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Found 6 results

  1. My company believes that if a prime contract does not contain the clause 52.244-2 "Subcontracts", then all subcontracts awarded under that prime are exempt from purchasing system review under FAR Part 44. This has been enshrined in our policy, and even contains the guidance to contact the Contracting Officer when the clause is omitted, to ensure that the omission is intentional. The reason given is that FAR 52,244-2(i) says "The Government reserves the right to review the Contractor’s purchasing system as set forth in FAR Subpart 44.3". I contend that the absence of this line in the contract does not create any such automatic exemption. I have been unable to locate, within in the FAR, any acquisition supplements or any other contracting resources, any support for the company's position. Is anyone else observing this exemption, and if so what is the basis for it?
  2. Good morning! As a government services contractor, we have recently purchased software for a purchasing system. We understand that all subcontracts should be entered into the system, but I am wondering if we need to enter for audit compliance - items such as rent contracts/Purchase Orders or contracts/Purchase Orders we have with outside firms for support services such as recruiting or marketing. These obviously impact our rates. Is it of your opinion that these Purchase Orders be entered into our purchasing system module to be compliant for Government audit? Thank you!
  3. I was hoping I could pick someone's brain, as I wanted to confirm as to whether or not there is some federal or accounting principle that would prevent the following or if there are any ramifications that I may not be aware of? Long story short, we are a Subcontractor to a contract in which the Prime is requesting to handle all travel for our employees. From making arrangements, to reimbursing and/or paying the employee. The CLIN associated with travel was awarded on a cost reimbursable basis not-to-exceed $350k. Not sure if it's such a big deal but logically it just doesn't make sense to me. My understanding is that should we ever be audited by DCAA, that the question would be raised of why the Prime elected to handle and issue a purchase order strictly for labor. Thank you in advance for your thoughts and expertise. Rae
  4. We currently have an FFP proposal submitted for approx. $24 million over three years. Our work is mainly DoD. It is CAS covered (we are currently modified CAS w/ CAS contracts under $50 million a year). My supervisor seems to believe that there is some kind of dollar threshold (in this case $20 million, she thinks) that sets off a business system audit of some kind. Is any one familiar with this? We have only had an audit of our accounting system to date and is was found to be adequate. I have spent a lot of time over the past few days trying to find reference for my supervisor to this threshold/requirement to support her but I cannot find anything that appears to fit the bill. Any feedback would be appreciated. The contract does have the business systems clause flowed down if that helps with a response. Thanks!
  5. My company has completed negotiations with the prime on a govt contract. We have a confirmation of negotiations memorandum and my company has signed and submitted to the prime the Certificate of current Costs & pricing. The subcontract remains undefinitized as the prime says they're waiting for an audit by the government. It's my understanding that the government will not audit an already negotiated subcontract because it's of no benefit to them at that point. Prime also wants a reopener. Anyone ever have a similar situation? Would the govt audit an already negotiated agreement?
  6. We have a CR contract awarded in 2012 to a not-for-profit small business organization for R&D. Now, in one of the option years, the contractor is claiming that they can do a portion of the work for less if they hire a subcontractor to do that portion of the work. They are trying to charge the government for the audit of a potential subcontractor to do this work. The government did not 'request' or 'require' that the subcontractor be used--the contractor proposed it on their own. I can't find anywhere that addresses this directly (or indirectly on the facts presented--existing contract, subcontractor audit, etc). So my question is whether the government is/can be liable for the cost of auditing the potential subcontractor? The contract is subject to the HSSAR if that helps.