Former_DCAA Posted September 13, 2024 Report Share Posted September 13, 2024 I have a few questions based on the following scenario: - A company has only held firm fixed price contracts, but a few years ago was awarded a contract that is primarily FFP, but has CPFF and Cost CLINs for Travel and Over and Above work - Their accounting system is not setup in accordance with the SF-1408 or DFARS accounting system criteria - The contract has the allowable cost and payment clause I have requested a report on activity + invoicing on these CLINS. Questions: - Are they required to submit a final indirect cost rate proposal (aka incurred cost submission) every year with activity on those CLINs? They have not - How could this have even been awarded to them without an adequate accounting system? Quote Link to comment Share on other sites More sharing options...
Retreadfed Posted September 14, 2024 Report Share Posted September 14, 2024 On 9/12/2024 at 8:52 PM, Former_DCAA said: Are they required to submit a final indirect cost rate proposal (aka incurred cost submission) every year with activity on those CLINs? Theoretically yes, however, if there has been no activity on the CLINs, doing so would be an act with no significance. On 9/12/2024 at 8:52 PM, Former_DCAA said: How could this have even been awarded to them without an adequate accounting system? Contractors are required to have an accounting system that is adequate for the contract type contemplated. The CO who awarded the contract may have considered the contract to be FFP and the contractor's accounting system adequate for that contract type. Quote Link to comment Share on other sites More sharing options...
Former_DCAA Posted September 17, 2024 Author Report Share Posted September 17, 2024 On 9/14/2024 at 5:46 PM, Retreadfed said: Theoretically yes, however, if there has been no activity on the CLINs, doing so would be an act with no significance. Contractors are required to have an accounting system that is adequate for the contract type contemplated. The CO who awarded the contract may have considered the contract to be FFP and the contractor's accounting system adequate for that contract type. I confirmed that there is activity, but it less than 1% of their total costs. Would your suggestion be to bring this up to the CO and see if they want the submission? Quote Link to comment Share on other sites More sharing options...
Retreadfed Posted September 17, 2024 Report Share Posted September 17, 2024 1 hour ago, Former_DCAA said: Would your suggestion be to bring this up to the CO and see if they want the submission? Yes Quote Link to comment Share on other sites More sharing options...
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