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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 airf
  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
  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 sub
  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 v
  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, a
  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 indirec
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