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Everything posted by Former_DCAA

  1. I will look for the RFP. In the Task Order section B.6, it says The Total NTE for this task order is 800K, has the PoP, Contract Type as T&M and then just has the table posted with no additional context.
  2. I was not around at the time, but my understanding is that it's directly from our proposal to the gov't and they just copy and pasted it into the Task Order.
  3. I agree, this is my first time seeing a table of hours by category in the task order.
  4. It's strange, its just hanging out there on its own page with no reference to it.
  5. On a T&M task order, where a table of hours and rates by labor category is incorporated into the task order, what is the procedure for transferring hours between labor categories (while still staying within the overall budget)? The project was started in 2020 and due to turnover, the hours mix will be different, but the overall cost will remain the same and the work will get done. However, the contracting officer is giving us a hard time about the change, without pointing to any guidance. I've reviewed the IDIQ, task order and FAR 52.243-3 and don't see reference to hours changes. Thanks
  6. I think absent a plan to get people back to the office or attempt to sublease or break the lease, even if not truly idle facilities, DCAA could just use reasonableness to question the costs and that would be my position as an auditor.
  7. In the scenario I'm dealing with, maybe 5 out of 100 people are coming in due to essentially permanent telework. Without further DCAA guidance, I assume many auditors will take that position.
  8. Does anyone have experience with how DCAA is treating facilities costs for contractors that have not returned to the office or have only partially returned? I see 2 scenarios: 1) The company plans to return, however delayed their plans due to Omicron and increased cases. - Still past the 1 year generally allowed for idle facilities per FAR 31.205-17 Idle Facilities and Idle Capacity, would DCAA question lease costs? 2) The company realized that they don't need either all or some of the office space and should be looking into breaking the lease or subleasing - Would lease termination costs be allowed?
  9. If a company had a settled indirect rate year and then discovers some sort of fraud that changes the rates, is there a mechanism to redo the settled rates to account for the change? I'm not seeing anything in FAR 42.705 Final indirect cost rates.
  10. Thanks for the insight. The company only rents one building that houses all employees and all direct and indirect functions are performed there (plus some telework). There are a few other very small commercial contracts and gov't subcontracts, but this one contract is about 95% of the total work.
  11. That's kind of the approach I was thinking, I just don't know what happens if they wind up winning another contract and that Contracting Officer rejects that idea.
  12. That is correct. The reason is that the indirect rates are extremely high and this is a change that can have the biggest impact. It is definitely a stretch though.
  13. Rent, leasehold improvements, utilities and related costs. They are currently accumulated in an intermediate fool and get allocated to Overhead and G&A based on headcount.
  14. Are there any issues I'm missing with attempting to charge facilities direct to a contract? Background: Company primarily performs on one large gov't contract and about 80% of the people are dedicated to that contract, while the remaining 20% are execs, HR, IT, etc. The contract is being re-competed next year and we're looking at proposing roughly 80% of the facility cost as direct. I haven't been able to find anything that prohibits doing so.
  15. I don't know what the billing rates used in 2010-2011 were since there are no records available. All know is that the rate agreement letter matches the rates on the audit report, so I'm willing to sign the rate agreement letter.
  16. Unfortunately, I have no idea if true-up invoices were submitted to adjust to the recommended rates. The audit report is from September 2015.
  17. I recently started at a gov't contractor with HHS as the primary customer. They had some CPFF and T&M contracts in 2010-2011 and then nothing else until 2019. All of a sudden, we got a rate agreement letter from 2010-2011. Nobody from that timeframe is still around, but I was able to find an incurred cost submission and audits performed by a third party and the rates matched to the audit recommended rates. Normally, we'd need to issue final vouchers to close out the contract, however I have no records on what was billed (other than Schedule I). What would you suggest doing in this occasion? I am leaning towards doing nothing and seeing if HHS comes back with anything.
  18. This is a Thomson Reuters product geared towards law firms, but I was wondering if anyone has used or seen it used successfully by a government contractor.
  19. If a Small Business on a multi-award IDIQ set-aside contract is acquired and loses its small business status: 1) Can it complete existing orders? I have not found anything that says no. 2) Can options on existing orders be exercised?
  20. I read the DPAS regulations and can't seem to find an answer. Is a DPAS rating on a contract (or subcontract/purchase order) considered CUI? Does a foreign national need to be restricted from seeing it?
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