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Postaward

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  1. ConMan411 Cost and FFP items should each be on there own ACRNs. If your invoicing and shipping, the liquidation is a moving target. Progress Payments usually apply contract wide to all FFP ACRNs (unless otherwise specified). If a CLIN has cost and FFP elements you can get overpaid. ACO should know that. Don't want to mix those items up under same ACRN. FFP under one ACRN, cost under another; will make life a lot simpler.
  2. Deaner, I would go with brian’s logic. Whom ever issued the grant (Grants Officer, aka GO) would be the one to administer the grant unless delegated to an Administrative Grants Officer. Contracts shouldn’t be doing administrating (decisions and approval up to the warranted grants officers). Deaner “The grant was awarded and funded. what am i suppose to do with the grant funding.... no idea. The VA employee (grantee) would submit documentation supporting the SF270 Request for Advance or Reimbursement to the GO for approval. Possibly following the budget proposal submitted in the grant proposal. The GO would approve payment (very simplified).
  3. Yes, I read into the post. My take from the post is what leo1102 has stated "If the sum of all tolls are billed on a single invoice and if that invoice is recurring on a monthly basis, then this is a recurring procurement and should not be paid using a GPC." My take from jimschank post; each amount is a monthly bill. The GPC holder is getting one bill " One person in an offsite office has an ez pass account to pay the toll charges for the staff in that office.". So, It is not a on demand service where each toll is paid immediately. I wasn't as clear as leo1102.
  4. As a previous billing official on the GPC program, I say violation. You can’t keep making purchases over and over (knowingly) if they end up exceeding SAP. Look up split disbursement (doesn’t matter that individual purchases are under, you also need to evaluate recurring purchases too). You have history from the previous year to indicate that the SAP will be exceeded. A better instrument (contract, BPA) should be established.
  5. Not concerning the approval process (and that is what was asked), addressing the idea of the CLIN structure ---for DoD see https://dfas4dod.dfas.mil/cps/contractingofficers/: OSD AT&L DPAP Policy Memo "USA001601-11-DPAP - Contract Line Item Pricing Integrity", which prohibits the use of "dollars" or "lump sum" as a unit of measure on a contract line item. Just a FYI which may change the approval process.
  6. I would notify the government. FAR mentions submission of payment for contract and CCR not matching. FAR 42.12 This subpart prescribes policies and procedures for -- (a) Recognition of a successor in interest to Government contracts when contractor assets are transferred; ( Recognition of a change in a contractor’s name; and © Execution of novation agreements and change-of-name agreements by the responsible contracting officer. See FAR 4.1102 ( c )(1) (i) If a contractor has legally changed its business name, "doing business as" name, or division name (whichever is shown on the contract), or has transferred the assets used in performing the contract, but has not completed the necessary requirements regarding novation and change-of-name agreements in Subpart 42.12, the contractor shall provide the responsible contracting officer a minimum of one business day's written notification of its intention to change the name in the CCR database; comply with the requirements of Subpart 42.12; and agree in writing to the timeline and procedures specified by the responsible contracting officer. The contractor must provide with the notification sufficient documentation to support the legally changed name. (ii) If the contractor fails to comply with the requirements of paragraph (g)(1)(i) of the clause at 52.204-7, Central Contractor Registration, or fails to perform the agreement at 52.204-7(g)(1)(i)©, and, in the absence of a properly executed novation or change-of-name agreement, the CCR information that shows the contractor to be other than the contractor indicated in the contract will be considered to be incorrect information within the meaning of the "Suspension of Payment" paragraph of the EFT clause of the contract. FAR 52.407 (g)(1) Central Contractor Registration (i) If a Contractor has legally changed its business name, "doing business as" name, or division name (whichever is shown on the contract), or has transferred the assets used in performing the contract, but has not completed the necessary requirements regarding novation and change-of-name agreements in Subpart 42.12, the Contractor shall provide the responsible Contracting Officer a minimum of one business day's written notification of its intention to: (A) Change the name in the CCR database; ( Comply with the requirements of Subpart 42.12 of the FAR; © Agree in writing to the timeline and procedures specified by the responsible Contracting Officer. The Contractor must provide with the notification sufficient documentation to support the legally changed name. (ii) If the Contractor fails to comply with the requirements of paragraph (g)(1)(i) of this clause, or fails to perform the agreement at paragraph (g)(1)(i)© of this clause, and, in the absence of a properly executed novation or change-of-name agreement, the CCR information that shows the Contractor to be other than the Contractor indicated in the contract will be considered to be incorrect information within the meaning of the "Suspension of Payment" paragraph of the electronic funds transfer (EFT) clause of this contract.
  7. tguns A Proper invoice has to be totally correct. No errors, why would the clock start 3 July when is hasn't been reviewed to ensure it is accurate? A submission does not mean it is correct; the billing office (my assumption is where it was fax to) would be the best date to start in your example.
  8. H2H and Retread have it right. The invoice may still be wrong, I see issues like this weekly. Wrong ACRNs, CLINs, etc; the payment office will determine if the invoice is proper and when the time counter starts. CORs, QARs sign forms all the time that are not correct (not putting them down, there is a lot to verify). DFAS will pay interest if late.
  9. Question, being very general on the issue; trying to see if the $500 can be justified. The contractor’s offer was not correct but it was accepted by the government. Now the government has to correct the offer through a contract modification (more work) to make it correct. Isn’t the government just asking for consideration for its acceptance (cost of the modification)? Asking to learn.
  10. DCMA instructions: ....2.3.2.4. Excess and Remaining Funds. Generally fixed price contracts have an unliquidated (ULO) balance equal to $0.00 when the contract becomes physically complete. However, there are instances where the contract allows for variances in quantity shipped, the contractor has rounded on the invoice, or performance on a specific CLIN was not necessary (e.g., fixed funds provided for maintenance or service on computer hardware). (ND) The functional specialist shall complete a review of funds to determine the reason why the ULO balance does not equal $0.00. The review is conducted to determine if the funds are ?excess? or ?remaining? to contract requirements. Upon completion of the review, the circumstances that caused the funds balance will dictate whether funds can be deobligated via modification or removed automatically in MOCAS via the Q-Final process (see paragraph 2.3.2.4.2. for additional information about the Q-Final process). 2.3.2.4.1. Excess funds are funds relating to a specific line item or deliverable that was not performed on a contract. (ND) The functional specialist shall deobligate all excess funds by contract modification. For contracts administered in the MOCAS system, the modification shall be fully processed before proceeding with the MCC eTool Final Pay NLA procedure. 2.3.2.4.2. Remaining funds are funds left on a contract due to quantity variances or price rounding and where all contract performance as required by the contract has been completed and paid in full. (ND) For contracts administered in the MOCAS system, the functional specialist shall annotate the ACO Notebook with a remark stating, ?$XX.xx (amount of remaining funds) funds are remaining funds. When the Final Pay NLA is processed using the MCC eTool, this annotation enables MOCAS to use the Q-Final process and automatically clear the remaining funds and proceed with closing the contract. Prior to a contract moving to Section 5, when there is a ULO balance, MOCAS automatically generates a Q-Final transaction to reduce the ULO to zero. .... May or may not be helpful.
  11. Thank you both very much for your insight.
  12. I just picked up administration on a contract and would like to get a very anxious contractor paid. But there are issues. The payment office is saying the invoices do not match the contract price. Which they (the invoices) do not, because the buying command issued a modification. The question is where should the modification be applied? IDIQ supply contact. Quantities (min and max) and unit prices are set on basic. Delivery Order 0001 was issued and completed (not relevant, but DO 0001 had 4 mods: 01-04) DO 0002 was issued (say 04/11) following the basic?s pricing scheme. (DO 0002 has one mod already: 01) There are no other active orders. The buying command issued P00006 (say 06/11) against the basic. It changes the prices (which is what the contractor is billing to) and several other bits of information. The previous administrator said the buying command stated that the prices flow down. Here is where I disagree. My view is the price changes or the entire modification should be with DO 0002 so that the proper billing can take place. Not on the basic. I should have a X87888 11 D 8788 0002 02 vs. X87888 11 D 8788 P00006. Since the order was previously issued, prices would not flow down would they with P00006? Or is the buying command correct because orders on an IDIQ are not contracts by themselves? Hopefully I put in all the relevant information. Just FYI trying to get the payment office to just pay what the contractor is billing for ( it is a lessor amount and they can do an additional billing later if needed, but the argument is about matching the contract)
  13. Can a payment be made after the delivery date (performance date) ends? Yes, lot of supplies are shipped on the final delivery date and the government then gets billed after that date. Cost type contracts may be billed years after the final delivery date. Does the FAR require the contracting officer to modify the contract to extend the delivery dates? if so what part? 43.103 -- Types of Contract Modifications. Contract modifications are of the following types: (a) Bilateral. A bilateral modification (supplemental agreement) is a contract modification that is signed by the contractor and the contracting officer. Bilateral modifications are used to -- (1) Make negotiated equitable adjustments resulting from the issuance of a change order; (2) Definitize letter contracts; and (3) Reflect other agreements of the parties modifying the terms of contracts. Changing the delivery dates would be change in the terms of the agreement, if past the orginal date and no provision for early delivery. There should also be consideration given.
  14. PBP Performance Based Payment = If all milestone(s) are not completed for a task, no payment is approved. What more incentive would you need.
  15. DFAS has a long acronym guide http://www.dfas.mil/dfas/contractorsvendors.html Then acronym guide (49 pages worth).
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