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marcfgov

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About marcfgov

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    Corporate Finance professional, life-long learner - I know what I don't know is encyclopedic/Wikiepedic (my daughter's addition), adjunct MBA professor in accounting & corporate finance, CFO, CPA, MBA, blah-blah-yadda-yadda, Deltek CostPoint SME and yes, I am here to help with Deltek CostPoint if needed. Not trying to impress, but impress upon you that I am also here to help.
  1. Here_2_Help and Retreadfed, Thank you, I appreciate you taking the time to respond! Sorry for the delay, I had "notify me of replies" off. Here_2_help, I agree with you on the what the "FAR means". I feel like a dog chasing its tail! I love the story of the thermal ink! Can you imagine the look on the Auditors face! Retreadfed, thank you for pointing me to CAM: 3-204.21 Contractors Use of Scanned Images. This of course references (a) FAR 4.703(c)-1,2 and 3; (d) and (e). (e) is where it gets interesting. . . e) If we have not tested the contractor’s scanned images,
  2. Hi, With the increase in online T&E solutions, has DCAA established additional guideline related to Original Receipts vs. scanned and digital copies, etc. My question is related to 4.703.(c).3 (see below) "The contractor or subcontractor retains the original records for a minimum of one year after imaging to permit periodic validation of the imaging systems." I have delved deep into the internet and have found no guidance. If we meet (c) 1 and 2 then 3. defeats the purpose of reduction of paperwork, time for scanning and maintaining originals, etc. I have been through
  3. Vern, Here_to_Help, et.al., (Please read) OK, so it appears that I did make a "newbie" mistake. The internet is a wonderful tool, but you only get a response to "what you ask", and it clouds out everything else and my question was "confusing" my searches. I completely skipped the one authoritative document, the FAR, for my search and well DUH, I "missed the forest for the trees." Gosh, I do feel stupid; boy those crow feathers are hard to get down! (no, really). With that over with, this contract was novated in an acquisition, during the novation process, it changed from a CPFF
  4. I’m sorry I over reacted. After further review, I took things too literally. You all are have always been here to help. I really couldn’t find anything and was frustrated , as always you all did provide the guidance I was looking for. Looking for a “mulligan”, ok?
  5. Thank you for your responses. I’ve come here for assistance four times since I became a member of this group in 2010. I am a faithful follower of the topics and posts. I researched and went through the blogs before I posted my question. And I read and respect all the answers and guidance. Yes, some of the copy and paste came from the post I found on this site from 2002. I apologize if I came off as a newbie, ignorant or lazy by asking if there was clarification from the 2002 post . I’ve read the contract, as I do before I ask for help I acknowledge that what I dont know is encyclo
  6. This topic was discussed back in 2002! I am wondering if anyone has more current data. My company has a T&M contract with the Federal Government to provide information technology services and an issue has come up regarding the use of exempt (salaried) personnel, the hours they work, and how those hours are billed. All of the personnel performing under the contract are exempt from the Fair Labor Standards Act (FLSA) and routinely work more hours than what would be considered a typical workday (8 hours). Since our employees are exempt from FLSA, they do not receive additional compensat
  7. Thank you. That also makes sense. We have not had to provide any type of cost analysis at this point in the company's history. We only had to prove commerciality for the original GSA pricing (many years ago). The remainder of the awards have been competitive FFP. We are looking to expand and that is the push to move towards a compliant system and all that accompany it.
  8. Thank you for your reply! Very Helpful in framing my thoughts. As for the "withoug change it practices and approach" that is what I am here to do. Using Deltek, setting up pools, policies and procedures, etc. This question is just the band-aide as we are moving forward toward bigger and better things! As GSA has moved more to the cost based pricing, this company has been "forced" to move away from commerciality and focus more on a bottoms up approach. Again, thank you all for your help and support. This is be best resource!
  9. Oh Masters of the Government Contracting Universe, Me again! I am with a new company, we do not have CPFF contracts (we do have FFP and T&M from GSA FABS/MOBIS schedules). Are we able to team with an Prime on a CPFF contract? Does CPFF always flow down to the sub? Just checking as I see opps that we can’t prime, but we could provide the services as a sub. I believe I can bid FFP CLINS and T&M CLINS using my GSA pricing, but as we grow, I am worried about flowdown clauses. My understanding is that whether we (as a sub) are exempt from CAS or is based on our specific situation, not the
  10. Hello GURU's Been a while since I have been on. We are having to take out a loan to cover short-term working capital. Let's say $2.0M with loan origination fees of 0.5%. It is a two year loan. I know that I can amortize the cost over the two years, and because it is in the normal course of business and reasonable, yada, yada, I believe that the fee is allowable. Saying that, can I just expense at close and cover it in "fees" (this is not prepaid interest, it is the closing costs, legal, documentation, etc.) Thanks, Marc
  11. Every time I ask a question here, I realize that what I don't know is encyclopedic! How do you know all this stuff! In any case, thank you all for your insight and taking time to answer. We'll eat the burdended costs. Charge it to a nonbillable, unallowable charge number against the profit on this contract. I'll talk to the PM's an make sure that we discuss the issues that are brought up here. Thanks again, Mark
  12. Thank you gang! I know it was a little unclear "babble", so to speak!, but you got me focused! I have a program manager on-site, the customer asked him a question not specifically related to the current cost objective, a little out of the scope, but in the same area (program for one system vs another system). The answer took him considerably longer than he anticipated (20hours) and he wanted to know where to charge his time. From my perspective, PM overhead, he didn't want to charge his contract and change a bid & proposal charge number (not really potential new work). He just needs to
  13. Where do we draw the line between what is Business Development and what is Overhead when it comes to potential new work. I have a program manager working on a question from the customer, it's an ECP, so that can go as bid/proposal work against the existing contract. For the 'information' that is being requested for another system, I'm not sure exactly what will come of it (as in New Contract, CLIN, Delivery Order or nothing). Typically, we get a request for proposal, not a request for information. My suspicion is that it will end up being an ECP, but what if they change their mind and don'
  14. Oh MAN, ALL, YOU ARE THE BEST yes, (all of you)! I know it should be straight forward, but sometimes I get "wrapped around the axle". Yes, I was looking for direction on what "flavor" CAS, and I think that I am going to get the FULL Monty! You also hit on my research topic for tomorrow, Disclosure Statement NOW or interim exemption. We are getting the contract novated from another company that we are a minority owner. So I am preparing for the immediate burden of requirements! I am going to start the preparation now. I have the accounting system, timekeeping and expense reporting, but w
  15. Thanks Vern! Yes, I had already been through 9903.201-1. I know the question looked like I didn't take time to look it up and I just came to you for the answer! I just didn't want to get into too much dialogue. Sometimes too much info, I guess I just went straight to the facts. Next time, I will go through my thought process. Saying that, my specific question is, since we have a FFP agreement with the Prime, and since they have FFP and Sole Source, are we going to be Full or Modified. My contract with the Prime states specifically FFP and nowhere does it state that we are sole-source (ex
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