govtacct02 Posted October 30, 2017 Report Share Posted October 30, 2017 I am looking for a reference I can cite that articulates when a Guidance memo/paper issued by DPAP or Defense Pricing expires. Can anyone help? Link to comment Share on other sites More sharing options...
Don Mansfield Posted October 31, 2017 Report Share Posted October 31, 2017 Like this: Quote Any document that is to be incorporated into a particular regulation is marked to indicate that regulation and either the actual date of incorporation or the estimated date of incorporation. After a document is incorporated into a regulation the actual date is marked and the document is transferred to archives. Documents not to be incorporated into policy are transferred to the archives 60 days after publication. https://www.acq.osd.mil/dpap/ops/policy_vault.html Link to comment Share on other sites More sharing options...
joel hoffman Posted October 31, 2017 Report Share Posted October 31, 2017 10 hours ago, Don Mansfield said: Like this: https://www.acq.osd.mil/dpap/ops/policy_vault.html Don, I didn’t read that policies not to be incorporated into a regulation expire upon transfer to the policy vault. “The Policy Vault is a central repository for documents that are available to the public. Uncontrolled unclassified memoranda, guidance, reports, and other DPAP-related policy documents are found here.” Link to comment Share on other sites More sharing options...
here_2_help Posted October 31, 2017 Report Share Posted October 31, 2017 I suspect the question has to do with whether DPAP and other DoD activities can avoid the required regulatory rule-making process by issuing guidance and memoranda that interpret regulations, without actually incorporating those interpretations into the regulations. Link to comment Share on other sites More sharing options...
Don Mansfield Posted October 31, 2017 Report Share Posted October 31, 2017 3 hours ago, joel hoffman said: Don, I didn’t read that policies not to be incorporated into a regulation expire upon transfer to the policy vault. “The Policy Vault is a central repository for documents that are available to the public. Uncontrolled unclassified memoranda, guidance, reports, and other DPAP-related policy documents are found here.” I don't know the significance of a document being transferred to the Policy Vault archives. The description of the archives sounds like a policy document graveyard: Quote Policy Vault Archives The archives is the final repository for all documents that were incorporated into a regulation or instruction. It is also the final repository for any document that was not intended to be incorporated into regulation or instruction. Those documents shall be moved to archive after 60 days in the policy vault. It would be strange to move documents to an archive if they were still effective. But, I admit I don't know for sure. Link to comment Share on other sites More sharing options...
govtacct02 Posted November 1, 2017 Author Report Share Posted November 1, 2017 22 hours ago, here_2_help said: I suspect the question has to do with whether DPAP and other DoD activities can avoid the required regulatory rule-making process by issuing guidance and memoranda that interpret regulations, without actually incorporating those interpretations into the regulations. Here - Yes, you are correct, and also to respond to DOD activities that are using old guidance to make a CAS-related argument where rulemaking has not occurred. Thank you all. Link to comment Share on other sites More sharing options...
here_2_help Posted November 2, 2017 Report Share Posted November 2, 2017 govtacct02, Remember that DPAP issued a follow-up memo, stating that any assertions of CAS non-compliance had to cite to the CAS regulation and not to the original DPAP memo. Link to comment Share on other sites More sharing options...
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