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GovCon 3rd Decade

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Everything posted by GovCon 3rd Decade

  1. There are many on LinkedIn, which is where all my clients have found me, but I would assume there might be many on this site as well.
  2. 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?
  3. 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.
  4. 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.
  5. Joel - Thanks for the laugh. All - If you have not been to dcaa.mil lately, there is a new version of the ICE Adequacy checklist dated Nov. 2011, now 7 vs. 3 pages, but same stuff. I have also never had DCMA disagree with DCAA's decision on ICE or anything. I agree best bet is submitting ICE file with schedules in order, but I add several things to the ICE models that I do.
  6. Thanks for the help, love your handle too. No worries on the ICE format, I have been doing these since the Lotus days long before ICE and make many adjustments to accommodate reality and my personal preference and have passed audits every time, I think it is substance over form, especially when the form does not accommodate the scenario. Things that bug me on ICE are not having pool, base and rate on same schedule (B/C) so mine do. Not showing rates on on costs by contract schedule (H) so I add onto mine and schedule (I) A/R does not split over/under billed between cost and fee, so I split but also show total. Add but don't delete.
  7. Thank you for sticking with me on this. I hope you can see why I was struggling and how ultimately you have to break one rule to comply with another and the DCAA ICE evidently does not consider this scenario, which is not that unusual. Also wanted to say I love your logo!
  8. Hi Joel - I did not want to not answer you, but I think you saw answer in later post, yes? What is DB=DataBase to me. Cheers! Teri
  9. Ok, so not in G&A BASE...then #4 of #4 Last question was... Do those Unburdened B&P ODC's get included in B&P/G&A Pool (per DCAA ICE format) for allocation on G&A base? Do you see why I am asking this now?
  10. Thank you for the follow-up, halfway there...Clear on A but not on B... A1) I do understand B&P/IR&D are just allocated on the same basis, just said that way to keep it short. A2) Thanks, I can do that. I will just override formulas in DCAA ICE Model. Won't be the first time to do. B2) Same answer as A1. No problem. I agree. But am saying again to be clear and to match DCAA ICE. B1) Not clear. ODC's are only burdened with G&A. So they either go in G&A/B&P POOL(s) or BASE?
  11. Hi Vern - You have an excellent memory and yes it is the exact same question. I have a new client with the same issue and I still don't seem to be able to get a a complete answer. I totally appreciate those who have started an answer but no one seems to be able to get through the end. It seems that suddenly the concept of POOL vs. BASE evaporates. Maybe it is too long and I need to split into two and start in middle. A) So...Value-added G&A Base with M&S Pool, B&P Material is burdened with M&S... 1) Does the BP Material and its M&S Burden get added to the G&A POOL? 2) Does the remaining portion of the M&S Burden stay in the G&A BASE? Same Value-added G&A Base with M&S Pool, B&P ODC's belong in 1) G&A BASE with other ODC's? OR 2) G&A POOL with other B&P costs?
  12. When you have a Value-added G&A base because you have an M&S Pool to burden Materials and of course the B&P Labor with OH goes into the G&A pool to be allocated, does the M&S on the B&P Material also go into the G&A Pool? Then leave the remainder of the M&S burden in the G&A base with the other Overhead?
  13. Joel - No problem, mine crashed so I don't see what I typed posted anywhere now. I understand any proposal uses estimated rates, no problem there, but it appears it would not matter what rates might be estimated since they cannot be recovered in billing since it appears there can be no escalation of direct or indirect costs proposed or billed, except for SCA wage or H&W rate increases which can only be burdened with payroll tax and workers comp on the increased base. No more OH, G&A or Fee on increased portions. No offense taken, I agree 100%, any contractor should understand the contract they are proposing on. I would never sign a contract I did not fully understand, but I was not there 3 years ago or even three months ago. I am an independent consultant hired to work on 2010 YE close in place of a terminated Controller. I am not doing proposals or billing, I am just trying to understand large losses on this contract for multiple years by looking at proposals and 52.222-43. Looking to confirm my understanding of how this should be done compared to what has been done and is still being done. (Also need to setup rates for 2011 and 2012, so that in mind as well). Was hoping someone might be able to fill in the piece I might be missing or share how they make this work to at least break-even or minimize loss since I just can't believe this is the intention. (Client did not even know there was a loss on prior years till I noted). Part 2 is not really a "sub", think consultant helping (prime) client with proposals whose costs are booked as G&A expense to client, indirect expense. Just ironic Govt thinks contractor does not incur/cannot bill G&A expense to process SCA increase proposals. Sorry to torture you with this.
  14. Where can I find the rules to watch out for when I have an employee who normally works as Corp G&A performing Direct labor? He is fully qualified and there is no issue with labor categories or pay rate but he will physically be working on base vs. Corp office. I understand I want to have his Fringe follow his labor and occupancy if both spaces are not kept open and available to him to use. (in other words, I understand if someone else is sitting in one of his spots while he is in the other, occupancy allocates to the user). This is a temporary assignment to fill in for the regular person who will be away for multiple weeks at a time and more than once, but not a permanent change since this ee will ultimately return to his full-time Corp G&A position. Are there issues to be aware of?
  15. Great site Bob! You have some sharp people on here discussing some complex issues, where I thought there was no forum in existence. I do not usually like to be viewed as an anonymous user, but think that may be best to keep my client specifics private for them.

  16. Sorry, I see it was Joel who restated my first item exactly correct here, but Vern was very much on the right track as well.
  17. Hello Vern and Joel - Thank you so much for responding and sorry for my delayed return, just been swamped with work. I actually typed a lengthy reply to Vern last night but must have done something wrong since I do not see it here(rookie). Also sorry to put so many pieces in one question. Setting aside the Billing since it is FP and cost allocation since internal, the new territory for me is the proposal side and Vern has the first item exactly right, but I caused confusion on part two. 1) Assuming my interpretation of 52.222-43 is correct, SCA wage rates must be proposed at current hourly WD and H&W rates, and this clause allows for increases when DOL increases these rates, so even though a proposal is done for 3 years there is no escalation of the WD or H&W rates, since it is understood there will be increases in these rates on DOL timing. So at best you have fully burdened and applied Fee to the first set of WD & H&W amounts, then for all future options only the WD & HW rates increase, but not the burdens or fee, when of course in reality you incur OH & G&A in years 2 & 3 too, SO YOU JUST DON"T GET THOSE DOLLARS? Or is it expected that you fabricate Year 1 burden or fee to cover years 2&3? That just seems wrong...which leads to my second issue, which is mostly a comment of disbelief, to confirm I understand. 2) I read that the reason there is no G&A (or OH) allowed is because there is no work required on the part of the contractor to manage these rate increases to SCA WD and H&W, which I totally disagree with the logic on that thinking because... I am a consultant assisting the prime contractor (missing Controller) and I have a subcontractor (another consultant) who has been creating these huge proposals showing, in the latest case, a 9 cent increase on H&W rates, for dozens of employees with multiple labor categories, WD rates, the old & new H&W = difference plus FICA and WC applied for the EE's in various locations CONUS/OCONUS multipled by hours for the straight time, OT, DT, Hazard and hardship rates. So there is very clearly G&A expense related to this exercise. The company had to hire a person just to do these updates, so what is the logic of no G&A? Since the person doing these was hired specifically to do this, the cost very clearly exists and is just even more obvious than if a normal employee was performing this task during their normal G&A work day. Hope this makes sense and I look forward to whatever portions of this you can confirm and/or explain the logic I'm missing. Thank you!
  18. To dcfan - I agree with what you found, that this decision is made by the employer, to pay you cash or provide the required benefits, but that is not to say it cannot be changed. One of my clients is currently reviewing their current choice and considering the options. So, to the extent your employer wants to keep employees happy, it might be worth mentioning your preference in a suggestion box. I think, but won't swear to it, that the disadvantage to paying cash is that the company incurs additional payroll tax on the amounts, aside from that, I think paying cash is much easier for employers than providing benefits but then employees are not covered either. I am no expert on SCA, and yours may differ, but above is my understanding from having done alot of reading up on this recently.
  19. Hi All - I am new to this forum, although not new to the industry (3rd decade), but my experience is with CPFF, T&M then FP, in that order, leaving me light on the end broad category and the combo of FP with SCA. I should also mention my expertise is on the accounting/compliance side vs. contracts/proposals, etc. but after 25 years as GovCon ee, now last 5 as consultant so trying to broaden my view of the whole enchilada. I saw discussion in 2002 with Vern and see he is still here, and was hoping he or anyone ese who has been down this path might shed some light on how best to navigate this one without losing your shirt & shorts. FAR 52.222-43 seems clear on FP contracts there can be no OH, G&A or Fee applied to SCA WD & H&W increases in option years = automatic loss (non-recoverable costs) assuming you allocate those to all contracts. Hindsight seems to say if you know this going in, you would have to increase initial burden or fee to cover those future option year burden increases, since despite Govt opinion there is no load on SCA rate increases, my client is currently paying my subcontractor healthy sums of G&A to prepare these SCA cost increase proposals for 9 cent increase on H&W that will add up, but may be 100% G&A actual vs. 4% normally applied. As accountant, used to fully allocating OH & G&A (Fringe too, but that is another can of worms). Do I assume these costs must be included in base, and then just not billable? I undersatdn FP not billed on cost, but still like to compare cost to billing internally to monitor profitability. Or are we supposed to exclude some portion of these costs since burdens are allowed on initial proposal, but just not on the increases, so messy. Up until this issue, I have always been able to follow the FAR logic, like it or not, but this seems like contradictory direction to me with regard to allocating indirect costsand I am finding no good guidance on issues. I saw some protests, but none quite same (other issues like SCA/CBA rates, etc.). Am I understanding this correctly? Is it really this messed up? How do other contractors do this or why do they want this work?
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