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Corduroy Frog

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  1. 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 through of the benefit for fixed-price contracts, however, there's nothing stopping a force majuere equity adjustment reduction due to changed legislation. Due I have a clue what's going on with this section 3610? Comments invited. I am aware there is another thread going on that is more comprehensive. But I see a different picture than COs riding a white horse to help contractors via 3610. More like the above...
  2. 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??
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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" from the IRS - more important than ever under the new tax law - which eliminates job expenses for employees. The accountable plan requires a trip report from the employee, even if the travel is charged to indirect. Accounting for advances, per diem, extra airline charges, restitution of money to employee or the company, etc. All of this sucks up ridiculous amounts of time and administrative effort. And any time the JTR is exceeded without permission subjects the company to an uncompensated loss.
  8. 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 contractor. We all know the govt is not supposed to respond with bias if a contractor does this, but most of us know those in the agency will hold a grudge.
  9. 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 is not allowed on Travel and ODCs for purposes of capturing revenue, does a contractor still have to do so for cost purposes on an incurred cost submission? If so, their G&A rate does not change, and they cannot recover the loss. ji20874, thanks for your comments, but you tend to minimize the effect of this. Chiefly, because no other element consumes as much administrative and G&A time as Travel. Advances, JTR, Expense Reports, etc. Not to mention application of JTR can result in a real loss if G&A is not allowed. There is real cost involved, not just imagined indirects.
  10. 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.
  11. 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?
  12. 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 one on this forum was aware of such a "new FAR clause." I wish to raise the discussion again, because many customers all-of-a-sudden insist that no G&A be priced with Travel. On the face of it, very few things require the administrative time like Travel does.
  13. Thanks. I've heard of Procas but know very little. Does anyone have hands-on experience with Lojix? Or even heard of them?
  14. What happened to the unallowability of legal costs where the government is the defendant?
  15. Does anyone have experience with both CostPoint and Unanet? I'm looking for a comparison. Possible factors for discussion include - capabilities, user-friendliness, and cost. Knowledgeable people out there are invited. Thanks, Corduroy Frog.
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