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  1. What is the interpretation or normal business hours for this cost principle application? FAR 31.205-46( "Airfare costs in excess of the lowest priced airfare available to the contractor during normal business hours are unallowable except when such accommodations require circuitous routing, require travel during unreasonable hours, excessively prolong travel, result in increased cost that would offset transportation savings, are not reasonably adequate for the physical or medical needs of the traveler, or are not reasonably available to meet mission requirements. However, in order for airfare costs in excess of the above standard airfare to be allowable, the applicable condition(s) set forth above must be documented and justified."
  2. we have never charged audit/tax work as direct expenses before, directly to a contract. it has historically been treated as G&A costs, G&A indirect cost pool. in this particular year we moved from corporate governance costs of registration and establishment of business in this foreign country which we charged to G&A, to annual audit work that is specific to audit work and tax work to be in compliance in the country and therefore, in contract compliance relative to only two contracts; therefore, this is a change, but it does not seem equitable to charge domestic or other country projects in this case when this work is benefiting only work in this foreign country. In reading FAR, I can see logical arguments both ways; however, while direct expensing will be an allocation to both a FFP and a CPFF contract, it does results in a higher value billed than the result of this expense being charges to a G&A account.
  3. does anyone know how DCAA would want legal and accounting costs specific to contracts in a foreign country accounted for? we have always treated legal and accounting as G&A costs; however we have some costs that are specifically grown out of having to comply with in-country tax laws, reporting, filing tax returns to be in compliance in that country. We have not charged legal and tax work as direct costs before, but they do not exactly fit a homogenous definition either.
  4. Thank you all for your feedback. It has been helpful and informative as this just doesn't seem acceptable given we have worked with this government customer before and have not had any issues submitting pricing of our subcontract, or a subcontract of ours, directly to the PCO. This has been incredibly helpful to determine appropriate pushback to the prime and the PCO and has taught me the importance of how to structure questions and receive information when there is a go between.
  5. while other areas in section L refer to only Major subcontractors, which we are not, the following is the section L piece that really baffles me why they are connecting proprietary information to be allowed to be sent to the PCO only if they are a MAJOR. I would have never interpreted it this way... We are not a Major sub and section L seems to indicate to me that Major subs have to submit in the same manner and format as the prime. Subcontractor Information: Proposals for all major first tier subcontractors shall be submitted within the prime contractor’s proposal. Major subcontractors are those whose cost equals 15% or more of total cost. Nonprime cost proposals should be submitted through the prime to the PCO. If the subcontractor considers its information proprietary, it may be submitted directly to the PCO by the same date and time the prime contractor’s proposal is due. The prime proposal shall uniquely identify major subcontractor costs within the supporting cost documentation. Subcontractor cost documentation shall be submitted at the same level of detail and in the same format as the prime’s cost proposal. Prime contractor cost detail must clearly identify portions of the proposal where supporting detail is provided by the subcontractor. The prime contractor is responsible for the consistency of the cost data between the prime contractor’s submission and any subcontractor data submitted directly to the PCO. The bid is well over $2mil and our component is over $2mil and we are not 15% of the total submission. It also allows for the prime to make changes to a subs pricing and to explain to the CO the changes and how the prime plans to negotiate or obtain discounts to a subs pricing. I do believe one members comment on this post that the prime could be confusing cost disclosure among other things to be valid. It is becoming hard to determine the prime's responsibilities in managing subcontractors and validating their bids with what is reasonable to request under competition.
  6. We have always had and also given the approval to provide the sanitized version to the prime and submit the proprietary unsanitized version to the government directly. We are not experts at the bid process by any means, so looking for valid options to push back and align the prime with what has been an ordinary process that we have experienced in the past. However, it seems you are saying "do what you are willing to do". There isn't necessarily a standard here.
  7. We are providing a firm fixed price proposal to a prime contractor. The prime contractor who is bidding under their small business wants us, the minor subcontractor, to provide base costs, actual labor rates, indirect rates to them and claiming the reason is to be bid compliant. Their subcontractor pricing model included tabs to provide details of how the FFP was arrived at, as well as a DCAA tab which provided for a request of base rates, OHD and indirect rates. We have never had to do this before, nor have any of our subcontractors done this for us. We are asking to provide a sanitized version to them and to provide our proprietary information directly to the CO as the section L describes. Their argument is that option is only for MAJOR subcontractors. They request we send them a sealed envelope which they will pass on. Well...the government customer did also give them the option to send the bid in electronically. We have worked with the government customer before and this handling is unlike any past experience; however, the prime is using "risk of non-compliance" as being the reason we have to provide these details. This seems to come up more and more as a sticky issue with companies claiming it's required and in some cases necessary to show management of the subcontractor. Do subcontractors have to provide proprietary information which could include actual labor rates, indirect rates, fee, etc to prime contractors when bidding on subcontractors? Is this one of those areas where there are no hard rules, FARs or protections in the bid process and is up to if your prime asks the CO the right way?
  8. Extend of Services in accordance with FAW 52.217-8 Option to Extend Services in accordance with the Performance Work Statement units is months. It is extended because the contract is part of a multiple task order contract that was awarded to another contractor and it does not begin yet.
  9. Under a DOD FFP contract does a contractor have to agree to a multi month extension without any adjustment if the cost to employ specialized personnel resulted in materially higher compensation than originally bid?
  10. In response to Retreadfed: When it was written in "available in case they are requested" it was accepted to satisfy the "small business" prime who wasn't sure what their duty of collecting receipts really was. We made it clear that meant they would be retained and available for any DCAA request and audit. WE do supply travel details which does show employees name, vendors, travel dates, to/from airfare and the fully burdened cost amount. We disagreed with providing them copies of receipt details as under cost plus this is a competitive disadvantage to have all detail cost breakdowns, actuals, indirect rate percentages applied and fee known to companies we also compete for business against. The specific costs they are asking for are direct travel costs primarily lodging and meal perdiem that is within the cost regs. Agreed, we shouldn't have to supply them within the cost regs of 31.205-46. Part of their reasoning is they want to make sure the rate is applied right for the particular locale the employees are being paid perdiem. On this particular contract its only one work location, but if we choose to pay a perdiem that meets or is even less than the allowed locale perdiem, it's our opinion we do not need to supply that.
  11. Is a prime contractor required to retrieve and retain detailed travel receipts from subcontractors on a cost plus contract? If not specific in the contract does a subcontractor need to provide the detailed receipts to prove compliance with 31.205-46 and JTF, FTRs? In this scenario, this particular request comes from a prime request to start submitting travel documentation to assure compliance with 31.205-46. The subcontractor pushed back since it is a cost plus contract, the subcontractor does not believe it's a reasonable request to provide the actual cost which further reveals indirect rate, fee and other proprietary details. We could one day compete against them in the same market space. The subcontractor per the contract is required to provide a summary of travel costs with monthly invoicing and to have available original receipts etc. etc should they be requested. This language developed out of pushback to the prime who wasn't sure what they were really required to do on retainment, so they felt safe even though we explained we would not be in agreement to submit actuals that are revealing of indirect rates, fess, and other proprietary business details such as our own internal travel reimbursement policies an practices.
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