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mcmack5

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  1. Ok, good. I think then that answers my question, because they did certify their cost at time of proposal and we did our due diligence under the FAR in documenting the subcontract as was required. Thank you all for the assistance, much appreciated.
  2. Retredfed & Neil - As for an audit, because you are dealing with an FFP SLIN, that SLIN would not be subject to audit under the standard FAR audit clause, 52.215-2, regardless of the prime contract type. - does this mean that even if the subcontractor submitted their proposal to us as a certified cost or pricing proposal it is still not subject to an audit (under letter c of that same clause since it was FFP? I think that Neil alluded to this fact) That was not my complete understanding of that clause, but if that is true, then my worry over this situation is for nothing. By the way, we are not the Prime for this contract, we are a second tier - but this clause 52.215-2 was flowed to us in our contract. I was worried about how this was priced during the proposal phase which is was why I questioned how the supplier first proposed the travel costs and was told at the time that they only charged actuals but had to propose estimated travel costs. Assuming that all travel would be taken, this is fine and per the FAR requirements. But, if the travel is not taken, the actuals can not be priced and charged, so the travel costs are not accurate per the FAR on the final invoice, so we are not in compliance, in my view.
  3. Well, the SLIN actually states 8 trips of Travel in the description (I mentioned that in my original post), so I would say that there is a charge for travel in the SLIN. If the description of the SLIN did not include travel, I would completely agree with you. I was really not worried so much about the cost and us being on the losing side of the table here, but more on the side of being caught on the bad side of an audit with unsupportable costs and charges for travel.
  4. it was part of a larger SLIN included engineering labor and 8 trips of travel - total SLIN cost over 100K - one lump sum - this did trip the TINA threshold, but we were not allowed to see the cost breakdown at time of proposal (Cost data was only provided to the government for this contract, upon request). There again...how much exactly are they charging us for travel and how can they substantiate that as actuals according to the FAR (or do they have to do that under a FFP priced contract?)
  5. Neil - The subcontractor is billing for the travel - that was kind of my problem with this whole thing too - how can the sub bill actuals, if there was no actual travel taken....I'm afraid that we are in conflict with the FAR in this instance.
  6. The prime is also a multi-type of award, has elements of both FFP and T&M - it is also a EV managed contract. They are claiming that this travel was quoted as FFP and as such is not cancelable as long as the deliverable is complete - which it is - just that the travel was not needed to complete the deliverable (it was for software design and itegration).
  7. I am currently managing a FAR part 15 subcontract with several SLINs that have FFP travel. It appears now that this travel will not be needed and will not be taken. We asked to de-scope the subK but were unsuccessful in negotiating this with the sub - they bid in 8 trips for two people for a full week, so the travel was fairly costly. My true concern here is not so much that we are paying for something that we did not get, but I am more worried about staying in compliance with the FAR. This travel was bid based on estimates from the year prior to award and when conducting my cost analysis for this effort I was told by the subcontractor that they always bill actuals per FAR part 31.205-46 (I questioned their costs, as I thought it was high at the time). So the billing for the travel at this time is based on estimates from almost two years ago, as it was the FFP that was accepted and put on contract at time of award. If we were to be audited on this contract and subcontract, could we be in violation of the FAR for billing of these travel costs even though they were bid and accepted as a FFP cost?
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