Ask A Professor (AAP) is a Department of Defense resource for asking acquisition and logistics questions concerning policies and practices.
Inter-Service Support Agreements - DD Form 1144 - invoicing standards requirements
8/29/2017 10:22:00 AM
Question: As the AMC MSC reviewer of DD Form 1144, I would like to know what ARMY reference(s) can I state on my Memorandum from CECOM to IMCOM requesting better proof of documentation for billing standards? Does CECOM have a right to request a more auditable documentation for a reimbursable charge?
Answer: This response is based on the information provided. We suggest you discuss with your contracting officer and/or legal department as appropriate. We do not have the capability to dig into every service's method of implementing contracting rules. We suggest you seek guidance from your command as to the standards the ARMY requires for this type of documentation. With that said, you have the right and responsibility to make a determination that the government is paying a fair price. We note this is ...(More)
Auditing Utilization Government Owned Material
7/25/2017 10:08:00 PM
Question: The question that I am asking is how do you properly audit/assess material for utilization? We have conducted a consumption assessment and we thought that should be sufficient. However it has raised some flag on how one should assess utilization as it pertains to material? According to the FAR 52.245-1 (f)(1)(viii)(A), "the contractor shall utilize, consume, move, and store Government Property only as authorized under this contract. The Contractor shall promptly disclose and report Government property in its possession that is excess to contract performance. This clause has raised some questions on whether this is a utilization issue or contract closeout issue. This being that samples are on contracts that are essentially excess to contract performance because the contract has been physically complete?
Answer: Utilization is probably one of the most misunderstood and difficult outcomes to audit. I applaud you for reaching out for clarification. I will state upfront that there is ...(More)
Request to Downgrade from ACAT I to ACAT III
7/21/2017 3:22:00 PM
Question: Can an ACAT I program be downgraded without reducing the funding, and what is the process to do this? If not, what is the process to request the MDA delegate authority to a lower level (PEO)?
Answer: ACAT I priorities are based on type of funding and on dollar threshold. For ACAT I it is, "Dollar value for all increments of the program: estimated by the DAE to require an eventual total expenditure for research, development, and ...(More)
Is DCAA Audit Required on a Time and Material GSA Order Closeout?
7/21/2017 9:05:00 AM
Question: Is a DCAA Audit Required on a Time and Material GSA Completed Order Closeout? If yes, provide FAR references.
Answer: This his response is based on the information provided. We suggest you discuss with your contracting officer and/or legal department as appropriate. You did not mention the value of the contract/order that you are closing out. T&M contracts have indirect rates, i.e. G&A on materials for which an ...(More)
Cost Accounting Practice Change - Changes to DL Bid Codes
5/10/2017 11:56:00 AM
Question: Is the change described in the scenario background considered a cost accounting practice change and subject to contract adjustment under the CAS Clause?
Answer: This response is based on the information provided. We suggest you discuss with your contracting officer and/or legal department as appropriate. It's possible that a change in rate composition could result in the need for the contractor to analyze the cost impact and let us know. Since the ...(More)
Is software for own use considered a Tangible Capital Asset?
4/4/2017 3:24:00 PM
Question: Is software for the contractor's own use considered a tangible asset?
Answer: The following response is based solely on the question and background information provided. As we do not have all the facts particular to your situation, we highly recommend you consult, as applicable, your contracting officer and/or Legal Office for further guidance. To answer the question we look at the definitions provided in FAR part 31 ...(More)
Applying Sales Tax on Construction Contracts
4/4/2017 8:46:00 AM
Question: Can you think of any situation where allowing a contractor to apply sales tax to any cost other than the bare cost of material and equipment?
Answer: The following response is based solely on the question and background information provided. As we do not have all the facts particular to your situation, we highly recommend you ...(More)