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MP65

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  1. We can begin drafting the report now and bill at the approved hourly rates, but because it covers activities through the end of the fiscal year - which is also the last day of the period of performance - the report cannot be finalized until after the contract has ended. The report summarizes the program's activities over the entire fiscal year and also has a financial analysis section. The COR sometimes has comments or questions to be addressed, and once we have COR approval, the report must then be formatted for 508 compliance before it is uploaded to a public domain (all requirements under the contract).
  2. Thanks very much - I may just weave some of the essence of FAR 1.102(d) into the request. Much appreciated.
  3. I have searched extensive and cannot find a definitive answer in the FAR so I am going to make my case to the CO and hope he agrees it is a reasonable request. I'll post an update here once I have an answer, for better or worse.
  4. I found an internal document from the U.S. Nuclear Regulatory Commission that states invoices for costs outside of the PoP must be approved by the CO. I am beginning to think the FAR is silent on billing outside of the PoP aside from stating that voucher must correspond to a specific billing period within the PoP (48 CFR 1552.232.70 (e) Period of Performance: "Invoices or requests for contract financing payment must clearly indicate the period of performance for which payment is requested....")
  5. Yes, the annual report is a separate deliverable and it is not priced. It was my understanding that the period of performance applied to the actual contract work and the report. It might be as simple as requesting CO approval incur the post-PoP costs associated with finalizing the deliverable, but I was wondering if others had come across this predicament. I guess we could bill and the client could deny the costs because they were incurred beyond the period of performance. Not submitting the annual report would likely find its way into our CPAR.
  6. That is a fair question. I cannot find any language in the contract that prohibits billing after the end date, but I also cannot find language that says it is allowable. The labor will be directly related to producing a deliverable that by definition cannot be finalized within the period of performance.
  7. Our T&M contract requires an annual report be submitted within 30 days after the end of the FY. The PoP also concludes with the end of the FY, and all work will be complete by the end of the PoP / FY. The client is unable to issue an NCE. Can the CO approve a request to incur labor associated with writing the annual report without it constituting an NCE? Thanks for any thoughts / similar experiences.
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