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UK Single Source Contract Regulations

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I have been asked to dig into the UK Single Source Contract Regulations. The SSRO rules apply to a large defence contract awarded without competition. When applicable, the SSRO rules supersede the long-standing MOU between the UK MOD and the US DOD regarding contract costs and audit. I realize that almost nobody has experience with these newly promulgated rules but I'm looking for any inkling of a policy position out of DOD on this issue. For example, has anybody heard whether DCAA will be performing audits IAW the UK SSRO rules, or will the UK auditors be coming to the US to perform audits?

To me this ought to be a big deal, but I'm learning it's not because the big defense contractors have set up UK subsidiaries who know how to comply with the rules, which are the equivalent of the Part 31 Cost Principles and CAS merged together, written in British. For them the US entities simply transfer costs and it's up to the UK entities to scrub them. I will not be so fortunate.

Anything?

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H2H, you must be lucky on this one.  I don't have any insight into what, if anything DoD may have in mind on this.  Unless there are U.S. appropriated funds involved, or the UK contract is in support of a US/UK/NATO program, DoD probably will not have an interest in the UK contract.  On the other hand, the State Department might if the item sought under the UK contract is covered by the ITAR.  That would be a matter between the contractor and State.  As for DCAA, because of section 893 in the 2016 NDAA, I doubt it will be doing any auditing of US companies receiving UK contracts.

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Thanks Retreadfed! Yes, the item(s) sought under the contract are covered by ITAR ...

H2H

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Popping in here to say that I've done my research and talked to as many people as I could. Some of the info has been conflicting -- e.g., one group is sure DCAA will be performing the audits but another group is just as sure that the UK MOD auditors will be performing them. That said, I believe we have a strategy in place that should work.

Fun times!

H2H

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