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  1. Cross Charging (Comingling of Contracts) as defined by the DoD IG's Office reads: Dishonest contractors can submit multiple bills on different contracts or work orders for work performed or expense incurred only once. A contracting official can facilitate the scheme and share in the profits by writing similar work orders under different contracts and accepting the multiple billings. (Source: International Anti-Corruption Resource Center, 2014) Fraud indicators related to cross charging (comingling of contracts) include, but are not limited to: Multiple awards for similar work are given to the same contractor. The contractor submits several invoices for the same or similar expense or work under different jobs or contracts. The contractor submits the same or similar documentation to support billings on different contracts. Similar work orders are issued to the same contractor under more than one contract. Contractor receives multiple awards for similar work. Frequent errors/corrections of errors on invoices and other documents. Contractor costs on fixed priced contract are unusually low. Costs on the cost plus contract are considerably higher than those expected or budgeted. Same employee billed to more than one job for the same time period. Whereas, Industry defines cross charging as companies filling various fixed-price and cost-plus contracts simultaneously. While sometimes, shifting the costs and expenses associated with fixed-price contracts to a cost-plus contract in order to increase their profit. Based on the DoD IG's definition, one could interpret that that it would not matter what type of contract it is. Thus, could the following be deemed as cross charging? Is the following actually allowable? Company ABC identified one specific employee on three (3) separate proposals while proposing that said employee would be providing 3/4 of his time (1,410 hours) on the first contract and 1/4 of his time (470 hours per contract) on each of the second and third contracts. The Government awards all three contracts to Company ABC on a firm-fixed-price (FFP) basis for the delivery of services and the company submits fixed monthly invoices per contract.
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