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marcfgov

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About marcfgov

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  1. 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.
  2. 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!
  3. 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 Prime’s. CAS does have mandatory flowdowns provisions, but in order to claim CAS exemption, all we have to do is show that we qualify, on our own, for a valid exemption. Saying that, we claiming exempt from CAS at this time. The GSA schedule pricing was not Cost Base, but Commerciality Based (which was approved years ago and we are not moving towards cost based). Thoughts?
  4. 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
  5. 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
  6. 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 be careful on what tasks he takes up that are not on the statement of work. A little scope creep is OK, a lot (on a FFP) eats into the margin. Thanks again. Best Regards, Mark
  7. 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't go through with it? At this point, it seemed more like a Business Development activity than an actual technical / contractual activity. But, perhaps I'm wrong. Where is that lne between support of the contract and working towards additional work? And is working towards that additional work (on the same contract) just OH or BD? Thanks,
  8. 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 we are essentially starting from scratch. Just set up an SSA (now that was fun and exciting!). Yes, we set up an SSA without purchasing a company! So now I have the SSA shell and am ready to populate with contracts! In the future, I will use the tems below "relevant, but not ultimately determinative, irrelevant", etc. to explain my position! I have been on this forum for a while and no joke, I truly appreciate the insight and guidance from everyone! Thanks for taking the time to respond. I really use your advice. This is the BEST site. Thanks! Marc
  9. 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 (except by virtue of the Teaming Agreement). We competed to get on the team and since paragraph 15 of 9903.201-1 states "Firm-fixed-prive contracts or subcontracs awarded on the basis of adequate price competition without submission of cost or pricing data" I am on the fence as to whether or not I am Full or Modified. In either case, having everything in place, except a Disclosure Statement (accounting system, timekeeping, etc) I was thinking Modified. But I could be wrong based on the other factors. Thanks, Marc
  10. Team, here are the facts: Firm-Fixed Price Prime is sole-source (only one with technology). DoD technology (non-commercial) We have negotiated a Teaming Agreement to be on the bid. (there were three subs that could have teamed with the Prime) Our agreement with Prime is Fixed Price. (since we are on the Teaming Agreement, I guess we would be sole-source) 5-year contract $100.0M Contract Will I be subject to CAS or Modified CAS? Thanks! Marc
  11. H2H, I know that I responded to this today! I thanked you for your quick reply and stated that I had used that basis for my decision. Some are questioning (the International Group) and I think that I need more information to understand the specifics. But I really do appreciate your fast response this afternoon, it really helped me! Mark
  12. I am fairly new to international companies. We just set up an SSA and I have several "sister" companies who will be subcontractors to us and need help in making sure that we do this right! Specific question on my plate: Our sister was a subcontractor to a large prime. Once the SSA was set up (earlier this year), we novated the contract to the SSA and now our sister is our subcontractor. We want to charge the sister Material & Handling/G&A of say, 18%. I have support for the rate, but are we able to burden the cost from our "sister sub"? 95% of our work will be us as "Prime" and sister companies as "subcontractor". We have no facilities, just our OH (Contracts, PM, Legal, B&P, Sales and Market, Finance, etc) How should we set up IC trading rules for this type of activity? Thanks, Mark
  13. THANKS! I understand! I'll keep you posted! Marc
  14. THANKS! I understand! I'll keep you posted! Marc
  15. Thanks! I do understand that you can have multiple G&A rates for the reasons that you identified. I am just speaking of having a contract for, application design in the US and one in say Germany, same company, same product. Specifically, can/should I have a different G&A Rate for CONUS and OCONUS? Thanks again.
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