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About here_2_help

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    Contributing Member
  • Birthday 12/17/1960

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    No special interests, really. Kind of a jack-of-all-trades/master-of-none kind of person.

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  1. FAR 32.503-6(g) addresses the situation where progress payments are being used for a contract that is in a loss position. ("If the sum of the total costs incurred under a contract plus the estimated costs to complete the performance are likely to exceed the contract price, the contracting officer shall compute a loss ratio factor and adjust future progress payments to exclude the element of loss.") Question: How does the loss ratio calculation work in a FPIF (firm target) situation? May the contractor use the agreed-upon formula to offset some of the estimated costs to complete for purposes of reducing the loss ratio, even though the final price has not yet been negotiated? I've looked through my reference library and couldn't find an answer to that question. I'm hoping others can assist.
  2. A couple of things that we know: (1) for R&D work, fixed fee is capped at 15% of total costs (FAR 15.404-4(c)(4)(i)(A)); and (2) when cost analysis is performed a structured analysis approach must be used to develop negotiation objectives. In my mind the best way to approach the negotiation is to use the structured approach (e.g., weighted guidelines or similar) to determine the fee you believe you are entitled to receive, then negotiate that dollar value, not the percentage. Avoid discussing the fee as a percentage of certain cost elements; attempt to discuss the fee as a dollar value--but use the results of the structured approach to support your position. All I've got. Hope this helps.
  3. If you have a Full CAS-covered contract and your cost accounting practices are consistently applied so as to make that contract compliant, then it doesn't matter whether a subsequent contract is subject to Full or Modified coverage. So long as the Full coverage contract is active, you will treat all subsequent contracts as being subject to Full coverage, whether or not the rules would formally apply Full coverage to those subsequent contracts. Because you have to be consistent. You can't have one set of practices for that one contract and another set of practices fore the other contracts. That's not how it works. Let me clarify: it will matter if you have a noncompliance with one of the Standards that only applies in Full coverage (e.g., CAS 403, 410, 418, etc.). If you are dealing with calculating the cost impact associated with a noncompliance, then it matters; otherwise, it does not. In my experience, it is rare for contractors or auditors to apply the kind of critical analysis to the CAS coverage regulations as Vern has done. Most people go right to the DCAA flowchart and that's the extent of things. Since so few people actually critically analyze the rules, I should think that im2 can argue any position that they feel to be advantageous to their organization, with little risk of contradiction. That's not saying what the technically correct answer is (if it matters, I think Vern is correct). What I'm saying is that I have yet to meet an active DCAA auditor (including a CAS Tech Specialist) or an ACO/DACO/CACO who has the ability to apply critical analysis to the question. My advice: Pick a position and advocate for it.
  4. In my view contracts are either exempt from CAS or they are subject to CAS. If subject to CAS they receive Full coverage unless eligible for Modified coverage.
  5. here_2_help

    Cost Allowability

    Yes, that is true 99% of the time. The only exception would be if the the cost pool includes a directly associated unallowable cost where the original unallowable cost is in the base. (See 31.201-6(d).)
  6. here_2_help

    Cost Allowability

    In another thread somebody posted "Unallowable means neither G&A nor Overhead." Unfortunately that thread is closed so I'm posting a response here, realizing that many people "lurk" without posting. That quoted statement is wrong. Unallowable costs are still the same costs they ever were, only unallowable. If the costs were G&A then they are still G&A. If they were overhead they are still overhead. If they were direct costs, then they are still direct costs. Unallowable costs must receive their fair share of indirect costs, so you have to keep them in the same place.
  7. here_2_help

    Business Development

    Interesting (to me) that "general answers" were expected but the best answer was a single word. Ah, well. As H. L. Mencken said, "For every complex problem there is an answer that is clear, simple, and wrong."
  8. here_2_help

    Business Development

    Absolutely true! Even though I am forced to point out that just because he agreed with your answer doesn't make it correct. As you know.
  9. here_2_help

    Business Development

    In other words, a lot of unallowable selling activity
  10. here_2_help

    Business Development

    Yes, that was my intent. The answer is there, for those who seek it out.
  11. here_2_help

    Business Development

    Have you reviewed illustrations (c) and (d) under CAS 410?
  12. here_2_help


    Can we all agree that leadership is different that management? Effective managers may be poor leaders, and vice-versa. I would assert further that effective managers are much more common that effective leaders. In my experience effective leaders all have one thing in common: the courage of their convictions. They have the courage to take responsibility and accountability for their decisions. Whereas effective managers often specialize in CYA.
  13. here_2_help

    Business Development

    Marketing is often G&A, which aligns with the "S,G&A" nature of commercial entities. Where companies sell to both government and non-government entities, they may form separate OH pools and allocate the marketing cost only to benefiting cost objectives.
  14. here_2_help

    ISO: Michael Golden Article

    Vern, are you registered? Wow! I looked at registering but it was too pricey for my little consultancy.