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eklene

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About eklene

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  1. To close the loop on this one: I never did receive any concrete guidance from the contracts officer. In the meantime, our most recent invoice which had total labor costs exceeding the originally estimated cost for labor was approved and paid. Ellen
  2. Yes. We will be needing more funds for personnel costs than originally estimated and less funds for travel costs. We have not come across this before, since most of our funding is grants (where there is a certain amount of leeway in regard to changes in spending by line item) and fixed-price contracts (where this is not an issue).
  3. eklene - So have you read the entire contract to determine if your answer is in it? Yes, none of the cost related FAR clauses that are included in our contract address this issue. 52.216-7 Allowable Cost and Payment 52.232-22 Limitation of Funds 52.232-20 Limitation of Cost 52.243-2 Changes - Cost Reimbursement
  4. Thank you for your response. I actually already quoted the EDGAR regulation to the KO, but was told that this regulation is not applicable, since EDGAR only applies to grants and agreements, but not to contracts. Ellen
  5. Just realized that I posted this in the wrong Forum subgroup. We (non-profit organization) have a cost reimbursement contract from DOE and need to rebudget between direct cost line items to allow for more spending on labor and less on travel. We will not exceed the total contract value. For DOE grants, the EDGAR regulation is ?The Secretary may restrict the transfer of funds among direct cost categories or programs, functions and activities for awards in which the Federal share of the project exceeds $100,000 and the cumulative amount of the transfers exceeds or is expected to exceed 10 percent of the total budget as last approved by the Secretary.? Since this is a contract, the federal contracts officer is asking me to supply the FAR regulation which states that a contractor may rebudget between line items and the percent limits before approval is required by the contracts officer. I can't find such a regulation in the FAR, but I am sure you all will know. Vern: This is my first time posting, so please be gentle. Ellen
  6. We (non-profit organization) have a cost reimbursement contract from DOE and need to rebudget between direct cost line items to allow for more spending on labor and less on travel. We will not exceed the total contract value. For DOE grants, the EDGAR regulation is ?The Secretary may restrict the transfer of funds among direct cost categories or programs, functions and activities for awards in which the Federal share of the project exceeds $100,000 and the cumulative amount of the transfers exceeds or is expected to exceed 10 percent of the total budget as last approved by the Secretary.? Since this is a contract, the federal contracts officer is asking me to supply the FAR regulation which states that a contractor may rebudget between line items and the percent limits before approval is required by the contracts officer. I can't find such a regulation in the FAR, but I am sure you all will know. Vern: This is my first time posting, so please be gentle. Ellen
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