-plus contracts. the recovery benefit in terms of hours to the govt for T&M contracts. No pass thr
  5. Now I'm being told that for companies sufficiently small, their entire payroll costs can be forgiven, even for employees who are working on a contract. To reward the company for "not laying off anyone" even if they wouldn't be laid off anyway. I can't believe that a company can get loan forgiveness plus bill the govt for a contract already in place. Double-dipping. If this is true, contracting officers would have the right to insist that contractors reduce their billings for amounts that correspond to loan forgiveness. Comments??
  6. A Communique from a contract officer stated that the charging of an indirect account could not be used to increase rates for purposes of cost reimbursement. Anyone heard the latest on this? I think the contracting officer was just passing down what she had been sent.
  7. Whether the fee can be added to the cardholder depends on state law. IOW where you live or operate. However, states that prohibit adding the fee to the payer somehow exempt themselves, and will not hesitate to add a "convenience" fee to someone's tax bill if they pay by credit card. IRS accepts credit cards, but will add 2% to any payment agreement involving a credit or debit card. Just yet another case of governments exempting themselves from unfair legislation forced upon its constituents.
  8. Thank you Mr. Culham. Joel, I don't know whether a contractor can insist on payment terms or not. Small contractors do not have that much bargaining power. Payments from Gov't credit cards bring heavy fees - like 4% which can eat into a fee big time if unexpected.
  9. Sometimes the govt chooses to pay the contractor with a govt credit card. Suppose the gov't pays $3000 to a contractor on a credit card. The credit card charges 3% to the contractor, or $90. Question: Since the fee is based on a percentage, is it the same as a commission (selling expense). If so, does this make the $90 unallowable cost? It is a necessary cost of doing business but it is still a form of commission.
  10. Thanks to everyone who has contributed. From the standpoint of the contractor, few COs are as consistently fair-minded as ji20874. Most of them see nothing but dollar signs and are adamant that the government is going to save money by denying G&A on travel, not considering that the contractor will make up the loss somewhere else. I have to take issue with Here-2-Help, normally a reliable source of good information. Administration of travel is indeed a time-consuming tar baby, and to assert otherwise makes me think one has never had to deal with it. We now have "accountable plans"
  11. Thanks ji. You may not have been on the other side (contractor), and should be aware of some real world (but unwritten) factors: The negotiating power in most cases are overwhelmingly in favor of the government. The contractor is chosen out of several competing contractors and cannot negotiate with an agency who insists. Only in cases where the contractor has clear, attractive and unique capabilities can a contractor be on level ground with the government. If a contractor files a claim, or sometimes even when they lodge a protest, many agencies become infuriated with the c
  12. Thanks to all who are participating in this discussion. All of you are more knowledgeable than myself. However: If a company is disclosed as a "total cost input" methodology for cost allocation, can they change as a result of this relatively new phenomenon? Regardless of what Huntsville RFPs are saying, contracting officers are going after this new approach like a pig after slop. Incurred cost submissions address cost only and not revenue (except for the section addressing T&M). And there are several instances where revenue does not flow as cost does. So if G&A i
  13. Thanks for your help ji20874. So far, the problems have been with proposals submitted in the last several months - no awards. The RFPs do not contain the FAR clause. Forgive me, also, but I'm not familiar with Alt. I, and I don't encounter Alt. I in my searches.
  14. Thank you ji20874 for your response. I have read FAR 52.212-4 in its entirety and find no mention of travel. Is it possible to produce a paragraph in response, or a link to the relevant passage?
  15. I began a discussion on this a few months ago, when certain agencies were disallowing G&A on Travel Costs. The result of the discussion was that only GSA work would disallow G&A on Travel and even then only with negotiations with the contractor. Since then, it appears Disallowance of G&A on Travel is sweeping the industry like an epidemic. We are told (as several contractors in Huntsville AL have been told) that G&A is not going to be allowed on Travel. One of the agencies said there is a new FAR clause disallowing it. When I raised the discussion a few months ago, no
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