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Found 4 results

  1. My company is interested in setting up CPSR-compliant policies and procedures. In my previous lives, I have tracked compliance actions (ie, EEO, TINA, Reps and Certs, etc) at the subcontract level (covering all subsequent Task Orders) and I've also done it on a per Task Order basis. I think each have their own unique pros and cons. I have my own preference but would like to hear the experience/thoughts of others. Thanks!
  2. Hello All, Recently DCAA finished it's audit of our 2008 Incurred Cost Submission. One of the findings we are taking issue with is for a subcontractor who apparently did not file (and has not filed to-date) an incurred cost submission of their own. DCAA affirms that it was our responsibility to make sure the subcontractor filed an ICS. I believe this was the only contract the subcontractor had for the year. This is leaving us with potentially millions in penalty. Does anyone have experience with this type of situation or similar? I am trying to research as much as possible to see what options we have at this point. Any and all feedback is helpful. Thanks!
  3. Good morning, I am new to WIFCON and managing my company's first prime contract, which is CPFF for engineering products & services. We added a new subcontractor not part of the original bid, and our FFP subcontract was approved by our ACO. In our original cost proposal we bid using our G&A as a pass-through/contract administration fee, which was accepted by the government. We have now switched to a material/subcontractor handling fee for material purchases, vendors, consultants, etc. G&A is applied only to this fee instead of the whole subcontractor price, which lowers the overall amount of pass-through. We do have program management and contract administration pieces to managing the work of the subcontractor. What can I charge as a pass-through fee -- the bid G&A, the current/actual G&A, or the material/G&A mix? (or another option?) The material/G&A mix would be the lowest cost to the government. Also, if current/actual G&A should be applied, do I need to re-calculate that and re-determine pass-through for each invoice or can I determine it now and use it for the length of the subcontract? Thank you for your help! Vr, SD
  4. Is there a requirement that if a Prime is awarded an FFP contract and the Prime has a Sub performing some of the work, that the type of SubK issued must mirror the Prime's contract? If not, what might be some of the advantages and disadvantages of issuing a Cost Reimbursement type SubK and is the Prime allowed to cap the number of hours the Sub may invoice the Prime for?
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