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52.204-14 - Question


ConMan411

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A task order awarded in 2016 has just now hit our Service Contract Reporting list in SAM.  However, this is a FPIF task order and we are working on "progress payments" not "invoices" as we are delivering a system, with a ETA of 2021 for the DD250.  I am a bit confused as to why we are now being asked to report on this task order, how its applicable since we aren't providing "services" and what amount I would use for "total invoiced" when we are using progress payments. Any advice?  When I posed the question to our CO office, they referred me to the technical POC.

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I don't have all the answers to your questions, but I do know that progress payments are cash-flow-enhancing financing payments that are not final payments for delivery. As you noted, you will still have to submit one or more DD250s ("invoices") to liquidate your progress payments and receive final payment for delivery. If you don't have any interim deliverables and haven't submitted any DD250s, then "total invoiced" amount = zero.

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Thank you here_2_help, it confirms my understanding of the progress payments and how I view the total invoiced amount being zero.  Maybe someone else knows more about the service reporting to see if the reporting is required when we are delivering something.  We have other contracts that are services with a few materials that we report, but this task order is nothing at all like our "services" orders, this is delivering a complete system(s) built with COTS (if that matters).

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7 hours ago, ConMan411 said:

A task order awarded in 2016 has just now hit our Service Contract Reporting list in SAM.  However, this is a FPIF task order and we are working on "progress payments" not "invoices" as we are delivering a system, with a ETA of 2021 for the DD250.  I am a bit confused as to why we are now being asked to report on this task order, how its applicable since we aren't providing "services" and what amount I would use for "total invoiced" when we are using progress payments. Any advice?  When I posed the question to our CO office, they referred me to the technical POC.

FAR 2.101 defines an "invoice" as a bill or written request for payment for supplies delivered or services performed (bold type added)

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The right side of this document might give you a lead on the source for service contracts that require reporting. The left side might answer your question regarding date and type contract requiring reporting. It seems to me that your FPIF contract might come under the broad umbrella of fixed price contracts that require reporting.

https://www.sam.gov/SAM/transcript/SCR_QSG.pdf

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