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Hi ALL, Government customer is pushing back on our Prime invoice submission which included (a reduced) G&A on top of a Subcontractor ODC where they (sub) applied G&A to ODCs (Travel). Basically our sub incurred travel expense that are allowable and billable to the program and sub applied G&A to ODCs when submitting their invoice to Prime for processing. Prime applied G&A when processing the subs ODCs (at a reduced rate) onto final invoice (in customers mind we are "doubling up" G&A - I should also note this is the first time this long standing contract (FFP) has had a sub on it so this is new to this group of GS that handle this program). We've been in contracting for 20+ years and been through a ton of audits both with DCAA and other firms and the only push back we've ever received on this was "why we were applying a discounted G&A instead of our actual G&A to these?" never that it was unallowable, speaking to colleagues in the industry this seems pretty standard practice. My question is, does anyone know of FAR clause relating to this or have a better way of explaining to customer? I tried to explain that both companies are applying G&A to it because we are both incurring expense to process these ODCs (was worded better than that) but he still has doubts. I appreciate any and all feedback!
I recently inherited a software maintenance contract which includes FFP service maintenance and Cost Reimbursable Travel and ODCs. The contract was awarded with the need to move the software to a cloud environment. The technical POC has determined a viable cloud computing company that is able to support the software and requested that I add the company’s monthly subscription fee to the contract as an ODC. The technical POC indicated that they assumed the costs would be handled as an ODC and they estimated it as such when they prepared their IGCE. What’s the best way for me to add the software subscription to the contract? I do not like the idea of adding the subscription as an ODC since its not a typical ODC expense and it seems odd to pay for a commercial software subscription on a cost reimbursable basis. I’m considering modifying the contract to add a new Software CLIN which we could fund the subscription. I’m also wondering if I should modify the contract at all because maybe the software subscription should be handled as a subcontract to the prime? Any input is greatly appreciated.