govtacct02

Bob, Thank you for sharing your expertise and for maintaining this valuable resource that keeps things alive for other "dinosaurs" like me.. We are the grateful beneficiaries of your work and mission. Your service is commendable, as is those who engage in dialogue and offer their superior expertise on the Discussion Boards. I have been here since 1998; I have shared this resource with my colleagues and it has been an excellent training and awareness resource. It is so important that people learn the history of prior decisions, legislation, intent of the rule-makers, etc. to make fully informed decisions/conclusions on contractual matters. That would die if there was nobody keeping this alive - but you are. I hope that you continue to work this, and when you are ready to do the hand off, that there is someone as remarkable as you keeping this alive. Deeply grateful to you, Bob, and to all of the SME's that are engaged. Very Respectfully, govtacct02

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I do not understand how decrementing profit on a commercial item would be appropriate if the determination of price reasonableness was truly based on a market price. It seems to me that the buyer is conducting a cost analysis and hoping to arrive at a cost-based price for a commercial item. Please clarify!!

Also - are you performing any contracts that are subject to Full Coverage by the Cost Accounting Standards?

Are you a contractor or a government buyer? What is the G&A base for the selling or buying entity? (Total Cost Input, Value-added, single element?) We need more information to be able to help you. Also, it appears you are looking at the DCAA Contract Audit Manual. CAS 410 can be accessed at https://www.acquisition.gov/chapter_99/part-9904-cost-accounting-standards.

If you agree to a $-0-or reduced amount for indirect costs using Alt 1, you are still required to follow your disclosed or established accounting practices for allocation of indirect costs. You cannot reallocate that cost to other contracts without this restriction. So in effect are voluntarily foregoing recovery of allocable, allowable and otherwise reasonable costs.

We're having them conduct floor checks virtually. However, in this environment, not everyone they are floor checking has a camera on their computer and they've been trying to use FaceTime or similar app on a smart phone. Our employees don't like getting an unannounced video call while working from home during this situation, especially with ITC concerns. We've had some concerns about social engineering, too.

I don't know what I would do without WIFCON, either!

Thank you both.

When a foreign concern (UK; has a QMAC) is filling out the CAS Notifications and Representations and is claiming a foreign concern exemption , what is the compliant way to answer the question regarding the filing a CAS Disclosure Statement? Should they answer the question with information about their QMAC submission or leave the question blank since they do not have a CAS Disclosure Statement? Thanks!

We would have no way to provide that information to you without evaluating your particular situation...you have to go out for quotes...have you done that?

Thank you Bob. I read both side by side and the difference in the final one dated Jun 7 is that on the second page, the last sentence in the paragraph that starts "Effective immediately..." is revised as follows: "Contracting Officers shall implement this policy for all future solicitations that require a Certificate of Current Cost or Pricing Data [emphasis added] and, to the extent practicable, in currently open solicitations."

Here it is. USA000646-18-DPAP.pdf

Does anyone have a copy of the June 7, 1989 memo from Eleanor Spector entitled "Contractor Delays in Submitting Certificates of Cost or Pricing Data" that was referenced in Shay Assad's Policy memo (link posted on the WIFCON home page) ?

Yes, thank you.

Does anyone know where I can view a full copy of the CAS Working Group Interim Guidance Papers ? I had a link to a copy via DAU that was posted on this site years ago, however, that copy was missing pages at the end of WG Paper 81-25...and there is no longer a (publicly available) link on the DAU site. Thank you.

Here - Yes, you are correct, and also to respond to DOD activities that are using old guidance to make a CAS-related argument where rulemaking has not occurred. Thank you all.

I am looking for a reference I can cite that articulates when a Guidance memo/paper issued by DPAP or Defense Pricing expires. Can anyone help?

A CPFF subcontract (not construction) is being closed out (we are the sub) and we need to understand what the order of preference is : PO or subcontract document, with regard to period of performance. There is nothing in the subcontract to state order of precedence. The PO indicates the extended period of performance, and it added value to the subcontract. The subcontract was not modified when the PO was modified. Thanks.

You might want to read the Sikorsky COFC case on CAS 418 - selection of an allocation base for material handling that involved government property ($0 value on the books) was part of the debate. No. 09-844 ¶¶ 45-50; Sikorsky Aircraft Corp. v. United States, 105 Fed. Cl. 657, 674 (2012) (“Sikorsky II”)

As a follow up - my local DCMA office provided the adequacy review program, that includes conformity. If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had.

I am not a DCAA auditor. So srterral, I won't be able to take you up on your offer. Thank you anyhow. Joan - I do not see the term "conformity" in DCMA Instructions on CAS Compliance...or in Policy 120. Can you provide a more specific link? Thanks.

A few years ago, the responsibility for determining adequacy of a Contractor's CAS Disclosure Statement transitioned from DCAA to DCMA. Prior to that, when DCAA would review for adequacy, they followed a checklist of sorts to review the form part( vs. the Continuation Sheets) that contractors also found helpful. It is no longer in the DCAM, and I can't find something like it in DCMA instructions. Does anyone have an old copy of this tool that they would be willing to share? I am trying to use it for training purposes. Thanks.

This is one that is under the purview of the DCMA to review due to dollar value, so it is a DCMA analysis of a proposal.

Yes, and I also looked at the DFARs PGI 215.404-1 Proposal analysis techniques, (c )(iii). This is a cost monitor requesting we reformat the actuals into a specific cost monitor workpaper format during a proposal audit, and there are no specific instructions in the solicitation as to how to format to respond to audit questions. My thoughts are that nowadays it is not such a good idea to push back.