Volume 5 – Use of Blended Rates for Multiple Compensation Caps – February 2015

The resent change in the compensation cost principle has created a situation where different compensation caps will apply to different contracts. This can create difficulties for government contractors in forecasting and calculating their provisional and final indirect cost rates. Contractors are faced with a number of options on how to handle the different compensation caps. Each option has it unique benefits and drawbacks.

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Volume 4 – Lodgings Plus Per Diem Method – October 2014

The US Government (USG) is involved in activities all over the United States and overseas requiring contractors to incur lots of travel costs. The Federal Acquisition Regulation (FAR) cost principles provide some basic travel procedures that contractors can elect to could follow. The FAR also incorporates, in part, supporting regulations to further define those procedures including additional restrictions on what types of travel costs are allowable under USG contracts. Even with these travel rules and regulations, contractors have various options for handling the allowability of travel costs as described in FAR 31.204-46.


Volume 3 – Fly America Act – October 2014

The Federal government spends billions of dollars annually procuring supplies and services from Government contractors. The Government has enacted rules and regulations to provide guidance on how Government contracts will be executed and how Federal funds will be spent. There are laws and regulations that decree that Agencies or Government contractors shall give preference to US companies over foreign companies while spending Federal funds on supplies or travel. This paper will briefly discuss the Fly America Act.


Volume 2 – Limitations on Pass-Through Charges – November 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.


Volume 1 – The Interim DFARS Business Systems Rule is “in Play” – November 2011

CostTrend has been following the DOD initiative for new procurement rules on Contractor Business systems (CBS). The interim DFARS rules have been issued and are now in effect, and the Government Contracting community is studying the clauses and developing compliance strategies. We have prepared an introductory summary, focusing primarily on DFARS 252.242.7002 Contractor Business Systems which establishes the prescribed framework for administration of the six individual business system clauses.