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About ry_lock

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  1. Correct. formerfed is spot on as well. Our agency's budget office said their main problem with this is DCMA approving payments with expired funding. DCMA sees NWCF and think the funds are still available for expenditure; however, the underlying appropriations' expenditure availability window has actually closed. DCMA has no way of knowing. We do; however, couple things: 1. Legal has a problem incrementally funding a R&D contract with OM/Procurement funding due to those funds' fully fund policies; 2. When it's time for the recompete, turns out the previous contract was fu
  2. I did. He came back with TPA is verified prior to coming to the KO and that the burden to ensure its following proper law rests on the divisions making the request. They don't fund contracts with different CLIN's w/ different PoPs. I believe it is the norm; however, our LOA 97x4930 isn't a true NWCF, at least not all of it. Our 97x4930 can contain true WCF (revolving or overhead no-year funds), but it can also contain funds that still have FY identity. We send out money on a contract that we receive reimbursable (not true NWCF), we cite our LOA to ensure we pay the bill. It's a b
  3. I work at a R&D Navy Working Capital Fund activity. The technical divisions rely on sponsors to provide funding. When it comes to obligating funds on contract, our org uses two types of funding: direct cite (sponsors LOA) and "reimbursable" (our DWCF LOA: 97x4930 ). Direct cite funding isn't the problem, the problem is obligating DWCF. When we use reimbursable funding, our financial system spits out the 97x4930 LOA. I had a $3M increment that contained 12 internal "job order numbers (JON)". The JONs don't show any useful info. However, lately after consulting with legal, I've requeste
  4. I began working at a Navy working capital fund agency 10 yrs ago. The way the R&D contracts were set up completely different than they are now. The contracts back then provided maximum flexibility to meet our customers requirements. Fast forward to today, most people here (new) state how multiple aspects of the old contracts were not right or legal. We are now setting up the contracts completely different and I believe is in a way an annually appropriated agency does which decreases flexibility for our R&D efforts. The more I research I conduct the more I think it was OK to do. To add
  5. No. We fall under (iii) When the use of multiple accounting classification citations is authorized for a single contract line item, establish informational subline items for each accounting classification citation in accordance with 204.7104-1(a).
  6. I think this is where Legal's concern is with a single CLIN that uses RDT&E and O&M funds.
  7. We've determined O&M money can be used to fund efforts in the SOW in support of R&D work (FMR Vol 2A, Chapter 1, Paragraph 010213). I found a great write up on this located here: http://www.strategicinstitute.org/other-transactions/appropriations-ots/. It talks about OT funding but the point they make is relevant to R&D contracts funding. My argument is if a single CLIN sites the whole SOW, which allows for R&D work that is capable of being funded with RDT&E, O&M, working capital funds, then breaking out a separate CLIN for O&M work seems pointless to me, henc
  8. It sounds like this would cause for a lot of administration. How do you know exactly how much, for example, 10,000 LOE cost? Are these fixed price contracts? If you obligate $1,000,000 for 10,000 hours and price the SLIN in this way and the contractor comes back saying they expended the 10,000 LOE but it costed them $900,000, do you move $100,000 off that SLIN? OR if they say they completed the 10,000 LOE for $1,100,000, how do you move funding onto that SLIN? Seems you better hope you have additional funding that is the same FY and color to cover the increase considering you can't have SubCLI
  9. I was trying to say that the SOW lists general, broad tasks. The general tasks allow for numerous tasks to be performed due to the fact they would all fall within scope of a task in the SOW due to its broad nature. If we further defined every possible task (to break out R&D and O&M) that could be required, there's high probability everything potential task required would be thought of. Hence why the SOW needs to be broad in nature. The tracking will be done by knowing all work that was funded via CLIN 0002: O&M Labor went to O&M work. My argument is that we can't estimate
  10. I currently work at a working capital DoD, R&D organization. Most of our funding comes from outside sponsors which comes in at a very unpredictable pace. I have CPFF R&D contracts that are funded mostly by RDT&E and Navy working capital funds. We also receive O&M funding for those contracts. We've determined O&M can be used on R&D contracts as stated in the FMR Vol 2A, Chapter 1, Paragraph 010213. The issue at hand is the CLIN structure of the contract. Some individuals in my contract’s office require if a R&D contract will use O&M funding, a separate O&
  11. One issue I can foresee is I would end up with a severable services contract with a POP that exceeds the RDTE’s period of availability. Example: Contract is 1/17-1/18 6/17 – option 1 exercised, bringing end date to 1/19. 11/17 – option 2 exercised, bringing end date to 1/20. 11/17 – obligate FY17 or 18 RDTE funds for a severable services contract with a PoP that extends until 1/20 – beyond the RDTE funds period of availability (9/19). FY19 or FY20 funds would be appropriate for work done in 1/20. I would be creating an obligation for money not yet appropriated.
  12. In R&D the work can be quite unpredictable and fairly undefined. Vendor's are not able to price the SOW's I attach to RFP's as they are very vague. In order to accommodate this, I usually attach an anticipated level-of-effort to the CPFF Term RFP so all vendors come in on the same playing field. The issue arises when we say, for example, "Agency anticipates 20,000 hours for the base year and each option for a total of 100,000 hours." Once the contract award has been made the work itself fluctuates: the level-of-effort can be accelerated or decelerated depending the way the R&D is being
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