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Hey Contracting professionals, I'm trying to see if the DFARS 252.242-7005 (and other clauses and systems requirements referenced therein) apply to my AbilityOne Contractor... 252.242-7005 "applies to covered contracts that are subject to the Cost Accounting Standards", 48 CFR § 9903.201-1 - CAS applicability (b) [exemptions] (5) Contracts and subcontracts in which the price is set by law or regulation. Prices in the AbilityOne Program are set by the AbilityOne Comission (i.e. law or regulation). Therefore, even if I have included the 252.242-7005 and 252.242-7006 in my award, as CAS exempt, these will not apply to the AbilityOne contractor, correct? Thanks in advance, prudentmindstx
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Once a contractor triggers the Full CAS covered threshold, when can it determine that a contract is only Modified CAS and can a business unit get back to only being Modified CAS covered? I understand that once a contractor has triggered the Full CAS covered threshold, that all subsequent contracts in that accounting period that are not exempt from CAS would also be Full CAS. My interpretation of the CAS Coverage and Disclosure Statement Determination flow chart in the DCAA Contract Audit Manual (Figure 8-1-1) (http://www.dcaa.mil/Content/Documents/CAM/chapter_08_-_cost_accounting_standards.pdf) is that determination for Full or Modified CAS coverage is made for each contract. For example, a business unit receives an award of $10 million, which is not exempt from CAS. The business unit has not received $50 million or more in net CAS-covered awards in the preceding cost accounting period, nor received a single CAS-covered contract / subcontract of $50 million or more during the current cost accounting period, but is performing on a contract that was determined to be Full CAS covered that was awarded 2 years ago. My interpretation, is that the contract would be determined to be Modified CAS covered. I have received an interpretation from a consultant that if you are currently performing on a contract that was determined to be Full CAS covered, then all contracts that are not exempt from CAS would also be determined to be Full CAS covered, even if that contract was awarded 2 years ago and in the preceding year you did not receive $50 million or more in CAS-covered awards, and the current award isn't $50 million. I understand that the business unit would need to keep it's Accounting System in a way that meets Full CAS as long as there is one Full CAS covered contract. The reason for the question is that my interpretation would mean a business unit could get back to only being Modified CAS covered if all Full CAS covered contracts ended and the business unit has not hit one of the $50 million triggers listed earlier. I'm interested to know how others on this forum interpret the CAS determination. -
contemplating a cost accounting practice change. Changed in CAP Scenario contemplated is over five year period would result in same expense at the end of the five years. Net would be zero increased costs in aggregate However change in measurement would case more costs to be incurred in the current periods and lesser in subsequent periods. GDM offsets would be appropriate because FP increased costs - - lower costs to Government, and Flexibly-priced contracts increase - - higher cost to Government Thoughts? thanks
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FYI, a recently published (redacted) ASBCA decision sustains a contractor's appeal of a COFD related to changes in cost accounting practice. The DACO "abused her discretion" by failing to strictly follow FAR 30.602, specifically the mandatory consideration as to whether the cost impact from the contractor's changes to cost accounting practices was material in amount. A very important decision for those dealing with CAS compliance. http://www.asbca.mil/Decisions/2016/58068 Raytheon Company, Space & Airborne Systems 8.9.16 (REDACTED VERSION).pdf -
I support a program with contracts defined as firm-fixed price (FFP), labor hour (LH), time and material (TM), indefinite delivery indefinite quantity (IDIQ) with economic price adjustments from collective bargaining agreements (CBAs)/ wage determinations (WDs). The contracts were awarded under FAR 15 with adequate price competition. Due to some security aspects in the SOW the effort is considered non-commercial and agency described as design/detail. Historically, the program has considered these contracts exempt from Cost Accounting Standards (CAS) per the exempted category (15) below, as there was always adequate price competition and they have not collected cost or pricing data with the offers. Is this interpretation correct? (b) The following categories of contracts and subcontracts are exempt from all CAS requirements: (1) Sealed bid contracts (2) Negotiated contracts and subcontracts not in excess of $500,000. For purposes of this paragraph (b)2 an order issued by one segment to another segment shall be treated as a subcontract (3) Contracts and subcontracts with small businesses. (4) Contracts and subcontracts with foreign governments or their agents or instrumentalities or, insofar as the requirements of CAS other than 9904.401 and 9904.402 are concerned, any contract or subcontract awarded to a foreign concern. (5) Contracts and subcontracts in which the price is set by law or regulation. (6) Firm fixed priced and fixed price with economic price adjustment (provided that the price adjustment is not based on actual costs incurred) contracts and subcontracts for the acquisition of commercial items (7) Contracts or subcontracts of less than $7.5 million, provided that, at the time of award, the business unit of the contractor or subcontractor is not currently performing any CAS-covered contracts of subcontracts valued at $7.5 million or greater. (8-11) [Reserved] (12) Contracts and subcontracts awarded to the United Kingdom contractor for performance substantially in the United Kingdom, provided that the contractor has filed with the United Kingdom Ministry of Defence, for retention by the Ministry, a completed Disclosure Statement (Form No. CASB-DS-1) which shall adequately describe its cost accounting practices. Whenever that contractor is already required to follow U.K. Government Accounting Conventions, the disclosed practices shall be in accord with the requirements of those conventions. (See 9903.201-4(d).) (13) Subcontractors under the NATO PHM Ship program to be performed outside the United States by a foreign concern. (14) Contracts and subcontracts to be executed and performed entirely outside the United States, its territories, and possessions (15) Firm fixed price contracts or subcontracts awarded on the basis of adequate price competition without submission of cost or pricing data.
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My company submitted a proposal for an effort which included facilities capital cost of money. The resulting contract contains neither 52.215-17 or 52.215-16. We meet all of the criteria under 31.205-10(b and our COM calculations are compliant to the limitations in 31.205-52. However, our customer is now telling us that COM is not an allowable cost. Under what circumstances would this be the case? I'm assuming that the omission of 52.215-16 is of no bearing as it is a required clause for cost reimbursable supply contracts when applicable. -
Hello All, I was just wondering if it is going too far when the KO requests a copy of the DCAA audit report with proposal submission on a cost type contract. Shouldn't the letter from DCAA/DCMA stating that the cost accounting system/purchasing system is acceptable enough? What happens if the vendor has the DCAA/DCMA letter, but does not have the audit report itself?
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I have just taken over contract management of a contract that is fixed unit price/IDIQ, under the standard set of government terms and conditions - which includes CAS. Originally, the contract was awarded under adequate price competition, with no submittal of current cost or pricing, so it would seem that it would be CAS exempt pursuant to 48 CFR 9903.201-2(. However, since the subsequent modifications and follow-on options are now sole source, does this make it now CAS applicable? It is for IT services and, arguably, it probably should have originally be awarded as a commercial items contract. The current value is close to $200M. Comments/opinions appreciated!