DD Form 1423, Block A Interpretation

[jksbarrett]

How do you interpret Block A: Contract Line Item No. in DD Form 1423: The CLINs on which the work to prepare the deliverable should be billed or the CLINs to which the deliverable is applicable / the CLINs on which the deliverable should be reporting? 

Deliverables such as a software test report seem obvious... the CLIN on which software testing is occurring is the CLIN on which the time developing the test report is what should be listed in Block A. 

However, an MSR (the deliverable that spurned this discussion) is an example of deliverable that should be reporting status of all activities across all active CLINs but the hour spent preparing it should be accounted for on a single CLIN. 

The DOD 2010.12-M states: "Block A, "Contract Line Item No." (CLIN) - Enter the CLIN that is associated with the CDRL."

[ji20874]

I think Block A is for the contract line item that purchases the data.

As an aside, I note that your example is for a MSR.  Some people believe that the term "data" does not include information incidental to contract administration, such as financial, administrative, cost or pricing, or management information.  If MSR stands for monthly status report, maybe you don't need a CDRL to get it -- if so, your problem disappears entirely.

[Vern Edwards]

DD Form 1423 is an exhibit. See DFARS 204.7105 and DOD PGI 204.7105. It is used to collect individual data deliverables (data items) under a single contract line item rather than establish a separate line item for each data deliverable. It is an administrative convenience.

When using DD Form 1423 the CO must establish a contract line item for data, then refer to the DD Form 1423. In Block A you insert the contract line item number for data.

So, you might have:

CLIN 0001 - Performance in accordance with Section C, Statement of Work for the X Program.

CLIN 0002 - Exhibit A, DD Form 1423, Contract Data Requirements List (CDRL).

On the DD 1423, in Block A, you would insert "0002."

[common_fate]

My experience was different. I regularly saw multiple CLINs referenced in Block A. I never even considered the issue of identifying which CLIN in Block A to be about billing. It was far more important to ensure the correct distro statement/ instructions for preparation was applied to the particular data being procured. 

On 2/2/2022 at 6:23 PM, jksbarrett said:

However, an MSR (the deliverable that spurned this discussion) is an example of deliverable that should be reporting status of all activities across all active CLINs but the hour spent preparing it should be accounted for on a single CLIN.

As it relates to your original question, the monthly status report should be its own deliverable with its own CDRL. Reference all applicable CLINs in Block A (for example: 0001 -0002 (0003 if exercised)) ... but not because of the billing question, but because the monthly status report would have its own distro statement and instructions for preparation versus the other CDRLS on the award.

[formerfed]

8 hours ago, common_fate said:

My experience was different. I regularly saw multiple CLINs referenced in Block A. I never even considered the issue of identifying which CLIN in Block A to be about billing. It was far more important to ensure the correct distro statement/ instructions for preparation was applied to the particular data being procured. 

As it relates to your original question, the monthly status report should be its own deliverable with its own CDRL. Reference all applicable CLINs in Block A (for example: 0001 -0002 (0003 if exercised)) ... but not because of the billing question, but because the monthly status report would have its own distro statement and instructions for preparation versus the other CDRLS on the award.

I agree.  One chief reason the 1423 process was developed decades ago was to standardize data reporting.  One identifies all data required in contract performance and summarizes it in the 1423 attachment.  For each item, an appropriate Data Item Description (DID) describes appropriate data requirements for specific data.  The ASSIST system has several DID formats someone can pick from for a monthly status report for example.

If this were my contract, I would try to develop a single monthly report for the entire contract.  But if performance requires a diverse mix, I would establish a separate CLIN for each.  But the CDRL items don’t have anything to do themselves with billing apart from the fact you might be paying for the data deliverable as a CLIN itself.

[Vern Edwards]

@common_fate @formerfed

11 hours ago, common_fate said:

I regularly saw multiple CLINs referenced in Block A.

2 hours ago, formerfed said:

I agree.

The instruction for Block A on the back of DD1423 says "self explanatory."

So what does "contract line item" mean to you two?  Source?

Furthermore, DOD 2010.12-M, Procedures for Acquisition and Management of Technical Data, May 1993, which is still referenced by DAU, paragraph C.3.3.3.1, subparagraph C.3.3.3.1..2 says:

Quote

C3.3.3.1.1. Block A, "Contract Line Item No." (CLIN) - Enter the CLIN that is associated with the CDRL.

So, what are you two talking about?

What you have "seen" is not always what is correct. The DD1423 is part of a system of documents, including the DFARS, the DOD manual cited above, and DOD Handbook 245D. The system has a purpose and a logic. Why not just follow instructions and understand the logic instead of relying on what you have "seen" and making stuff up?

[formerfed]

I’m not sure we all are addressing the same point.  This is the issue that started the thread:

 

Quote

However, an MSR (the deliverable that spurned this discussion) is an example of deliverable that should be reporting status of all activities across all active CLINs but the hour spent preparing it should be accounted for on a single CLIN. 

Vern, how do you respond to the original question?

[Vern Edwards]

42 minutes ago, formerfed said:

Vern, how do you respond to the original question?

Go back and read. I responded to it on February 3. 2022.

[formerfed]

Vern,

I see what you’re saying.  In practice many offices are including data items as separate clings or sub lines, especially when they carry a significant price.  So the DD 1423 identifies data items as deliverables with their own prices in Section B.  I think that practice carries over sometimes to the notion that everything in the DD 1423 needs identified such as monthly status reports which is the basis of the ordinal thread question.

[Vern Edwards]

As ji20874 pointed out in his response, some, including me, do not think a monthly status report is "data" that the government is purchasing. It should not be treated as a deliverable. It should not be included on a DD1423. The SOW should simply state that the contractor must report the status of the program or project to the CO and the PM in writing on a monthly basis.

AS for the OP's question, just follow the instructions in the documents I cited and in any local addenda. "Contract line item" should be clear to all but the truly clueless.

The DD1423 is used as an "exhibit." It is a list of separate deliverables. See DFARS 204.7101. The purpose is to avoid the need for a large number of CLINS in Uniform Contract Format Section B. Each exhibit is assigned its own CLIN. That's the CLIN to cite in Block A. Each item on the exhibit has its own number. You can have multiple exhibits on a contract, each associated with a different performance CLIN.

Do people "see" it done differently? Yes, because people don't follow instructions or depart from them for their own convenience or for reasons only God knows..

The system is not hard to understand if you take the time to research its underpinnings. I learned about DD1423, exhibits, and attachments almost 50 years ago. The system has changed little since. But at least three quarters of today's workforce are clueless. Some of that is due to no instruction or faulty instruction; some of it is due to a lack of curiosity; some to a lack of skill at inquiry; some of it is due to cut-and-paste behavior.

[Evonan]

In my experience for AF Systems, we used the 1423 for each CLIN that had data deliverables. The data CLINs in the contract were generally "not separately priced" so it wasn't used for billing. It was used to identify what data deliverables were required for each CLIN identified in Block A of the 1423. Each contract/order would have multiple CLINs each requiring multiple data deliverables. Again, just my experience. 

[Vern Edwards]

Just now, Evonan said:

In my experience for AF Systems, we used the 1423 for each CLIN that had data deliverables. The data CLINs in the contract were generally "not separately priced" so it wasn't used for billing. It was used to identify what data deliverables were required for each CLIN identified in Block A of the 1423. Each contract/order would have multiple CLINs each requiring multiple data deliverables. Again, just my experience. 

That is proper usage in accordance with DOD policy and instructions. I presume that if you had two CLINs that required data deliverables, you had two DD Form 1423 exhibits, one for each CLIN.

Block A on  each exhibit would identify the CLIN with which it is associated. Block 5 of each data item on the exhibit would identify the part of the contract that specifies the work that is expected to produce the data to be delivered.

[Evonan]

1 minute ago, Vern Edwards said:

That is proper usage in accordance with DOD policy and instructions. I presume that if you had two CLINs that required data deliverables, you had two DD Form 1423 exhibits, one for each CLIN. Block A on  each exhibit would identify the CLIN with which is associated. Block 5 of each data item would identify the part of the contract that specified the work that produced the data to be delivered.

Vern,

Yes, that is generally how it would flow. One form for each CLIN that required deliverables, so each order or contract could have anywhere from 1 to hundreds depending on the buy. 

[Vern Edwards]

Just now, Evonan said:

One form for each CLIN that required deliverables, so each order or contract could have anywhere from 1 to hundreds depending on the buy. 

I think it may be permissible to use one exhibit (DD 1423) for a contract with multiple CLINs. But I would have to check that. It may be necessary to have multiple exhibits if each CLIN is separately-funded.

[uva383]

See DFARS PGI 204.7105(1)(4):

(a) Use of exhibits.

(4) Each exhibit shall apply to only one contract line item or subline item.

 

[Vern Edwards]

Thanks, uva383.