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here_2_help

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About here_2_help

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  • Birthday 12/17/1960

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    SoCal
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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. Bob -- thank you. Embarrassed I missed it. Edited to add that I'm not completely embarrassed, because there does not seem to be a Federal Acquisition Circular (FAC) associated with the change. Is that a common occurrence, I wonder?
  2. Currently, FAR 15.403-4(a)(1) states, in pertinent part "The threshold for obtaining certified cost or pricing data is $750,000 for prime contracts awarded before July 1, 2018, and $2 million for prime contracts awarded on or after July 1, 2018." I'm trying to find the FAC and the FAR Case that implemented that threshold change, which was first mandated by the 2018 NDAA. I've searched the WIFCON list of 2018 and 2019 FACs ... with no luck. Did I miss it?
  3. Yeah, that is technically correct. Please walk me through how awarding an out-of-scope modification to an existing contract is acceptable under CICA. What kinds of justifications does the KO need to make?
  4. Contracts awarded to small businesses are exempt from CAS. Period. No matter what happens after award. Once no longer a small business, then that exemption is no longer available to the contractor. There may be other exemptions available. Assuming no exemption is available, then that next contract award would be subject to CAS. That next contract award, standing alone, would be used to determine whether the contractor could elect modified CAS coverage.
  5. Yeah, having spent more than a decade in the engineering services/EPC industry, I think there are several commercial contract models that the government would do well to accept. The GMP is one of them. The other type I favor is a hybrid of cost-type and fixed-price, where the labor and material cost elements are reimbursable but the indirect costs are a fixed multiplier on those variable costs. Such an efficient approach, especially in a competition, where a one-tenth of a point difference in the multiplier may cost you the job. Also, nobody cares about auditing the indirect costs because they
  6. Funny that. I was just reading Volume 5 of the USAF Contract Pricing Reference Guides this weekend, refreshing my memory on negotiation techniques and styles. Have you reviewed its helpful guidance recently? I find it to be very useful.
  7. You answered your own question in your original post, where you said I have nothing further to add to the conversation. Good luck!
  8. Yes, you are effectively agreeing to a margin reduction on that contract equal to the forgone G&A expense.
  9. Joel, in my view you're describing a fairly obscure and minor type of defective pricing, which turns on the definition of cost or pricing data, and that definition contains the word "significantly." So, no. I'm not going to go there with you. Insignificant costs or insignificant refunds/rebates don't matter, by definition. Now, I know this is a WIFCON-special rabbit hole (and we all love those!) ... but were we talking about refunds of state/local taxes, we could have a whole thread about the differences between 52.229-3 and 52.229-4, and also the commonalities (e.g., the government only
  10. The cost principle you quote is applicable. However, the government is only entitled to participate in the credit/rebate/allowance to the extent it paid for the original cost. If you charged the cost that generated the cashback/credit card rewards to a government contract (either directly or indirectly) then yes, the government participates. Same with the cost of the vending machines. However, whether the government recovers its share of the credit/rebate/allowance is dependent on contract terms and conditions. For example, if the government's share is allocated to firm, fixed-priced cont
  11. If any KO would care to respond, I'm interested in the quote above. Is it common to wait to negotiate pending audit reports and other analyses, even if you have a regulation or statute telling you to definitize?
  12. The proper G&A allocation base is the one that best represents the activity of the business unit being managed, not the one that avoids government scrutiny.
  13. Gentlemen, Consider that a contractor's proposal is an estimate of future costs to be incurred, plus a profit or fee on those estimated future costs. That's all it is. That's all a proposal ever is. Cost or pricing data (whether certified or not) are the facts upon which that cost estimate is based, or other factual information that prudent buyers and sellers would reasonably expect to affect price negotiations significantly.
  14. If you didn't report the asset's value to the "driver" as compensation, I would consult with a tax attorney, not a CPA. I have nothing else to add to this thread, sorry.
  15. Roy, I cannot tell whether you are contractor or government. As has been posted, the government can request whatever backup it finds necessary, though if significantly more than customary, and if it creates an additional cost burden, the contractor may be entitled to an equitable adjustment. Maybe. It depends. I remember a long time ago when our Navy customer wanted every single expense item on the invoice fully documented, right down to receipts for employee expense reports. We shrugged and said, "sure, you're the customer." It was a very large ID/IQ contract with multiple cost-reimbursa
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