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Everything posted by here_2_help

  1. 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.
  2. 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.
  3. 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.
  4. 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).)
  5. 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."
  6. 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.
  7. here_2_help

    Business Development

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

    Business Development

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

    Business Development

    Have you reviewed illustrations (c) and (d) under CAS 410?
  10. 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.
  11. 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.
  12. 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.
  13. https://www.usatoday.com/story/tech/talkingtech/2018/07/24/cord-cutting-accelerate-millions-more-than-expected-leaving-pay-tv/823950002/
  14. bob7947, I understand a current slide deck is available on the Netflix website. It keeps evolving...
  15. Anybody else follow the Netflix HR philosophy on "talent density" and how having the right people surrounded by the right colleagues obviates the need for process controls? Just me, then? It will never in million years happen to the Federal government. It would be transformative if it did, though. https://www.slideshare.net/BarbaraGill3/netflix-culture-deck
  16. Recently I participated in a discussion where it was asserted that technology is moving faster than (government) contracting can keep up with it. I'm not going to give any specifics. Suffice to say that there were certain, known, threats to military assets that we had the technology in our hands to address, but we could not get it to the requiring activity quickly enough to address the threats. The assertion was that the contract SOW didn't permit it, or that the modification process took too long (because of the need to determine price reasonableness), or some other perfectly understandable acquisition-related requirement. It was frustrating to the technical folks, who had the right solutions but who were prohibited from providing them. I'm not complaining; I'm posting this because it's a commonly held belief that the limit on innovation is found in the acquiring activity and not in the requiring activity. In this particular discussion, I was not able to disagree with that belief.
  17. here_2_help

    FAR 15.408 Deviation - re: 52.215-12

    The DoD and other Class Deviations implemented the threshold change in advance of formal rule-making. The Class Deviations expressly provide that prime contracts awarded before the effective date of the threshold change may be modified to comply with the higher threshold, with no consideration required. The prime simply has to request it. If you are awarding a subK between July 1 and the date on which your contract is modified to comply with the higher threshold, you may want to stick with the lower threshold. Or you could get a letter from the Prime contract CO giving you permission to use the new threshold while the mod is being processed....
  18. eager, Your questions are really not all that difficult to answer. The problem is that you are seem to be looking for an education on the topic, and this forum isn't really a good place to get an education; it's a better place to get specific questions answered. Bottom-line (for me) is that nothing you posted shocks me or presents a challenge that cannot be overcome. Do you have access to a seasoned contracts professional who can give you the time necessary to educate you on the topic?
  19. here_2_help

    Reprocurement After T4C

    jjj, 3. Are you saying that the government's declination to exercise a performance period option is tantamount to a termination for default? 4. Are you saying that the GAO decision you cited supports a "reach back" instead of a new procurement, where the government declines to exercise a performance period option?
  20. here_2_help

    Volume 2

    Link: https://section809panel.org/wp-content/uploads/2018/06/Sec809Panel_Vol2-Report_June18.pdf
  21. here_2_help

    Volume 2

    Re: Section 4 (CAS). I counted ~ 20 recommendations and all of them would be great steps forward. However, there is nothing in there about significant rule-making efforts. E.g., concurrent changes to cost accounting practice and the definition of "increased costs in the aggregate." So ... baby steps in the right direction.
  22. here_2_help

    A $1,220 Coffee Mug

    Obviously an old design for the KC-135. Does anybody know if the new KC-46 tanker will spec-out a different cup design? How much will they cost?
  23. Is there a thought that the hours were in any way incorrect? If not it's hard to see how the invoice was in any way a "false" claim. However, if the company wants to be cautious it can convert the hours to nonbillable and reflect the credit in the next billing cycle.
  24. here_2_help

    Probability Problem #2

    To add to Vern's point, Don's problem has omitted significant information regarding the probability distribution of the contractors' costs. Don has provided a probability estimate that the actual value may be $20 million higher than the most probable cost (which I assume is the mean of the distribution), but he has omitted a probability estimate associated with an actual value that is $20 million lower than the most probable cost. We need the distribution around the mean, and the standard deviation, if we are going to play probability games.