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Subcontract LCATS Consistent with Prime?


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Do the subcontractor labor category names have to be the same as the primes? We try to keep them consistent, but sometimes our Sub's are given different LCAT names than we have in our prime contract. We have a new billing person and they are insisting that we cannot do that because the subcontractor bill will not reconcile to what we bill the Government. Does anyone have any experience or insight on this? Can you provide a regulation?

Thank you,

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Thank you, but my question relates more toward billing specifically. Our billing person says that you cannot have the sub's invoice say SME II and then map it to our FA III. I think the billing person just gets confused and it causes more work for them. But I didn't know if there was regulatory guidance somewhere like DCAA, I looked it up and couldn't find anything.

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SubK,

In my view the guiding principle should be equivalence. Do the qualifications of the labor categories match up, regardless of the nomenclature used? If so, then I would be fine with mapping them. In fact, I would definitely map them based on qualification equivalence regardless of what the titles say.

If your billing person is having problems, it's likely because nobody prepared a mapping and reviewed it in terms of qualifications and signed-off. If that happened and your billing person is still hesitating, I would strongly suspect you are not paying enough to attract the right type of billing person to support government contract invoices.

Hope this helps.

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