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Trying to find opinions on whether or not a contractor needs to have an adequate accounting system for a T&M task order under a commercial IDIQ contract. The solicitation was developed with FAR Parts of 12, 15, and task orders are being issued under Part 16.

Background: The RFP stated that the contractors would have to have an adequate accounting system since T&M type task orders would potentially be awarded. Therefore, the offerors were required to have accounting system audits performed by DCAA. One of the contractors was deemed in-adequate; however, was still awarded an IDIQ with a statement made that they would only be eligible for firm fixed price task orders until their accounting system was deemed adequate. A follow up audit has been conducted by DCAA and again they are deemed in-adequate; however, with a note from DCAA that there is minimal risk to the government with one of their issues. After discussions with the contractor, one of the issues can be fixed; however, the other issue they are not going to fix, as they state does not pertain to them since they do not bid on cost reimbursement type work. This is the issue that DCAA has stated has minimal risk to the government.

My question is: If the contractor is never going to have an adequate report from DCAA are they eligible for T&M type task orders under a commercial IDIQ? I always thought with all T&M’s they need an adequate accounting system no matter what (based on FAR-other than FFP needs adequate accounting system). Or is commercial handled differently? Or is it a Contracting Officers discretion?

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The FAR does not require an adequate accounting system for T&M contracts -- it does for cost-reimbursement contracts (see FAR 16.301-3), but not for time-and-materials contracts.

However, your RFP did. Would you be upsetting the original competition by giving this contractor an exception to the RFP/contract requirement?

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However, FAR 16.104(i), Adequacy of the contractor's accounting system, states, before agreeing on a contract type other than firm fixed price, the contracting officer shall ensure that the contractor's accounting system will permit timely development of all necessary cost data iin the form required by the proposed contract type.

When I see other than firm fixed price, I think T&M is included.

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To me, the standards in FAR 16.301-3 and 16.104( i ) are very different, especially for a commercial item contract.

However, this is not relevant. It seems to me the competition purposefully EXCLUDED offerors who didn't have an adequate accounting system (using the definition in FAR 16.301-3? 16.104( i )? some other definition?). Even so, your agency awarded to a seemingly ineligible offeror making it eligible only for some task orders. Now, there is a thought to make that offeror eligible for all task orders.

Perhaps your agency should re-do the competition. There could have been many potential offerors who didn't propose because of the adequate accounting system test -- this offeror wasn't eligible under your agency's RFP but it got an award anyway (did the debriefings mention that one of the awardees wasn't eligible?). To me, is seems unfair to now make that offeror eligible for T&M task orders when everyone else who would have liked to proposed under those conditions has been shut out. It seems this one offeror/contractor is being treated very favorably.

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Trying to find opinions on whether or not a contractor needs to have an adequate accounting system for a T&M task order under a commercial IDIQ contract. The solicitation was developed with FAR Parts of 12, 15, and task orders are being issued under Part 16.

Background: The RFP stated that the contractors would have to have an adequate accounting system since T&M type task orders would potentially be awarded. Therefore, the offerors were required to have accounting system audits performed by DCAA. One of the contractors was deemed in-adequate; however, was still awarded an IDIQ with a statement made that they would only be eligible for firm fixed price task orders until their accounting system was deemed adequate. A follow up audit has been conducted by DCAA and again they are deemed in-adequate; however, with a note from DCAA that there is minimal risk to the government with one of their issues. After discussions with the contractor, one of the issues can be fixed; however, the other issue they are not going to fix, as they state does not pertain to them since they do not bid on cost reimbursement type work. This is the issue that DCAA has stated has minimal risk to the government.

My question is: If the contractor is never going to have an adequate report from DCAA are they eligible for T&M type task orders under a commercial IDIQ? I always thought with all T&M’s they need an adequate accounting system no matter what (based on FAR-other than FFP needs adequate accounting system). Or is commercial handled differently? Or is it a Contracting Officers discretion?

A contractor needs to have an accounting system that is adequate for the contract type being considered before the contractor can be determined responsible. This means you have to look at what type of accounting data is required for the contract type being considered. A contractor should only be required to generate minimal accounting data under a T&M contract for commercial items. For example, the cost principles do not apply to such a contract and the contractor does not have to submit an incurred cost proposal. Thus, the contractor would really have to have a screwed up accounting system not to be adequate for this contract. However, you said the contractor was awarded a contract, but somehow you stated the contractor would only be eligible to receive firm fixed price orders. That signnifies that you found the contractor's accounting system adequate for this purpose. I am curious as to exactly what standards DCAA used in conducting this audit and what were the deficiencies in the accounting system as alleged by DCAA. Finally, DCAA does not determine responsibility, the contracting officer does. If DCAA did not apply the proper standards and you determine that the contractor's accounting system is adequate for the contract type, I don't see why you could not determine the contractor responsible in regard to T&M orders.

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"A contractor needs to have an accounting system that is adequate for the contract type being considered before the contractor can be determined responsible. This means you have to look at what type of accounting data is required for the contract type being considered."

Yes, this is true. But the sad fact is that DCAA does not have a separate audit program for each contract type. In other words, DCAA has a one-size-fits-all-contract-types audit program that assumes all contract types (other than FFP) require the same level of adequacy. E.g., contractors that do not have any contracts that require progress payments are required to have accounting systems that can support cost-based progress payment requests, contractors that don't have any contractors that require accounting at CLIN levels are required to have accounting systems that can account for costs at the CLIN level, contractors that don't have any cost-reimbursement contracts are required to have accounting systems that meet all requirements of cost-reimbursement contracting, etc.

DCAA is in the process of revising its accounting system audit approach to address the needs of the new DFARS business system clauses. I've seen a briefing on the new approach. So far as I can tell, DCAA has no intention of having an accounting system adequacy audit program that can be tailored to focus only on requirements specific to the contract type(s) that the contractor has, or is bidding on.

I think it would be a great service to all DCAA customers if they would create just that type of flexible audit program. But as far as I can tell, there is no intention of doing so.

Hope this helps.

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I agree, that it would be nice for DCAA to have variations of audits based on the contract type; however, I was told that by our Cost/Price Auditors that they don't do that. I am still at a loss because I have a report that states they are in-adequate and without being an auditor myself, I cannot make the determination if their accounting data is adequate for T&M. That is why I am struggling because, I don't want to determine a contractor un-responsible for a T&M task order, if in reality they have adequate accounting data for T&M; however, the DCAA report just states they are in-adequate since it is a one size fits all report.

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CMSHR,

You said that the IDIQ was "commercial". What payment clause do you expect will control the contractor's invoicing? If you are contemplating 52.232-7, I think you and the contractor are SOL.

H2H

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CMSHR,

You said that the IDIQ was "commercial". What payment clause do you expect will control the contractor's invoicing? If you are contemplating 52.232-7, I think you and the contractor are SOL.

H2H

The payment clause should be Alt I to 52.212-4.

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I agree, that it would be nice for DCAA to have variations of audits based on the contract type; however, I was told that by our Cost/Price Auditors that they don't do that. I am still at a loss because I have a report that states they are in-adequate and without being an auditor myself, I cannot make the determination if their accounting data is adequate for T&M. That is why I am struggling because, I don't want to determine a contractor un-responsible for a T&M task order, if in reality they have adequate accounting data for T&M; however, the DCAA report just states they are in-adequate since it is a one size fits all report.

You stated that DCAA identified two issues. Apparently one of the issues relates to the contractor's ability to account for costs on cost reimbursement contracts. Because you are dealing with a T&M contract for commercial items, that issue should not be a stumbling block for the contractor to receive such orders. However, you have not identified what the other issue is or how it relates to the accounting data a contractor is required to generate under 52.212-4, Alt I, which is the appropriate payment claues for T&M contracts for commercial items. Read the clause and compare its requirements to what the DCAA audit report says, then exercise the authority given you as a contracting officer and make a decision. As long as the contractor can account for time expended on the contract, I think you have little risk. As I mentioned before, the cost principles do not apply to this type of contract and the contractor does not have to submit an incurred cost proposal. Finally, remember simply relying upon a DCAA audit report does not insulate you from having a successful protest filed asserting you did not have a rational basis for determining the contractor non-responsible.

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Retreadfed,

I agree that that 52.212-4 (Alt 1) should be the correct payment clause in the contract; however, I was hoping to learn what the actual payment clause was. Further, I also agree with you that if the correct payment clause was incorporated, then the DCAA issues are very likely to be moot.

I would like to be able to answer the original questions as follows.

1. Is the contractor eligible for T&M type task orders if DCAA says the accounting system is inadequate?

My answer would be yes if the 52.212-4 (Alt 1) clause was in effect and the CO found the contractor's timekeeping and billing systems to be adequate, based on the DCAA report.

2. Does a contractor need to have DCAA determine that its accounting system is adequate if the Government will award T&M type task orders under a "commercial" (i.e., Part 12) ID/IQ award?

My answer would be no since doing so violates the spirit, if not the express intent, of FASA--which is to award to "commercial" companies that would not otherwise be available to the government since they will not be able to comply with all requirements. Moreover, FAR 12.102© states that Part 12 policies take precedence over the policies of other Parts of the FAR (e.g., Part 16). So I would argue that if the CO is awarding under Part 12, s/he can find that there is no need for the contractor to have an accounting system that DCAA has determined to be adequate for "other than FFP" type work.

But the sticky issue is the solicitation. If it made DCAA's accounting system adequacy determination an element of responsibility, and that requirement was applied to all offerors, then how do you get around it without being accused of treating one offeror unequally. I don't think you can.

We have seen several recent bid protest cases along these lines (Vern posted one as I recall). If the CO requires DCAA to audit an offeror's accounting system and conclude that it is adequate under the criteria that DCAA uses, then a DCAA audit report that states the offeror did not meet those criteria is fatal. As far as I can tell, there is little (if any) leeway for a solicitation that misapplies that requirement, or DCAA criteria that are not applicable to the contract type that is being awarded. The lesson here, I would think, is that CO's had better be careful in what they require from offerors--make sure that they are asking for what only what they need to ask for. Second, when dealing with DCAA, the CO should attempt to focus DCAA on applicable requirements and try to get inapplicable criteria dropped from the audit scope. (I think this latter effort would fall under "agreed-upon procedures" in the DCAA rulebook.)

Hope this helps.

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The accounting system for a T&M commercial contract must be adeqate to comply with the terms and conditions of the T&M commercial contract.

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Retreadfed,

I agree that that 52.212-4 (Alt 1) should be the correct payment clause in the contract; however, I was hoping to learn what the actual payment clause was. Further, I also agree with you that if the correct payment clause was incorporated, then the DCAA issues are very likely to be moot.

I would like to be able to answer the original questions as follows.

1. Is the contractor eligible for T&M type task orders if DCAA says the accounting system is inadequate?

My answer would be yes if the 52.212-4 (Alt 1) clause was in effect and the CO found the contractor's timekeeping and billing systems to be adequate, based on the DCAA report.

2. Does a contractor need to have DCAA determine that its accounting system is adequate if the Government will award T&M type task orders under a "commercial" (i.e., Part 12) ID/IQ award?

My answer would be no since doing so violates the spirit, if not the express intent, of FASA--which is to award to "commercial" companies that would not otherwise be available to the government since they will not be able to comply with all requirements. Moreover, FAR 12.102© states that Part 12 policies take precedence over the policies of other Parts of the FAR (e.g., Part 16). So I would argue that if the CO is awarding under Part 12, s/he can find that there is no need for the contractor to have an accounting system that DCAA has determined to be adequate for "other than FFP" type work.

But the sticky issue is the solicitation. If it made DCAA's accounting system adequacy determination an element of responsibility, and that requirement was applied to all offerors, then how do you get around it without being accused of treating one offeror unequally. I don't think you can.

We have seen several recent bid protest cases along these lines (Vern posted one as I recall). If the CO requires DCAA to audit an offeror's accounting system and conclude that it is adequate under the criteria that DCAA uses, then a DCAA audit report that states the offeror did not meet those criteria is fatal. As far as I can tell, there is little (if any) leeway for a solicitation that misapplies that requirement, or DCAA criteria that are not applicable to the contract type that is being awarded. The lesson here, I would think, is that CO's had better be careful in what they require from offerors--make sure that they are asking for what only what they need to ask for. Second, when dealing with DCAA, the CO should attempt to focus DCAA on applicable requirements and try to get inapplicable criteria dropped from the audit scope. (I think this latter effort would fall under "agreed-upon procedures" in the DCAA rulebook.)

Hope this helps.

H2H, I have to take issue with several things you wrote above. First, if the contract is for commercial items, 52.212-4 Alt I is the authorized clause. 52.232-7 is not authorized for use in T&M contracts for commercial items. In the absence of a deviation to the FAR, use of 52.232-7 would be an unauthorized act on the part of the contracting officer.

Second, the contracting officer does not have to determine that the contractor's timekeeping and billing system are adequate based on a DCAA audit report. While DCAA is the usual source of information on these subjects, the contracting officer can make this determination based upon information from any source. I have seen knowledgeable contracting officers totally ignore DCAA findings of inadequacy on these topics when the audit report is not based upon rational or reasonable application of FAR requirements.

Next, the requirement that DCAA approve a contractor's accounting system as a criteria for responsibility has to be given a rational interpretation. Surely, you are not suggesting that the contracting officer must blindly follow what DCAA says, no matter how erroneous DCAA might be. In fact, the GAO has held just the opposite on several occasions. The principle to be followed in tis circumstance was stated in McKissack+Delcan JV II, B-401973.2; B 401973.4 (January 13, 2010):

Responsibility is to be determined based on any information received by the agency up to the time award is proposed to be made. FAR sect. 9.105-1(B)(3); American Tech. & Analytical Servs., Inc., B-282277.5, May 31, 2000, 2000 CPD para. 98 at 3. The determination of a prospective contractor's responsibility rests within the broad discretion of the contracting officer, who, in making that decision, must necessarily rely on his or her business judgment. We therefore will not question a negative determination of responsibility unless the determination lacked any reasonable basis. Oertzen & Co. GmbH, B-228537, Feb. 17, 1988, 88-1 CPD para. 158 at 3. In this respect, while a contracting officer has significant discretion in this area, a negative responsibility determination will not be found to be reasonable where it is based primarily on unreasonable or unsupported conclusions.[8] Decker and Co.; Baurenovierungsgesellschaft, m.b.H., B'220807 et al., Jan. 28, 1986, 86-1 CPD para. 100 at 7. Moreover, an agency's reliance upon the advice of DCAA does not insulate the agency from responsibility for error on the part of DCAA. See ASRC Research & Tech. Solutions, LLC, B-400217, B-400217.2, Aug. 21, 2008, 2008 CPD para. 202 at 11 n.12.

Note the reference to DCAA. In McKissack, the GAO found the contracting officer's reliance on a DCAA audit report to be unreasonable. While later decisions have upheld contracting officer determinations based on DCAA audit reports, in those situations, the GAO found contracting officer reliance to be reasonable. Thus, the question to be addressed is did DCAA properly apply the criteria for finding a contractor's accounting system inadequate considering the contract type contemplated? If it did not, upon a proper challenge by the contractor, a contracting officer's reliance on DCAA's conclusions would be misplaced and unsupportable.

One final note, the OP did not say whether the contractor in question was a small business. If so, I would like to know if the matter was referred to the SBA and if it was, what was the ourtcome.

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It seems to me that everything depends on the express terms of the solicitation, since GAO generally requires agencies to reject proposals that do not satisfy the solicitation's express terms. In the opening post CMSHR said:

The RFP stated that the contractors would have to have an adequate accounting system since T&M type task orders would potentially be awarded. Therefore, the offerors were required to have accounting system audits performed by DCAA.

If that is all that the solicitation said, then DCAA audit should be sufficient, and DCAA approval should not be essential. However, if the solicitation said that offerors must have a DCAA-approved system, then the CO had better have a pretty good explanation for disregarding the solicitation's express requirements. Such a requirement would be a special responsibility standard (aka "definitive responsibility criterion") pursuant to FAR 9.104-2, and would have to be enforced. See J2A2 JV, LLC, GAO Dec. B-401663.4, 2010 CPD para. 102, April 19, 2010. The only way out would be for the CO to determine that (a) the definitive criterion exceeded the agency's minimum needs and unduly restricted competition and (B) the offeror is responsible under a more reasonable standard. See Topley Realty Co., GAO Dec. B-221459, 86-1 CPD para. 398, April 23, 1986. However, in such a case it might be necessary to cancel the solicitation and start from scratch in accordance with FAR 15.206(e).

Bottom line: The solicitation should have said only that an offeror had to have an accounting system adequate to the contract type as determined by the CO and left it to the CO to decide later how that should be done. The system need not have been pre-approved by anyone. Absent some stupid agency policy requiring mention of DCAA in the solicitation, DCAA should not have been mentioned in the solicitation.

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Retreadfed,

I never said that 52.232-7 would be the correct clause to use. My point was that if a T&M type contract is being awarded, it's not the ENTIRE accounting system that needs to be adequate in all respects. Rather, I would assert that the contractor's timekeeping system needs to be adequate and its billing system needs to be adequate. These are subsidiary systems within the overall accounting system. I don't see how the government can award a T&M type contract if DCAA opines that the contractor cannot account for its time, since labor hours will be (largely) the basis for the price paid. Similarly, I don't see how the government can award a flexibly priced contract if DCAA opines that the contractor cannot issue an accurate invoice. Finding that the contractor's timekeeping and billing (sub)systems were adequate would seem to me to be the minimum findings necessary to issue a T&M task order in the face of a DCAA audit report that says the contractor's accounting system, as a whole, is inadequate.

Vern and Retreadfed,

I don't disagree with your points--in theory. But the scenario that's on the table is whether a CO can award a T&M task order when in possession of a DCAA audit report that states that the contractor's accounting system is inadequate. In this case, we have the helpful note from DCAA that risk to the government "is minimal" but that didn't change the audit report's opinion that the accounting system is inadequate.

While I would be thrilled to see a CO have the wherewithal to overturn or ignore a DCAA opinion and issue a T&M task order, via use of "independent business judgment," I'm still waiting to find that courageous CO. I mostly deal with DCMA so perhaps they are all at another agency. My current experience with DCMA is that it takes at least one Review Board, and perhaps two or three, to execute any controversial decision. It's so much easier just to go along with the DCAA report and avoid any controversy, and (in my experience) that's exactly what happens.

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Help:

You raise two distinct issues: (1) whether a CO legally could proceed in the face of DCAA's disapproval and (2) whether he or she would have the guts to do so. I know of nothing that would legally prevent a CO from rejecting DCAA's disapproval. Why a CO would want to do so I cannot say, but as a matter of statute and regulation the CO, not DCAA, has the last word on matters of contractor responsibility. DCAA audits are recommendations only. See Marine Design Technologies, Inc., GAO Dec. B-221897, 86-1 CPD para. 502:

As MDT points out, the contracting officer rejected DCAA's recommendation to use a 46 percent overhead rate with a ceiling on the actual rate to be charged. In our view, the decision not to follow the DCAA recommendation was reasonable in light of the contracting officer's conclusion that the two key assumptions on which the DCAA recommendation was based (projected work orders and new contract awards) were not accurate. In any event, DCAA audit reports are advisory only; there is no requirement that they be adopted by a contracting officer. Booz, Allen & Hamilton, B-213665, 84-2 CPD para. 329.

If a CO were to determine that an offeror is responsible despite DCAA's disapproval, and if there were a protest, I would hope the CO could state his or her rationale for rejecting DCAA's finding. (Perhaps the offeror presented the CO with a private accountant's opinion developed after the DCAA audit.) Assuming that the CO could give a reasonable explanation, I don't think GAO would sustain a protest of an affirmative determination of responsibility based on the ground that DCAA had disapproved the contractor's system.

Would a CO have the courage to do it? Would a CO's superiors let the CO do it? Probably not, but some CO;s might, even if most would not, and some of their bosses might let them. Who knows?

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Retreadfed,

I never said that 52.232-7 would be the correct clause to use. My point was that if a T&M type contract is being awarded, it's not the ENTIRE accounting system that needs to be adequate in all respects. Rather, I would assert that the contractor's timekeeping system needs to be adequate and its billing system needs to be adequate. These are subsidiary systems within the overall accounting system. I don't see how the government can award a T&M type contract if DCAA opines that the contractor cannot account for its time, since labor hours will be (largely) the basis for the price paid. Similarly, I don't see how the government can award a flexibly priced contract if DCAA opines that the contractor cannot issue an accurate invoice. Finding that the contractor's timekeeping and billing (sub)systems were adequate would seem to me to be the minimum findings necessary to issue a T&M task order in the face of a DCAA audit report that says the contractor's accounting system, as a whole, is inadequate.

Vern and Retreadfed,

I don't disagree with your points--in theory. But the scenario that's on the table is whether a CO can award a T&M task order when in possession of a DCAA audit report that states that the contractor's accounting system is inadequate. In this case, we have the helpful note from DCAA that risk to the government "is minimal" but that didn't change the audit report's opinion that the accounting system is inadequate.

While I would be thrilled to see a CO have the wherewithal to overturn or ignore a DCAA opinion and issue a T&M task order, via use of "independent business judgment," I'm still waiting to find that courageous CO. I mostly deal with DCMA so perhaps they are all at another agency. My current experience with DCMA is that it takes at least one Review Board, and perhaps two or three, to execute any controversial decision. It's so much easier just to go along with the DCAA report and avoid any controversy, and (in my experience) that's exactly what happens.

H2H, let me give you a real example of where it would be foolhardy for a contracting officer to accept a DCAA opinion that a contractor's timekeeping and billing systems are inadequate resulting in an inadequate accounting system. In this situation, DCAA determined these systems were inadequate because the contractor did not account for its time on commercial (non-government) contracts to the same level as it did on its government contracts. For its government contracts, the contractor was required by contract terms to account for costs and bill at the task order level or CLIN level on various contracts whereas on its commercial contracts, the contractor only accounted for time and billed at the contract level. DCAA could identify any impact this so-called deficiency had on government contracts. What logical connection did this so called deficiency have on the contractor's ability to account for costs on government contracts is beyond me. Any contracting officer receiving this report should not give any deference to it and it certainly should not be considered a valid basis for finding a contractor's timekeeping, billing or accounting system inadequate.

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Retread:

You have to admit that what a CO, especially a DOD CO, should do with a DCAA recommendation and what she would be willing or able to do are two different things.

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Retread:

You have to admit that what a CO, especially a DOD CO, should do with a DCAA recommendation and what she would be willing or able to do are two different things.

Yes, and it is a sad commentary on the state of government contracting.

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First time poster, long time follower of this great Board..., really great board.

I have two bullets.

(1) The comments about a DCMA KO overturning a DCAA accounting inadequate accounting system.., yes, that would take a lot of guts. Things have changed at DCMA in that we (KOs) now have to have more mgmt approval than before.., we cannot work as independently as we used to. And if we go against DCAA, we have to use our internal board (as several have stated above). So in reality, no matter how brave or how smart the DCMA KO is, it is not healthy to reject a DCAA system report. I am sorry if I am stating the obvious.

(2) Several have posted that they would like to see some sort of scaled-back system audit for T&Ms, etc.., On the DCAA website, click on Standard Audit Programs and then check out the 17741 Accounting System for Commericial T&Ms. This appears to be very scaled back in that indirect costs are not mentioned to the extent as the 'full-blown' system audits. I am not saying this is the answer, but perhaps DCAA can be guided to use their own audit programs if you are awarding T&M (LH) type contracts.

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First time poster, long time follower of this great Board..., really great board.

I have two bullets.

(1) The comments about a DCMA KO overturning a DCAA accounting inadequate accounting system.., yes, that would take a lot of guts. Things have changed at DCMA in that we (KOs) now have to have more mgmt approval than before.., we cannot work as independently as we used to. And if we go against DCAA, we have to use our internal board (as several have stated above). So in reality, no matter how brave or how smart the DCMA KO is, it is not healthy to reject a DCAA system report. I am sorry if I am stating the obvious.

(2) Several have posted that they would like to see some sort of scaled-back system audit for T&Ms, etc.., On the DCAA website, click on Standard Audit Programs and then check out the 17741 Accounting System for Commericial T&Ms. This appears to be very scaled back in that indirect costs are not mentioned to the extent as the 'full-blown' system audits. I am not saying this is the answer, but perhaps DCAA can be guided to use their own audit programs if you are awarding T&M (LH) type contracts.

The problem is that DCAA has not issued any guidance in regard to an incurred cost submission when the only contracts a contractor has that require the submission of an incurred cost proposal are T&M contracts. I know that some DCAA offices are requiring such contractors to submit full incurred cost submissions although the only indirect cost subject to adjustment under these contracts is G&A.

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What is included in a Commercial T&M Rate?

Although these rates are not based upon costs does the contractor still need to be careful not to quote/charge indirect labor as direct labor? If a contractor in its internal accounting treats certain labor functions as a cost allocation – such as office administration or home office costs, can it choose to quote/charge these labor costs under a direct Commercial T&M Rate?

Without a disclosure statement, does the distinction between direct and indirect labor go away?

Likewise, must the contractor estimate consistently under commercial T&M?

Would this issue be covered under an Adequate Accounting System requirement?

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