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  1. I see the FAA doesnt follow FAR. They start the rfp with a standard form 33 (FAR) but then no reference of the body of regulation. I see now that it is AMS and it appears that AMS does not have distinct definitions and has more flexiibility to make a ffp adjustable for hours not worked. thanks for directing me to the right place.
  2. FAA and it is a negotiated rfp.
  3. I've read the rfp. it is not a FFP LOE, it is not a FFP economic price adjustment. It states it is a FFP period. It has a clause for an adjustment annually for SCA wages and benefits. It has a clawback exercised on an annual basis for labor hours less than planned by x% by LCAT type. The contract from this administration does not reference any FARs in the contract.
  4. What regulation allows for clawbacks on a FFP contract if DLHs are less than x% of planned DLHs? Are clawbacks allowable?
  5. Other than a documented medical reason, are there any exceptions in JTF DOD travel regulations to allow a contractor to book business or first class over coach fare for travel to an international place, say Japan from NC? Such as the employee would be required to leave on Easter Sunday and he doesnt travel on Easter Sunday so had to book a Monday upgrade to available Coach fare to make it there in time?
  6. We seem to continually overprice bids. I think it comes down to hours DLHs and fringe hours we calculate. Is there any recommended reading or training on how to calculate labor and DLHs and fully burdened rates? For example, if the government wants a T&M rate for a certain 19 week period, an annualized rate calculation doesnt potentially recoup all the costs, if the person uses some of the time off in the period. What is the best practices to determine the denominator of DLH (productive hours)? This type of training and guidance would be helpful.
  7. we were teaming among many with no guarantee of work and there is no signed subcontract with fixed T&M rates stated. We submitted multiple rates and we were asked to reconfirm them a few times and I believe there was a good through date specified. They are now actually providing a few positions after a long Covid delay hindering the contract starting.
  8. If a T&M rate was provided in the RFP stage in 2018 and the contract is finally starting in 2022, is a sub committed to that rate or the T&M rate can be re-evalucated upon getting the work? Are T&M contracts only considered variable cost contracts for ICE model purposes?
  9. Contracts ebb and flow which affects the TCI indirect rate calculation. For bidding future work, when the indirect rate is high due to decreases in contracts, is there a max indirect amount the government would allow? I have only read that "fees" over 10% draw scrutiny.
  10. We have a Firm Fixed Price contract that is not domestic in one country. A foreign country where the labor comes from raised their minimum labor rate for employees working at this location in the middle of the contract term effective immediate. We requested an equitable adjustment because this was a labor law change that we have no influence over and it was denied. Additionally, these employees per the contract had a right of first refusal on contract renewal and the contractor was required and additionally encouraged to keep these employees because they were a workforce significantly paid less than a US citizen. 1) are price adjustments allowed on government contracts? That was their first reason to deny...we signed a fixed price contract. 2) they said the clause that contractors had to comply with host nation laws was completely the responsibility of the contractor. The contract is written poorly and references very little FARs; even if they are absent, arent they applicable laws to contract governance? Arent there certain circumstances, such as laws changing mid-stream that provide an ability to seek a equitable adjustment?
  11. 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."
  12. 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.
  13. 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.
  14. 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.
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