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Found 3 results

  1. 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!
  2. 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?
  3. I have a R&D, CR contract with an educational institution. Therefore, it is subject to OMB Circular A-21. A-21 limits to $25,000 the amount of subcontracts that the educational institution can charge F&A costs on. The contractor is using other companies to perform non-commercial work under this contract--sample testing, biological supplies and testing, that kind of thing. My office has taken the position that this is a subcontract, and therefore subject to the $25,000 limitation imposed by A-21. The institution is asserting this to be a 'vendor agreement' (or supplier contract), as they use these services on more than just this one contract, and thinks that they are properly included in the MTDC of the contract. A-21 does not distinguish between vendors and subcontractors. The contractor is relying on the fact that A-133 makes the distinction. We believe that as they thought to distinguish in A-133, the silence in A-21 is intentional and that they would both be subject to the $25,000 restriction in A-21. I know that some of this depends on the work-they are performing direct work/supplies on the contract (as opposed to a general supplier contract for pencils, for example, which someone might grab to make notes on something under the contract). So my questions are: Does the proper application of A-21 differentiate between subcontracts and vendor agreements, specifically for the purposes of G.2? In the scenerio given, would this be considered a vendor or a subcontractor? Which definition of 'vendor' or 'subcontractor' applies? Is there a ruling (GAO case, FAR clause, Court of Federal Claims case, etc) that I could look to? I've found a few things that lightly dance around the issue, but nothing that addresses it directly. The smokier the gun the better. As a side note, we asked the people who established the indirect cost rates to begin with whether they included these 'vendor agreements' in the MTDC. Their response was a mind-blowing 'your guess is as good as ours' (paraphrased). And because it is CR, the contract doesn't stipulate one way or the other (though in the future we will!)