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GovCon 3rd Decade

Member Since 11 Sep 2011
Offline Last Active Jan 21 2013 07:05 PM

Posts I've Made

In Topic: Successor Contractor on SCA Covered Contract

21 January 2013 - 07:02 PM

I would agree I have never seen language saying the new contractor has to pay the rate of the old contractor if it exceeds the wage determination rate published by the DOL, however, that is a good question since they are required to bring forward the employee's accrued paid leave to pay out when the time comes. So if it was accrued at a higher rate on the first contractor's books, does he get a windfall for that?

In Topic: Does CAS apply to a large business subcontract under a small business prime?

21 January 2013 - 06:53 PM

Hi Vern - It just seems I am always hearing contractors trying to avoid CAS like it was the plague or rocket science, when personally I think is the easiest and most logical part of the whole FAR in my opinion, but I have yet to ever hear anyone say specifically what part of CAS it is that they are so desperate to escape from. Aside from having to complete a CAS Disclosure Statement, which is horrible old Government form, as they all are, it is actually much easier to fill out one of those, especially for an inexperienced contractor than it is to develop an indirect rate structure on a blank piece of paper. So, aside from the form and the fact that you are pretty much stuck with your first choice or have to complete the dreaded cost impact analysis to make a change (if you are unable to persuade them it is only an administrative change), which of CAS is it that everyone fears so much? I know contractors who purposely avoid growth to specifically to avoid the CAS threshold, which to me just seems crazy. If you can follow the rest of the FAR, CAS is easy. Maybe I have just been doing it too long, but I truthfully cannot think of a cost allocation method that would be better than any of the CAS. I would love to hear examples if anyone here actually has one to share.
I also hear about the high cost of CAS, which I don't get either. Other than having to hire or rent a cost accountant or similar to set you up and provide instructions on what to put where, which is usually good to do anyway, it is pretty logical stuff. In my opinion, without a doubt, it is much easier to be CAS-compliant than to try to avoid it and win the argument, I think is what gets complicated and expensive. My soapbox.

In Topic: Does CAS apply to a large business subcontract under a small business prime?

21 January 2013 - 01:22 PM

This won't be a popular opinion, but it seems to me if a contractor has mostly CAS-covered contracts, it would be difficult to pry one out and make it not follow CAS requirements.
Personally, I think once you are modified CAS, it is much easier to just do full-CAS since it is usually just around the corner and better to practice ahead of time than be taken by surprise as most contractors are, during audit, learning CAS via CAS violations. Which CAS are you trying so hard to avoid following? It is just cost allocation, how do you want to
allocate cost instead? I have never been able to get an answer to this question, but have never tried in this forum, and I know this forum has some die-hards like me who do not
just disappear when the questions get tough, so i am thinking this is the best place to ask.