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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?
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.
All, I'd like to get your opinion on a disagreement we are having with one of our DCMA folks. We have been performing under a CPFF contract since 1/1/14 which includes the 52.216-8 clause, and our KO has not withheld any payment of fee to date. DCAA recently audited the contract records, and deferred the question to DCMA on whether or not things have been handled appropriately. Our DCMA POC's answer was simply an e-mail stating "15% fee withhold is mandatory. The contractor has overbilled and no more billing is permitted. It is mandatory, that 15% of the fixed fee be withheld until such time as the Contractor's 2014 Incurred cost proposal is deemed adequate." I contacted the DCMA POC and stated that I don't disagree that the KO should withhold payment up to the 15% or $100K as the FAR clause indicates, but I contested the fact that he is claiming that "contractor has over billed and no more billing is permitted", stating that the onus is on the KO to withhold payment rather than for us to withhold billings (as an aside, our KO expressly told us not to do so). Am I crazy here? In the past, we automatically retained 15% on all CPFF jobs we had which contained that clause, and our DCAA auditors dinged us for doing that and our KOs got angry - it's like we can't win! Please let me know what you think. Thanks for the help!
Invoicing CP Subcontract - CPIF task order. Standard process used to build cost plus rate (1 salaried individual, 1 hourly individual on contract) cost base calculated for both types of individuals. (salary, calculated to hourly rate based on 2080 hours for the year) or (hourly rate accordingly), OH&G&A applied (accordingly)= resultant rate, This build up was provided at bid in sanitized version to prime and un-sanitized version to govt. (approved and awarded) Client invoiced for number of hours X Resultant rate.. in a standard month, (160 hours), Salaried individual works 120 hours, hourly works 160 hours. Client returns to question why the salaried individuals rate did not fluctuate based on the number of hours worked…. (this is where I need help) I understand the concept of Uncompensated over time causing the cost base to fluctuate if a salaried person works more hours than a standard week / month. However, we do not have uncompensated over time, so I have no trouble making this calculation / adjustment.(this is not the issue) But what happens when a salaried individual works “less” than a full month? Client requesting to see rate fluctuation, but based on cost build up, if I fluctuate the “cost” (which by this situation would go up, not down) would that not be double dipping, if I’m building my cost with “salaried down time” calculated into my OH already? Why would my cost change, if I’m only invoicing for the number of hours worked at the resultant rate? Invoicing requirements stated in the contract: Subcontract number & TTO number Total Straight Time labor charges by person – hours, labor category , rate per hour, and extended amounts or Fixed unit price and quantity delivered Material costs (if any) Travel and per-diem costs (if any) itemized by TTO Other costs incurred (if any) allowable under this subcontract Total current invoice amount and Cumulative billings by TTO to date This is exactly what was provided on the invoice Isn't this why we build a negotiated rate schedule - submit and get approved, and the true up at year end with an ICE review /submit?