I need to complete an interagency agreement with DCAA and think a case should be made for exempting the IA from the Economy Act. Is this unreasonable?

You should put this question to your finance office. The Economy Act governs certain kinds of transfers of appropriated funds between agencies, including cases in which the transfer is to pay for services provided by agency personnel.. It may govern this transaction. Don't ask contracting people. Ask finance people. Also, ask DCAA. They may know of some exemption or alternate authority.

Interagency Agreements are required for funds being transfered from the requesting Federal agency for work to be performed by the servicing Federal agency. OMB guidance makes this very clear. If an exemption is requested, it must follow OMB and your agency protocol. I also agree with Vern. Contact knowledgeable personnel. Not all contracting personnel are familiar with Interagency Agreements.

A reference that you may not have considered is the GAO reference known as the "Red Book" - The Principles of Federal Appropriation Law. Using it is not a replacement to requesting advice as suggested but giving it a read may help you understand the Economy Act better and might even address your question or future questions you might have about the Act. The Economy Act is addressed in Volume III, Chapter 12 of the reference.

Link to the Red Book is found here in WIFCON - http://www.wifcon.com/bonafidecontents.htm.

The Economy Act is only used when no other authority exists. I'm fairly certain there is some specific authority for DCAA to perform reimbursable work for other agencies. You can ask DCAA what that is. Or find it yourself through Google.

The Economy Act is only used when no other authority exists. I'm fairly certain there is some specific authority for DCAA to perform reimbursable work for other agencies. You can ask DCAA what that is. Or find it yourself through Google.

I recommend you read FAR 42.002 and Subpart 42.1. Also, it's interesting to note that DFARS 242.002((i) says:

"DoD requires reimbursement, at a rate set by the Under Secretary of Defense (Comptroller/Chief Financial Officer), from non-DoD organizations, except for?

(A) Quality assurance, contract administration, and audit services provided under a no-charge reciprocal agreement;

( . . .; and

(C ) . . .

(ii) Departments and agencies may request an exception from the reimbursement policy in paragraph ((i) of this section from the Under Secretary of Defense (Comptroller/Chief Financial Officer). A request must show that an exception is in the best interest of the Government." [emphasis added.]

It's possible your agency already has an agreement with DCAA. Asking DCAA is a good idea.