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Found 2 results

  1. I am currently a CPFF subcontractor under a Government prime contract. My company cycles on a calendar year and each January we update our provisional indirect rates for the upcoming year as well as calculate our final rates for the previous year. These rates are then provided to DCAA for review/approval and used for billing purposes under any CR contracts. This year, DCAA has stated that since we do not have a CPFF or T&M prime contract ourselves, we do not have a requirement to submit our PBR and they will NOT review our 2017 provisional rates. Our Prime contractor will not accept our updated rates for the CPFF subcontract since we do not have approved rates. As a small business, if we continue to bill using the provisional rates of 2016 (which were approved), we will be operating at a loss for 2017. In accordance with FAR 42.704 (c), billing rates may be prospectively or retroactively revised by mutual agreement between DCAA and the contractor. Without DCAA agreement, how is a subcontractor able to invoice for rate adjustments?
  2. Contract Type: CPFF I am currently analyzing a pricing proposal that used a combined OH and G&A Rate. I am concerned on how it's used for their breakdown. Example below: Direct Labor: 100,000 Rate (OH + G&A = 100%): $100,000 Materials: 50,000 ODC: 500 SubK: 1000 Subtotal: 251,500 Fee (1%): 2,515 Total Price: 254,015My concern is that the G&A was not applied to the other cost elements of 3 and 4. The subk total should not be counted, if I am not mistaken, due Value Added reasons. My Question is if anyone has encountered this before of a proposal using a combined rate? if so, is the breakdown example the "correct way" of applying the rate? Any suggestions would be appreciated. Thank you.
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