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Found 8 results

  1. 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 i
  2. 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_standar
  3. 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
  4. 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
  5. 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
  6. 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.
  7. 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?
  8. 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 cont
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