Volume 2 - Limitations on Pass-Through Charges - Novemebr 2011

FAR 52.215-22-Limitations on Pass-Through Charges-Identification of Subcontract Effort and FAR 52.215-23-Limitations on Pass-Through Charges are two clauses that are now being incorporated in Government solicitations and awards. These two rules are creating much concern in the government contracting community due to their “subjective” nature and the creation of new post-award audit rights regarding recovery of “excessive pass-through charges”. Our article describes the FAR requirements, highlights the areas of contractor compliance risk, and provides some ideas for mitigating the risk associated with an “excessive pass-through charge” determination by the Government. Further use without consent from CostTrend is prohibited. This document is for general information purposes and does not represent any type of professional advice. We have made every attempt to ensure that this document is accurate and reliable but CostTrend cannot be held responsible or liable for any errors or omissions or the results obtained from use of this data or any decision made or action taken in reliance of the data contained herein.