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Corduroy Frog

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About Corduroy Frog

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  1. Yes, but one of the things given to me in the way of advice is to change the disclosure such that travel is reduced from the G&A Base. A small contractor is not going to be prevented from changing the disclosure as they are not subject to CAS. If they are not going to get G&A on travel anyway, then why leave it in the base and have the allocated amount just go over the cliff and not be recovered? The FAR Clause with the Alt I is written for T&M contracts but govt agencies have gone so ga-ga over this that they just won't allow G&A on anything anymore under any circumsta
  2. Thank you for the accurate depiction of FAR 52.212-4 Alt I. Small contractors are not in a position to bargain for anything but $0, so the widespread bulldozing of this trend continues. I appreciate your taking the time to respond, but the abuse of small contractors continues with no apparent remedy.
  3. Disallowance of G&A on Travel has been around for awhile. Most govt people will tell you that it is negotiable, but in the real world, small contractors have no negotiating power with aggressive COs who have found out they can get away with it. Perhaps the Boeings, Lockheeds, and SAICs can negotiate, but none of the small contractors that I know. The authority, I am told, is a FAR Clause with an "Alt I" attached. Now I'm finding out that the govt COs are so deliriously happy with their success, that they have started disallowing G&A on ODCs, Materials, and Other costs - eve
  4. Thanks for the responses. Previous history with here_2_help and C Culham have been helpful indeed. I don't want to be unappreciative of their help. This was my first thread since buying a new computer, and Bob had to help me with the logistics so I could post. The Sick Leave question for the above was a simple trial post and I was 98% sure I was correct. Forums such as this often get responses with links rather than plain English. And they are better than nothing. But many times lazy people (such as myself) would rather entertain a simple yes or no with minimal discussion, as op
  5. I have mis-stated the question. Does sick leave enter the calculation of meeting the H&W hourly rate benefit in a WD? In other words, if the H&W is specified at $4.22, does sick pay become part of the calculation to meet the $4.22.
  6. I just had a Claws-out Fangs-out with a customer of mine. He insists Sick Leave is a part of Health & Welfare. I say no. Is he right?? (This is a trial post - logistics have been difficult)
  7. Why doesn't the customer simply issue a mod changing the PoP? Am I missing something here??
  8. Thanks to the respondents. It appears that the E.O. only applies to certain contracts, not all contracts. My assumption was wrong.
  9. 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
  10. 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
  11. 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??
  12. 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.
  13. 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.
  14. 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.
  15. 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.
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