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Everything posted by govtacct02

  1. Just curious - what do other contractors do when you are supporting an audit of a TINA-covered proposal and the auditor says you have to transmit actuals to them in their format, vs. the contractor's format, where there were no specific instructions in the solicitation to submit in a Government or Prime contractor specific format?
  2. Are you intending on claiming the executives' salaries in allocations to Government contracts/subcontracts?
  3. Appreciate everyone's input. Here are some answers: Can’t tell if the change you reference is with regard to a proposal on a not yet awarded contract or an existing contract. This is an existing contract. Are you asking because the FAR Part 15 reference is directed toward issues of certified cost or pricing data? Yes. Question is regarding disclosure requirements when financing is only element changed. Base contract was competitively awarded. Is the CO directing the change to the financing or is the contractor simply requesting for some reason? Contractor is requesting it. You have not identified the contract financing that is being changed and to what. Different financing or none at all? It would involve acceleration to payment schedule. If a current contract what stage, in general terms, is the contract in currently? It is a few months into a 4 year period of performance. Knowing a little more about the above may help with a more specific response but quick thought is if the reference to FAR Part 15 is not connected to matters of cost or pricing data then I would submit yes it porbably is an art specific to the contract at had in that it is a proposal to change the contract and that adequate information specific to the contract would be shared to evaluate the consideration be contemplated. That is what my initial thoughts were. But would like some feedback, understanding that it is not Legal Advice.
  4. Has anyone had experience with a having to determine 'adequate consideration' under FAR 32.005, when the change involved only a change in non-commercial item contract financing terms? (Presume no other changes are being made.) As I read FAR 32, it seems like determining adequate consideration is somewhat of an art. Would the contractor have to provide a FAR-15 compliant proposal in order for the CO to determine whether the consideration was "adequate"? Thanks.
  5. Happy Belated Birthday Bob! Thank you for all you do to provide this valuable resource ! Hope it was a good day!
  6. SpartanHead, I would add to the previous comments that since you are new to your company, you could benefit from an appointment with your Government Accounting department. They can explain the cost structure, the burdening sequence, and alert you with any other items that are pertinent to your position there. I always make a point to spend time with new people and provide them with all the tools they need to be compliant!
  7. The question I have is: As a contractor, can the SOFARS solicitation provision 5652.215-9011 compel me to submit a DD Form 1547 "Record of Weighted Guidelines Method Application" with my proposal to the buying command? I am having trouble reconciling this with the prohibition in FAR 15.404-(c )(5) from obtaining breakouts or supporting rationale for [a prospective contractor's] profit or fee objective. Thank you. An editable SOFARS provision reads as follows: 5652.215-9011 Proposed Profit/Fee (2005) Section L As prescribed in 5615.408®, insert the following provision, Editable Offerors are encouraged to submit a completed DD Form 1547 "Record of Weighted Guidelines Method Application" to support the proposed profit in accordance with DFARS 215.404-71. The DD Form 1547 and supporting documentation are/are not required. If submitted, the DD Form 1547 and supporting documentation shall be included in the cost volume of the proposal. The solicitation we received highlights "are required". 15.404-4 -- Profit stipulates: (c )Contracting officer responsibilities. (5)The contracting officer shall not require any prospective contractor to submit breakouts or supporting rationale for its profit or fee objective but may consider it, if it is submitted voluntarily.
  8. Fitz and the Tantrums - a little poppy but catchy - sounds a bit like a cross between Hall & Oates, classic Motown, and The Style Council. Anything by Pat Metheny Flamenco guitar (Ottmar Liebert, Strunz & Farah, Jesse Cook,et al), bossa nova (Getz/Jobim/Gilberto), or afro-cuban (Buena Vista Social club, et al)
  9. My company has foreign affiliates (Poland) that will have to have training on FAR Cost Principles. Is anyone aware of a resource (besides a foreign based branch of a U.S. consulting/audit firm to obtain the FAR in Polish?
  10. Please see the Wifcon Thread at the URL below. This should help. http://www.wifcon.com/arc/forum410.htm In this thread, Vern said: "The T&M payment clause, FAR ? 52.232-7, paragraph (a), is very clear that if the contractor devoted a direct labor hour to the performance of the contract work, then it is entitled to payment at the hourly rate stipulated in the contract schedule. The clause does not condition payment on what the contractor paid or did not pay the employee who did the work. Under a T&M contract, payment for labor is not based upon incurred cost."
  11. Please see the DOL website for FAQ's about the SCA applicability. http://www.dol.gov/whd/regs/compliance/web/SCA_FAQ.htm
  12. Edit: If they want to pay for advertising, they know how. Bob Antonio
  13. 10 U.S.C. 2306( d ) and 41 U.S.C. 254( B ) impose statutory limitations of 15% for fee on experimental, developmental, or research work performed under a cost-plus-fixed-fee contract. I work for a government contractor, and have been asked whether a CPFF supplies and services contract that includes development activities must be funded with RDT&E funds (for the development activities) to permit proposing fee in excess of 10% on those development activities. Thanks for your help.
  14. Bob, I don't know what I would do without WIFCON. I visit your site several times a day. You've put a tremendous amount of work and meticulous care into this site, and it is an excellent, excellent resource. It is on my list of "must use' websites. I advertise it to my coworkers and fellow industry association members as often as I can. I'll echo the other members who say WIFCON has contributed substantially to my understanding of so many contracting issues. And I will pray for your health, too! Thanks Bob.
  15. On September 14, 2010, Dr. Ashton Carter, Under Secretary of Defense for Acquisition, Technology and Logistics, issued a memorandum on the subject of Better Buying Power for the Department. In that memorandum, the Director of Defense Procurement and Acquisition Policy was directed to develop a cash flow model to be used by all contracting officers contemplating financing other than customary progress payments, such as Performance Based Payments (PBP). In addition, guidance was to be developed that ensures that the improved cash flow opportunities provide benefit to both industry (at both the prime and subcontractor level) and the taxpayer. The tool is at this website: http://www.acq.osd.mil/dpap/cpf/Performanc...d_payments.html Has anyone had any experience using this tool, or any thoughts about differences in profit % to expect as a result of using the tool? Thanks.
  16. Can anyone tell me what the alpha code in a DCAA audit report number that follows the fiscal year represents? I can't find it in the DCAM. For Example: 1234-2011A2700001 I know what all the other parts of the audit report nubmer represent, such as FAO and activity code. Thanks.
  17. Do you perhaps mean "CAGE" instead of CASE - as in Commercial and Government Entity (CAGE) Code?
  18. The absolute value of the mod exceeds the threshold for submission of cost or pricing data, and no exception applies, so the cost or pricing data must be certified. The problem is that the technical change to delete the work was agreed years ago. I am told that the statement of Work was changed and the contract was modified but the Estimated Cost was not reduced. The giveback proposal for the deleted work is being done only now.
  19. Can anyone explain how the "would have cost" rule would work in the context of a deletion in scope in a CPFF contract that occurred 2 years ago, and a technical modification of the contract was agreed to then (customer worked with engineers who did estimates of the change, but provided no cost or pricing data), but the proposal deleting the dollars is not being prepared until 2011? There were no actuals, and the work deleted is not severable. Do we have to get cost or pricing data updated as of 2011? Does the language in FAR table 15.2 referring to deleted work that says "(2) Include the current estimates of what the cost would have been to complete the deleted work not yet performed (not the original proposal estimates), and the cost of deleted work already performed." mean current estimates as of the date when the mod occurred, or as of 2011? Thank you.
  20. As a contractor, I've been involved in negotiations with certain DOD Agencies that shared their spreadsheets with us.
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