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Hi all, I am a new poster but have been using this forum for information for quite some time now. I am looking for some insight into an issue I am facing when Subcontracting with Universities under Time & Materials prime contracts, such as a GSA professional services schedule. Learning from past audits, it is my understanding that labor charges from Subcontractors for which there is an applicable labor category in your Time & Materials prime must be mapped and billed through the prime rate schedule. However, those hours must be supported by “individual daily job timekeeping records” (FAR 52.232-7(a)(5)(i)) aka time cards. Most Universities do not maintain time cards for professional salaried personnel. They are not required to under OMB A-21/ FAR 31.3 cost principles. They budget, report, and bill for their labor using an effort certification system, as a percentage of the direct salary paid in the accounting period. Universities fluent in federal contracts are generally aware of this and refuse to enter into Time & Materials contracts as their accounting system simply cannot bill for labor by way of hours. Most much prefer to work in the world of cost-based / grants. In the past, I have seen projects back into estimated hours for mapping and billing using that percentage of effort multiplied by standard hours for the period (e.g. 50% effort for a week x 40 hours a week = 20 hours), however they were dinged on an audit when the hours were not supportable by time cards (individual daily job timekeeping records), as there was no auditable trail of actual hours worked. As GSA rates are capped by the schedule, when projects require considerable materials (ODCS, travel, and subcontracts that cannot be mapped through the rates), effective fee suffers and project financial management becomes difficult. Further, you cannot propose fee on materials under FAR T&M contracts. We could try to push for FFP and/or Cost based agreements in these scenarios, but doubt a contracting agency will change it's acquisition plan to accommodate one potential offeror with a nuanced/complex question - which can be hard to effectively communicate during solicitation Q&A. Is my thinking/understanding here accurate? Are there any other strategies to accommodate this labor accounting/mapping issue? Thank you for any insight you may have - I appreciate your time and thought.