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Everything posted by here_2_help

  1. whynot, I'm having trouble parsing your language. But let me take a crack at an answer anyway. The answer to your question likely depends on the nature of the "pre-award audit". If the audit is in the nature of fact-finding, i.e., reviewing the support for the prime contractor's proposed costs, then I think the answer is "no, the contractor cannot be compelled to supply the requested supporting data." The natural result of failure to support proposed costs will be a large amount of questioned costs, which likely will affect the contracting officer's negotiating position. In other words, contractors who cannot or will not support proposed costs, should not expect to negotiate a price that includes the unsupported costs. If what is being negotiated is a commercial item as per FAR 2.101, then my answer above would be different. If the pre-award audit is a pre-award accounting system survey to see if the contractor can administratively support a contract award, again I think the answer is "no, the contractor cannot be compelled to support the audit with personnel or with documents." In this situation, however, I would expect the result of this failure to result in the contractor being determined not to be responsible and it likely will not receive the award. Hope this helps.
  2. Orion, 1. Do you have a contract with the entity being terminated? If so, what does it say about payment? If not, how do you (and the terminated entity) establish that you are an independent contractor? 2. Does your contract contain flow-down and other clauses that establish you to be a subcontractor? If not, why do you think you qualify for treatment as a subcontractor? Could you not simply be a management consultant? 3. If the terminated entity has included your costs in its Termination Settlement Proposal (TSP) then I believe it needs to pay you in the "ordinary course of business". That term is defined inconsistently among the various FAR payment clauses and, frankly, I'm not 100% clear on how it operates in a T4C environment. But the most common definition I can find is a) in accordance with the terms of your consulting contract, and/or within 30 days of submitting a request for payment to the Government. (Paraphrasing significantly here.) Where does your situation stand vis-a-vis the FAR definition of "ordinary course of business"? 4. In my view, your best course of action lies with an attorney. Depending on your answer to #1, above, you may want to consult with an employment attorney. Appealing to the TCO is not going to avail you much of anything, in my opinion. But good luck! H2H
  3. trplyr, I'm a bit hesitant to answer your question directly, because I feel that I'm missing some aspects of the situation. For example, you say "The buyer had no pricing history ..." but you don't say whether the seller could have provided information other than cost or pricing data -- e..g, prices at which it had sold this item in comparable quantities and similar terms & conditions. You say "the actual manufacturer ... did not want to be bothered with govn't source inspection" but you don't address whether the item might have (or actually did) qualify as a Part 12 acquisition (commercial item). I am pretty clear that (a) if this was a negotiated procurement and not an acquisition of a commercial item or a sealed bid, and ( if the government used cost analysis, then yes, during negotiations the government should deduct the value of the contractor's proposed unallowable cost (e.g., unallowable interest expense) when establishing the price that the government will pay. But this scenario reeks of a commercial manufacturer using a commercial distributor. Let me ask you this: if the manufacturer won't permit government source inspection, and its distributor cannot read the FAR well enough to know that it should not propose interest expense when justifying its proposed price, what makes you think that these two entities are going to be able to comply with any other contract term? (I'm thinking Buy American Act, Trade Agreements Act, Specialty Metals restrictions, etc.) Are you sure that they are presently responsible, including financially viable? Are you sure that Section K was accurately executed -- i.e., does this team even understand what they are executing? I don't mean to make a "federal case" out of this. But something (actually more than one something) is raising the hairs on the back of my neck and setting off my mental alarm bells. Do you think you might discuss this with your supervisor? Don't mean to get you all freaked-out, hope this helps.
  4. Of course it does, trplyr, in many (but not all) situations. "The cost principles are applicable to the pricing of contracts, subcontracts, and modifications whenever cost analysis is performed. ... The cost principles apply to the determination, negotiation, or allowance of costs whenever required by a contract clause." (Government Contract Costs & Pricing, 1st Ed., Karen Manos, author) See FAR 31.102. Hope this helps.
  5. Hi trplyr, I don't think you are looking at this in the right way. If you'll permit me, the price reduction flows from a change in the proposed profit, and should not be related to any change in proposed costs. Look at it this way, if a contractor has to finance contract costs over a significant period, it probably incurs interest, which is an unallowable cost. Unallowable costs reduce the contractor's profit. So if it has to cover the unallowable cost, it needs to receive more profit. If you eliminate the contractor's need to incur the unallowable interest cost, in a competitive situation the logical outcome should be that it will propose a lower profit amount, which will reduce its proposed price to the government. Hope this helps.
  6. Don, seriously, please re-read my post responding to your post. Your post said "If I'm a savvy contractor who knows these rules and wants to make money on a fixed-price contract where price was going to be a dominant factor in choosing who gets the award (and I anticipated a lot of change orders), wouldn't it make sense to offer a price as low as I could possibly stand (even below cost) in hopes that I could win the award and make up for any losses through equitable adjustments?" Your plain language indicates that you expect your "savvy contractor" to buy-in with the intention of getting well ["make up for any losses"] through equitable adjustments. That is exactly the practice the FAR terms an improper business practice. And if you will take a moment and re-read my post, you will see my position is clearly stated: "I have no problem with the initial buy-in. It's the getting well through fraudulently priced change orders or inflated bids for follow-on contracts that cause my problem." When a contractor submits change orders priced to not only cover the costs of performing the changed work, but also to cover losses it would otherwise incur from its initial decision to buy-in, that's what creates the fraud part, or so a prosecutor might well allege. My feeling was, and still is, that your original post quoted above was misleading. At a minimum, you failed to address the issue through citation to the appropriate FAR language. I remedied that omission through my honed "cut-n-paste" skillz. Now you might have posted hastily with some ill-chosen phrasing, and consequently perhaps we are on the same page after all. But I felt the need to point out to others, perhaps newbies at the whole "government contracting" thing, that buying-in with the intention of getting well through change orders is officially frowned-upon, and contracting officers need to be vigilant about detecting and reporting such improper practices. Hope this helps to clarify.
  7. Don, I have a problem with your "savvy" contractor's strategy, and let me explain why. It's a little thing we call the Federal Acquisition Regulation or FAR. It's got this little piece at 3.501 that discusses "buying-in" and requires a contracting officer to "take appropriate action to ensure that buying-in losses are not recovered by the contractor through the pricing of (1) change orders; or (2) follow-on contracts subject to cost analysis." I have no problem with the initial buy-in. It's the getting well through fraudulently priced change orders or inflated bids for follow-on contracts that cause my problem. I would hope that your "savvy" contractor can afford a good legal defense team. Hope this helps.
  8. formerfed: sometimes a contractor is not allowed to blend rates. For example: ========== 252.216-7002 Alternate A, Time-and-Materials/Labor-Hour Proposal Requirements ? Non-Commercial Item Acquisition with Adequate Price Competition. As prescribed in 216.601(e), substitute the following paragraph © for paragraph © of the provision at FAR 52.216-29: ALTERNATE A, TIME-AND-MATERIALS/LABOR-HOUR PROPOSAL REQUIREMENTS ? NON-COMMERCIAL ITEM ACQUISITION WITH ADEQUATE PRICE COMPETITION (FEB 2007) © The offeror must establish fixed hourly rates using separate rates for each category of labor to be performed by each subcontractor and for each category of labor to be performed by the offeror, and for each category of labor to be transferred between divisions, subsidiaries, or affiliates of the offeror under a common control. ========== Hope this helps.
  9. From a risk management standpoint, every supplier should be evaluated for its potential to deliver nonconforming goods/services. The impacts to the program/contract should be assessed, and appropriate mitigation plans should be put into place. In some situations, it may make sense to make two or more awards, in case the apparent winning bidder doesn't perform as promised. Especially if the risk assessment shows a relatively high probability of failure coupled with a relatively significant programmatic impact. Not sure if the Government folks can do this at their level, but I'm darned sure that the primes can do it -- and should. But they don't, or at least they don't do it often enough. I remember one program review I attended. For want of a properly drilled hole in a piece of titanium (work valued below the SAT), a launch date was missed, along with schedule-related milestone bonus payments and lots and lots of award fee. Nobody ever asked whether the low bidder was capable of actually drilling a proper hole in the titanium in this instance because, after all, that was the business the supplier was in and they had done it lots of times before. (NB: The supplier's senior prototype machinist retired a couple of months before the work was awarded....) In another instance, a tiny part fabrication P.O. put a $150,000,000 program in jeopardy and cost millions in lost award fees. Somebody could have awarded ten duplicate fab P.O.'s, received 10 parts, thrown 9 of them away, and that would have made really good business sense. I could go on. Hope this helps.
  10. Hi wayforward, The term "primary subcontractor" is a new one to me. I checked FAR 2.101 (definitions) and the definitions section of FAR Part 44, and I didn't find it. Where did you encounter it? If, as I suspect, it is not a formal term of U.S. Gov't. procurement, then why would you think there would be any conditions associated with it? Specifically, where did you get the notion that the percentage of work performed affected whether your company could be a "primary subcontractor" or no? Let me be a bit pedantic for a minute. I apologize in advance if I've misread your situation. If you don't see a solicitation clause in your RFP (or "tender" if you prefer) that discusses a particular term, or if you don't see a FAR or FAR supplement clause in the regulations that discusses a term, then that term is very likely not relevant to your company's bid. You probably want to review the clauses that are in the solicitation and also understand what representations and certifications you are signing in Section K of your proposal. You probably want to review FAR and FAR supplement clauses that you expect to be in your contract (if awarded). You will want to make sure that your company understands each clause and each rep/cert, because the clauses become performance promises after award -- i.e., non-compliance with a clause could be construed as a contract breach or have other serious repercussions. Reps/certs that are intentionally or even negligently inaccurately executed could taint the contract award, and may lead to litigation. With respect to your question on whether to bid blended rates or individual rates for each affiliated entity, a review of the applicable T&M payment clause will very likely lead you to the right answer. You may also want to consider the "Excessive Pass-Through" clause found in the DFARS, if your Government customer will be the Department of Defense. Here's some additional advice: If you don't feel comfortable interpreting the various clauses, and don't have a clear idea how your company will develop a strategy to comply with those clauses, then you will want to get some expert assistance. Yes, hiring an experienced Government contract attorney, or professional consultant, will be expensive. Yes, implementing compliant practices may involve burdensome impacts to existing business processes. No, hiring such experts and developing compliant practices will not be more expensive than failing to comply with solicitation requirements, or applicable contract requirements after award. Hope this helps.
  11. George, the costs may be allowable per 31.205-13. Activities intended to promote employee health, morale, productivity, or welfare -- such as safety meetings -- may be allowable. Not sure whether a BBQ meets the reasonableness test, though. civ_1102, cost allowability does not turn on cost allocability. Costs are allowable, or not, based on FAR cost principles and contract terms. Whether they are charged directly or indirectly does not normally enter into the determination. Hope this helps.
  12. My question is how the noncompetitive award of the additional task to the subcontractor was justified, and how price reasonableness was determined. Especially after the subcontractor had physically completed the original SOW.
  13. I disagree with that generalization. Rather, I would say that prime contractors typically pay subcontractors in accordance with the payment terms of the subcontract, else in the normal course of business (in line with payments to other vendors/suppliers). Prime contractors that make a habit of paying subcontractors only after they have received payment from the Government, will find (over time) that they are no longer the preferred customer of choice, and may see their supply base dwindle.
  14. The clause 52.216-7 is mandatory for certain contract types, including cost-reimbursement types. See the language at ((1)(ii), below. 52.216-7 Allowable Cost and Payment. As prescribed in 16.307(a), insert the following clause: Allowable Cost and Payment (Dec 2002) (a) Invoicing. (1) The Government will make payments to the Contractor when requested as work progresses, but (except for small business concerns) not more often than once every 2 weeks, in amounts determined to be allowable by the Contracting Officer in accordance with Federal Acquisition Regulation (FAR) Subpart 31.2 in effect on the date of this contract and the terms of this contract. The Contractor may submit to an authorized representative of the Contracting Officer, in such form and reasonable detail as the representative may require, an invoice or voucher supported by a statement of the claimed allowable cost for performing this contract. (2) Contract financing payments are not subject to the interest penalty provisions of the Prompt Payment Act. Interim payments made prior to the final payment under the contract are contract financing payments, except interim payments if this contract contains Alternate I to the clause at 52.232-25. (3) The designated payment office will make interim payments for contract financing on the _________ [Contracting Officer insert day as prescribed by agency head; if not prescribed, insert "30th"] day after the designated billing office receives a proper payment request. In the event that the Government requires an audit or other review of a specific payment request to ensure compliance with the terms and conditions of the contract, the designated payment office is not compelled to make payment by the specified due date. ( Reimbursing costs. (1) For the purpose of reimbursing allowable costs (except as provided in paragraph ((2) of this clause, with respect to pension, deferred profit sharing, and employee stock ownership plan contributions), the term ?costs? includes only? (i) Those recorded costs that, at the time of the request for reimbursement, the Contractor has paid by cash, check, or other form of actual payment for items or services purchased directly for the contract; (ii) When the Contractor is not delinquent in paying costs of contract performance in the ordinary course of business, costs incurred, but not necessarily paid, for? (A) Supplies and services purchased directly for the contract and associated financing payments to subcontractors, provided payments determined due will be made? (1) In accordance with the terms and conditions of a subcontract or invoice; and (2) Ordinarily within 30 days of the submission of the Contractor?s payment request to the Government; ( Materials issued from the Contractor?s inventory and placed in the production process for use on the contract; © Direct labor; (D) Direct travel; (E) Other direct in-house costs; and (F) Properly allocable and allowable indirect costs, as shown in the records maintained by the Contractor for purposes of obtaining reimbursement under Government contracts; and (iii) The amount of financing payments that have been paid by cash, check, or other forms of payment to subcontractors. (2) Accrued costs of Contractor contributions under employee pension plans shall be excluded until actually paid unless? (i) The Contractor?s practice is to make contributions to the retirement fund quarterly or more frequently; and (ii) The contribution does not remain unpaid 30 days after the end of the applicable quarter or shorter payment period (any contribution remaining unpaid shall be excluded from the Contractor?s indirect costs for payment purposes). (3) Notwithstanding the audit and adjustment of invoices or vouchers under paragraph (g) of this clause, allowable indirect costs under this contract shall be obtained by applying indirect cost rates established in accordance with paragraph (d) of this clause. (4) Any statements in specifications or other documents incorporated in this contract by reference designating performance of services or furnishing of materials at the Contractor?s expense or at no cost to the Government shall be disregarded for purposes of cost-reimbursement under this clause. © Small business concerns. A small business concern may receive more frequent payments than every 2 weeks. (d) Final indirect cost rates. (1) Final annual indirect cost rates and the appropriate bases shall be established in accordance with Subpart 42.7 of the Federal Acquisition Regulation (FAR) in effect for the period covered by the indirect cost rate proposal. (2)(i) The Contractor shall submit an adequate final indirect cost rate proposal to the Contracting Officer (or cognizant Federal agency official) and auditor within the 6-month period following the expiration of each of its fiscal years. Reasonable extensions, for exceptional circumstances only, may be requested in writing by the Contractor and granted in writing by the Contracting Officer. The Contractor shall support its proposal with adequate supporting data. (ii) The proposed rates shall be based on the Contractor?s actual cost experience for that period. The appropriate Government representative and the Contractor shall establish the final indirect cost rates as promptly as practical after receipt of the Contractor?s proposal. (3) The Contractor and the appropriate Government representative shall execute a written understanding setting forth the final indirect cost rates. The understanding shall specify (i) the agreed-upon final annual indirect cost rates, (ii) the bases to which the rates apply, (iii) the periods for which the rates apply, (iv) any specific indirect cost items treated as direct costs in the settlement, and (v) the affected contract and/or subcontract, identifying any with advance agreements or special terms and the applicable rates. The understanding shall not change any monetary ceiling, contract obligation, or specific cost allowance or disallowance provided for in this contract. The understanding is incorporated into this contract upon execution. (4) Failure by the parties to agree on a final annual indirect cost rate shall be a dispute within the meaning of the Disputes clause. (5) Within 120 days (or longer period if approved in writing by the Contracting Officer) after settlement of the final annual indirect cost rates for all years of a physically complete contract, the Contractor shall submit a completion invoice or voucher to reflect the settled amounts and rates. (6)(i) If the Contractor fails to submit a completion invoice or voucher within the time specified in paragraph (d)(5) of this clause, the Contracting Officer may? (A) Determine the amounts due to the Contractor under the contract; and ( Record this determination in a unilateral modification to the contract. (ii) This determination constitutes the final decision of the Contracting Officer in accordance with the Disputes clause. (e) Billing rates. Until final annual indirect cost rates are established for any period, the Government shall reimburse the Contractor at billing rates established by the Contracting Officer or by an authorized representative (the cognizant auditor), subject to adjustment when the final rates are established. These billing rates? (1) Shall be the anticipated final rates; and (2) May be prospectively or retroactively revised by mutual agreement, at either party?s request, to prevent substantial overpayment or underpayment. (f) Quick-closeout procedures. Quick-closeout procedures are applicable when the conditions in FAR 42.708(a) are satisfied. (g) Audit. At any time or times before final payment, the Contracting Officer may have the Contractor?s invoices or vouchers and statements of cost audited. Any payment may be? (1) Reduced by amounts found by the Contracting Officer not to constitute allowable costs; or (2) Adjusted for prior overpayments or underpayments. (h) Final payment. (1) Upon approval of a completion invoice or voucher submitted by the Contractor in accordance with paragraph (d)(5) of this clause, and upon the Contractor?s compliance with all terms of this contract, the Government shall promptly pay any balance of allowable costs and that part of the fee (if any) not previously paid. (2) The Contractor shall pay to the Government any refunds, rebates, credits, or other amounts (including interest, if any) accruing to or received by the Contractor or any assignee under this contract, to the extent that those amounts are properly allocable to costs for which the Contractor has been reimbursed by the Government. Reasonable expenses incurred by the Contractor for securing refunds, rebates, credits, or other amounts shall be allowable costs if approved by the Contracting Officer. Before final payment under this contract, the Contractor and each assignee whose assignment is in effect at the time of final payment shall execute and deliver? (i) An assignment to the Government, in form and substance satisfactory to the Contracting Officer, of refunds, rebates, credits, or other amounts (including interest, if any) properly allocable to costs for which the Contractor has been reimbursed by the Government under this contract; and (ii) A release discharging the Government, its officers, agents, and employees from all liabilities, obligations, and claims arising out of or under this contract, except? (A) Specified claims stated in exact amounts, or in estimated amounts when the exact amounts are not known; ( Claims (including reasonable incidental expenses) based upon liabilities of the Contractor to third parties arising out of the performance of this contract; provided, that the claims are not known to the Contractor on the date of the execution of the release, and that the Contractor gives notice of the claims in writing to the Contracting Officer within 6 years following the release date or notice of final payment date, whichever is earlier; and © Claims for reimbursement of costs, including reasonable incidental expenses, incurred by the Contractor under the patent clauses of this contract, excluding, however, any expenses arising from the Contractor?s indemnification of the Government against patent liability. (End of clause)
  15. I'm doing some research on DCAA's use of real-time "flash" audit reports. My thesis is that flash audit reports historically were issued to warn PCOs of contractor deficiencies that might impact contract pricing actions. That's why flash reports related to estimating system deficiencies are reportable audits in CAFU but other flash audit reports are not (at least, that's how I read DoDI 7640.02). Recently, however, DCAA seems to be issuing flash reports as a matter of routine, using them to document audit leads and other miscellaneous findings that clearly have no impact on current contract pricing actions. The "routine" flash reports have the same distribution as the estimating system reports, as far as I can tell. I confess I have little to go on other than gut feel. I can't find any guidance that discusses the reports other than the CAM or the DoDI noted above. So I'm soliciting any input -- anecdotes, reference material, etc. -- that might confirm, or refute, my thesis. Anybody? Thanks for the help.
  16. Orion, I assume you have some type of contract in place with the contractor. What does it say about payment terms? In my view, this has nothing to do with T4C or the Termination Contracting Officer or the Air Force. This is a private matter solely between you and your client. You have plenty of options, including legal ones. Why not pursue them? Hope this helps. (P.S., my contracts generally call for payment within 15 days. I'm currently awaiting a payment that's now past 60 days due. I feel your pain.) H2H
  17. Retreadfred, As I understand the issue, the original contract was effective prior to the date that the executive compensation caps were implemented in 31.205-6. A modification was subsequently executed after the caps became applicable. Somebody has alleged that the contractor has incurred unallowable executive compensation. The contractor is arguing that, since the effective date of the contract was prior to the implementation of the compensation caps, the "excess" compensation costs can not be deemed unallowable with respect to that contract. Somebody else seems to be arguing that, since the modification included 52.216-7, it established a new effectivity date and thus incorporated the modified cost principle. The question omits a discussion of the controversy regarding whether the executive compensation caps were retroactive (I believe General Dynamics litigated that point). In any case, Vern is right that one would need to see the entire contract and the entirety of the modification in order to figure out what the parties intended, and I bet there are some extremely pertinent facts/circumstances that would need to be fleshed out ... especially since "pricing" is not the same as cost accounting and/or billing.
  18. Vern, The point I was trying to make was that, if the government did not have a monetary remedy available under TINA, perhaps it would not be treated as TINA matter. We've discussed that point. There's no need for another thread.
  19. Vern, my point was that I would see a TforD as being unwarranted in a situation where the government suffered no harm. I acknowledge it is a possible course of action, but one I would find unlikely, given the circumstances. In the case you cited from, the government could allege actual harm. As a counter example, I have been part of multiple CPSR reviews, where several failures to comply with clauses that implemented statutorily mandated obligations were encountered. (E.g., failure to obtain EEO clearance when required, failure to flow down CAS admin. clause when required, etc.) In NONE of those instances did the DCMA reviewers ever recommend, consider, discuss, or even mutter under their breath, a TforD as the government's remedy. I would be surprised if the hypothetical situation I posited would be treated differently. Again, it is a possible course of action, but why? Just as a negotiating tactic to bludgeon the contractor into giving some form of consideration? I reiterate: I don't see it [happening] -- but I acknowledge that it could happen.
  20. Vern, I'm not seeing it, unless the Government has suffered some substantive harm in the scenario I posted. "A default termination is a drastic sanction, which should be imposed and sustained only on ?good grounds and on solid evidence.? E.g., Lisbon Contractors, Inc. v. United States, 828 F.2d 759, 765 (Fed. Cir. 1987). Government contract provisions authorizing termination of a contract for default are a species of ?forfeiture? and are to be strictly construed. Forfeitures are not favored, and one who asserts that there has been a forfeiture is held to the letter of its authority."
  21. General Electric had a similar issue, when valuing depreciation costs denominated in Turkish lira into U.S. dollars. http://www.ll.georgetown.edu/FEDERAL/judic...ns/00-1401.html Hope this helps.
  22. This has been a very helpful discussion. I have a question though. Let's say that the contractor in this example -- the one with the FFP contract who's changing subcontractors after award -- does NOT obtain cost or pricing data from its second subcontractor, as Vern and others have asserted must be done. Thus, the contractor has violated contract clause requirements as well as the TINA statute requirements. My understanding is that the Government's remedy is a unilateral price reduction for the amount of the costs that were defectively priced, plus interested on any overpayments. In this hypothetical example, how would the Government calculate its damages? What would its remedy be? If there are no damages, because the Government did not rely on the second subcontractor's cost or pricing data when negotiating the value of the prime contract, and there are no overpayments because the prime contract is FFP, then where do the parties go from here? Answering those questions would help me understand better what the dynamics are.
  23. On a whimsical note, I have to ask you when you think the Working Group guidance should lose its "interim" status? After all, we're talking about the seventies here. The "interim" guidance is, what, roughly 40 years old? At what point do the working group documents ever become "final" guidance papers? just wondering ... And for others, let's be clear that we are talking about DOD-specific guidance issued in the 1970's to help contracting officers and others address issues/concerns with the then newly issued CAS rules and Standards. It is/was internal guidance only and not found in any statute or regulation. The DOD guidance has/had no effect on other agencies, and no effect on contractors, and has not (to my knowledge) been recognized as authorative by any court. The guidance is, however, embedded into current DCAA audit guidance, and thus affects how DCAA views and interprets CAS requirements today. Hope this helps.
  24. Couldn't the orders trigger or affect CAS requirements under certain circumstances? For instance, assume the contractor is not currently subject to CAS because none of its contracts are greater than $7.5 million in value, but then it receives a single order in excess of $7.5 million. Would not future orders in excess of $650,000 be subject to CAS (assuming no other exemption was available)? Would not those CAS-covered orders need to be tracked and aggregated to determine the level of CAS coverage? For instance, assume the contractor was subject to CAS (or became subject to CAS under the above scenario), but was able to claim modified coverage because it did not receive more than $50 million in CAS-covered contracts in a single year. However, in the next year it received a number of orders under the BOA whose aggregated value exceeded $50 million. Would not future orders in excess of $650,000 be subject to full CAS coverage (as opposed to modified coverage)? Would not the contractor then be required to file a CASB DS-1 Disclosure Statement?
  25. I think you can find most of the substance of the CAS Working Group guidance within the DCAA Contract Audit Manual. If you need the exact papers, Lou Rosen collected them -- along with the Standards and preambles -- in a single book published last year. I don't believe they are available on the web outside of CCH or other subscription service. Hope this helps.
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