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Realigning 1 year funds


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We are currently in the base period of the contract which started in FY 18. The base period includes ODCs/travel which have not been fully funded. The funds that were obligated are 1 year FY 18 funds. Can funds from the travel CLIN be realigned to the ODC CLIN ?

 

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On 6/28/2019 at 1:36 PM, d0d01126 said:

We are currently in the base period of the contract which started in FY 18. The base period includes ODCs/travel which have not been fully funded. The funds that were obligated are 1 year FY 18 funds. Can funds from the travel CLIN be realigned to the ODC CLIN ?

 

Do you have access to DFAS or other finance and accounting offices or guides, regs, etc.?  

To me, it would be a within scope change, not a de-obligation and re-obligation of funds. If original year funding is still available for in-scope changes (usually for several years after the initial one year period of availability for “new” obligations), it would seem to me to be allowable to move same appropriation funds within line items on an existing contract.   There might be more machinations necessary, if the funds allocation numbers ( I don’t remember the correct terminology) between line items are different.  

The F&A folks are the experts and should be consulted as the mod will have to identify the accounting citation won’t it? 

Do not all KO’s, ACO’s  and their CS staff have access to F&A offices for answers to these type questions????? I can’t imagine that KO’s are making up funds citations on their own. Even when I was in the Air Force in the 70’s at base level , I had an F&A office for funding requirements and funding questions. 

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 I assume this is a cost reimbursement contract funded with FY18 O&M and has been incrementally funded.  Is this correct?  If so, my answer would be no...go get current year funds from your customer to add to the ODC CLIN and deobligate the old money off the CLIN showing a positive variance.  Consult with your comptroller as others have recommended to ensure you're not violating something in the FMR.  I hope you are not referring to ODCs that have already been incurred by the KTR.  There should be a record of LOF notifications sent by the contractor leading up to this point per FAR Clause 52.232-22 (hope that's in the contract if it's incrementally funded). 

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1 hour ago, GtarJohn said:

 I assume this is a cost reimbursement contract funded with FY18 O&M and has been incrementally funded.  Is this correct?  If so, my answer would be no...go get current year funds from your customer to add to the ODC CLIN and deobligate the old money off the CLIN showing a positive variance.  

Why are you saying this?

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Do you disagree with me or something?  I didn't know this was a debate forum or such that it was expected every post response to be a Grad School dissertation.  I'm beginning to believe this site to be more about trolling, 1-upping and/or flexing one's intellectual prowess than actually sharing ideas and offering potential solutions to problems.

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Sorry if I came across like that.  In the absence of more information from the OP, Joel Hoffman’s response above seems correct to me.  The obligation is valid and the only change is something in scope - using more ODCs than less travel.  The overall contract amount remains unchanged and it’s just a switch of funds at the sub object class level.

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7 hours ago, joel hoffman said:

it would seem to me to be allowable to move same appropriation funds within line items on an existing contract.

Joel, I agree, however I have seen contracts that specifically prohibit this.  Thus, I think it is necessary to know what, if any, restrictions the contract has in regard to moving funds from one CLIN to another.  Further, it is not clear if the OP is asking if the contractor can unilaterally "realign" the funds or if the government can do it.

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It's no big deal formented.  I don't have enough information of the OPs situation to really offer advice and can only speculate.  I don't see the realighment as being added scope...shoot, we (The USG) do CLIN realignments all the time on our cost type contracts.  Thinking more about this...It sounds like the ODC CLIN has been partially funded...thus the alignment will result in it being fully funded.  I would get your finance and legal to chime in on it before proceeding, but it may be ok.  Does the KTR's ETC and EAC show a need to be fully funded on the ODC CLIN?   If they are showing a positive variance in their status reporting, there may not be a need to fully fund it.  

 

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33 minutes ago, Retreadfed said:

Joel, I agree, however I have seen contracts that specifically prohibit this.  Thus, I think it is necessary to know what, if any, restrictions the contract has in regard to moving funds from one CLIN to another.  Further, it is not clear if the OP is asking if the contractor can unilaterally "realign" the funds or if the government can do it.

 Retread I agree  with you. 

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On ‎6‎/‎28‎/‎2019 at 2:36 PM, d0d01126 said:

Can funds from the travel CLIN be realigned to the ODC CLIN ?

Not enough information to conclude the appropriateness of shifting funds from one CLIN to another.  You’ll need to consider the time, purpose, and amount restrictions of the appropriated funds  before you can change what they'll be used for (the ODCs).  See the Red Book, Chapters 3, 5, and 6.

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So wouldn’t the mechanics of a “realignment of funds between CLIN’s” involve revising the estimated quantities of the line items for fully funded, fixed price contracts? Then, if the accounting citation is the same for both CLINs, it should be doable, but check with F&A . 

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