This is my first post to the forum. I sincerely hope I give enough information that I won?t get beat up too bad but if I don?t, please be gentle.
Here is the scenario. CPFF contract with multiple subcontractors. Period of Performance is by Government Fiscal Year. Subcontractors have submitted their invoices for September during the month of October. Once those invoices are received they are applied to the Prime contractors cost statement and then paid. The prime contractor submits a cost voucher for payment which is subsequently rejected since the subcontractors cost was applied AFTER the PoP had expired even though the costs were incurred during the PoP. DCAA stated the reason for rejection was the contract did not specifically allow for costs to be incurred outside the PoP.
Contract does contain 52.216-7. I also assume that DCAA is basing the rejection on the CAM para 6-202.2 Procedure Where Term of Contract Performance Period is Explicit A contract may provide that it expires on a specified date, unless terminated before that date, and obligates the contractor to devote a specified level of effort for a stated time period [see FAR 16.306(d)(2) and FAR 52.249-6(a)]. The auditor shall not approve for reimbursement any costs incurred by the contractor subsequent to the expiration date stated in the contract, or in excess of contract limitations.
Has anyone else had a similar issue with lagging charges and how was this resolved? Assume that a modification to the contract will not be processed.