bjohnson Posted August 27, 2021 Report Share Posted August 27, 2021 Hello - I am aware that the government does not pay for costs associated with the preparation and submission of a proposal, what are the general rules/guidelines regarding modifications? As an example we have an active contract where we are negotiating a change in scope and pricing. This modification has taken weeks and multiple rounds of negotiation equaling dozens of hours of work for our staff. Is it generally acceptable that we charge for work preparing modifications on active contracts so long as there is an appropriate billing code/task available? Thank you! Link to comment Share on other sites More sharing options...
Retreadfed Posted August 27, 2021 Report Share Posted August 27, 2021 Have you looked at FAR 31.205-18? Link to comment Share on other sites More sharing options...
Vern Edwards Posted August 27, 2021 Report Share Posted August 27, 2021 @RetreadfedIR&D and B&P? Link to comment Share on other sites More sharing options...
bjohnson Posted August 27, 2021 Author Report Share Posted August 27, 2021 I have looked at FAR 31.205-18 but I don't think this work fits. This work is directly related to the contract, but would a CO consider it IR&D or B&P? Link to comment Share on other sites More sharing options...
Retreadfed Posted August 27, 2021 Report Share Posted August 27, 2021 4 minutes ago, bjohnson said: This work is directly related to the contract, but would a CO consider it IR&D or B&P? If the contract requires the contractor to submit the proposal, it would not be considered a B&P cost. In this case, the cost could be charged as a direct cost of the contract. On the other hand, if the contract does not require the contractor to submit the proposal, a contractor could treat the cost as a B&P cost in accordance with FAR 31.204(d) and charge the cost as an indirect cost if that is its normal accounting practice. Link to comment Share on other sites More sharing options...
bjohnson Posted August 27, 2021 Author Report Share Posted August 27, 2021 Thank you @Retreadfed. Helpful to understand the difference between when it is requested verses not requested. Link to comment Share on other sites More sharing options...
Vern Edwards Posted August 27, 2021 Report Share Posted August 27, 2021 3 hours ago, bjohnson said: Hello - I am aware that the government does not pay for costs associated with the preparation and submission of a proposal, what are the general rules/guidelines regarding modifications? As an example we have an active contract where we are negotiating a change in scope and pricing. This modification has taken weeks and multiple rounds of negotiation equaling dozens of hours of work for our staff. Is it generally acceptable that we charge for work preparing modifications on active contracts so long as there is an appropriate billing code/task available? Thank you! What do you mean when you say you are negotiating a "change in scope"? If this "change" adds new work to the contract, then the cost of preparing a proposal is bid and proposal cost. Read the definition in FAR 31.205-18. If you when you say "change in scope," you're actually negotiating the cost of a within-scope change, then the cost of preparing and negotiating a request for equitable adjustment is an allowable part of the cost of the change. So which is it? Are you negotiating an out of scope addition of work to the contract or an equitable adjustment following a within-scope change? Link to comment Share on other sites More sharing options...
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