Luigi D'Amato Posted April 15, 2019 Report Share Posted April 15, 2019 Two wholly owned subsidiaries will be partnering for work to be rendered to the US Government under a CPFF contract. Both Business Units have their won DCAA approved Indirect rates. Company B will invoice Company A for all Direct Costs plus their Indirect burdens plus their fees. Company A, which owns the contract, will produce its own invoice charging all its costs plus Indirect and their fee. Is Company A allowed to apply a Fee, call it a Handling Fee, to the invoice received from Company B? Link to comment Share on other sites More sharing options...
Neil Roberts Posted April 16, 2019 Report Share Posted April 16, 2019 Is it contemplated that A will issue a subcontract to B? If so, are handling fees consistent with A's CAS Disclosure Statement or practice? If not contemplating a subcontract, does A contemplate handling the transaction as an inter-organizational agreement, and if so, why? Link to comment Share on other sites More sharing options...
here_2_help Posted April 16, 2019 Report Share Posted April 16, 2019 21 hours ago, Luigi D'Amato said: Is Company A allowed to apply a Fee, call it a Handling Fee, to the invoice received from Company B? If Company B is providing a comercial item and its consistent practice has been to sell that item at price and that price is not unreasonable, then yes. Otherwise, no. See 31.205-26(e). Link to comment Share on other sites More sharing options...
Retreadfed Posted April 16, 2019 Report Share Posted April 16, 2019 21 hours ago, Luigi D'Amato said: Is Company A allowed to apply a Fee, call it a Handling Fee, to the invoice received from Company B? Have you considered the impact FAR 31.205-26(e) may have on this issue? Link to comment Share on other sites More sharing options...
Recommended Posts