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Found 3 results

  1. Hi ALL, Government customer is pushing back on our Prime invoice submission which included (a reduced) G&A on top of a Subcontractor ODC where they (sub) applied G&A to ODCs (Travel). Basically our sub incurred travel expense that are allowable and billable to the program and sub applied G&A to ODCs when submitting their invoice to Prime for processing. Prime applied G&A when processing the subs ODCs (at a reduced rate) onto final invoice (in customers mind we are "doubling up" G&A - I should also note this is the first time this long standing contract (FFP) has had a sub on it so this is new to this group of GS that handle this program). We've been in contracting for 20+ years and been through a ton of audits both with DCAA and other firms and the only push back we've ever received on this was "why we were applying a discounted G&A instead of our actual G&A to these?" never that it was unallowable, speaking to colleagues in the industry this seems pretty standard practice. My question is, does anyone know of FAR clause relating to this or have a better way of explaining to customer? I tried to explain that both companies are applying G&A to it because we are both incurring expense to process these ODCs (was worded better than that) but he still has doubts. I appreciate any and all feedback!
  2. If a government prime contractor issues a Time & Material subcontract, can the G&A applied to materials be a fixed/lump sum value, so long as that lump sum value is established and set at the time of award? I understand the four criteria established in Urban Data System v. US, but I am trying to determine if the only way to surely avoid violation is to reconcile the G&A rate applied to materials to actuals at the close of an accounting period.
  3. Hi I'm looking at a proposal under the following scenario: Single Source Award/Certified C&P Data required Contract Type FFP (one T&M CLIN) Offeror: CAS covered (submits D/S). IAW Disclosed Practices G&A base is TCI. Offeror has a pool for material handling (M&H) (base - direct materials). Direct materials and the expenses on the M&H pool are part of the G&A base. 1. Here's the way the offeror is burdening materials in the proposal: Lets assume the M&H rate is 5% and G&A is 50% Direct Materials is $100,000 Materials 100,000 M&H 5,000 Subtotal 105,000 G&A 52,500 (subtotal x G&A) Total Material Cost 157,000 2. Here's the way I believe it materials should be burdened when the offeror has an M&H pool (value added G&A): Materials 100,000 M&H 5,000 Subtotal 105,000 G&A 2,500 ( M&H expense x G&A) Total Material Cost 107,500 3. Or if offeror has a TCI base: Materials 100,000 G&A 50,000 Total Material Cost 150,000 So basically they are applying G&A on top of M&H and materials. believe that if the offeror applies an M&H to materials it can apply G&A to the handling expense only and not to the direct material cost. If the offeror has a TCI allocation base for G&A, then it should only apply G&A to direct materials with no M&H. Are they doing this correctly or am I wrong?
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