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CPFF - billing labor category not originally in proposal

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Hello!

Contractor here, with a CPFF contract for a research effort. Our original cost proposal included a slew of labor categories for (I believe) cost analysis purposes. Our final contract doesn't specify anything about LOE, or approved labor categories. We have a new individual working on this effort (COTR is aware), but he would fall into a different labor category than what was on the original proposal. From my perspective, the labor category name is a moot point as we aren't locked into any specific approved rates via a labor category.

Do we need to provide any sort of notification, or new proposal activity? As it is a cost type, and not T&M I can't find a requirement in writing anywhere. If this does require some sort of approval, what guidance specifies that?

Thank you.

If the contract does not require you to provide notification then you do not have to. 

It's a best practice (but not overwise a rule or regulation) for the government to include a requirement to ask for CO approval of LCATs which weren't part of a vendor's original proposal.  I assume you looked in your contract for such language?  

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