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CDRL Review Period and Approvals
siwilliams posted a topic in Contract AdministrationI'm having a disagreement with my government customer about CDRL deliverables, review periods, and approvals. Block 8 of the 1423 is Blank. Block 16 of the 1423 states that the government will have 30 days to review the data submittal and respond with comments and the contractor will have 20 days to revise after receipt of the government's comments. The data item was submitted to the customer. The transmission included DID, SOW, CLIN, and CDRL references as well as the listed government review period. The government confirmed receipt of the data item. On day 40 I sent the government a notification that the review period has expired, the date of expiration, and notification that the Data submittal was now presumed approved by the contractor as we received no comments back on the item by the government. The government says that this assumption is incorrect as the 1423 says nothing about presuming approval. I argue that the document gives a number of days for government approval. Once that time has expired, unless contractor has received notification that the review period would need to be extended, then the government has not contractual right to additional comments. Realistically, we will likely allow additional comments, however, it's my argument that technically the window of opportunity has closed on that one. The COR asked under what authority and I really couldn't find anything that specifically addressed approvals of this nature except that Dod 50101.12 states that the dates are contractual obligations. Also the instructions for DD form 1423 seem to indicate the same. Any opinions on this would be appreciated.