0 - ABAD Government Responses.xlsx

Sheet1

https://www.dcaa.mil/Checklists-Tools/Pre-award-Accounting-System-Adequacy-Checklist/ Attachment 1 - ABAD Section L Volume IV Instructions: Section L.7.1.e states “All Offerors shall complete Pre-Award Audit Registration regardless of whether it has an approved accounting system.” We have been unable to obtain a format or template for the required Pre-Award Audit Registration either from our cognizant DCAA Auditor or through the DCAA website (http://www.dcaa.mil). A previous question asks: "Can the Government clarify the requirement for completing the “Pre-Award Audit Registration or provide the associated format/template as an attachment to the solicitation?" The Government's response states "Please find the checklist at the following link. It is the hyperlink titled "Preaward Accounting System Adequacy Checklist." https://www.dcaa.mil/Checklists-Tools/Pre-award-Accounting-System-Adequacy-Checklist/." The original question pertains to the “Pre-Award Audit Registration” as identified in Section L.7.1.e. The Government's response pertains to the “Preaward Accounting System Adequacy Checklist" as identified in Section L.7.1.d. These appear to be two different requirements based on the naming conventions used.

Can the Government clarify the requirement for completing the “Pre-Award Audit Registration," as required by Section L.7.1.e, or provide the associated format/template as an attachment to the solicitation? The offeror shall complete the "Preaward Accounting System Adequacy Checklist" and submit it with the proposal. The CO will then either review the Checklist or engage with the offeror's cognizant DCAA office to review the checklist and determine its adequacy in order to complete the SF 1408.

The intent of Section L. 7.1.e is as follows: The offeror shall complete the process of submitting the checklist in Section L.7.1.d, and comply with any DCAA audit requirements that may result from the submission of the adequacy checklist, regardless of whether or not they have an approved accounting system. Aside from the Preaward Accounting System Adequacy Checklist, there are no other documents required to be submitted as part of the Offeror's proposal in relation to Section L 7.1(d) and 7.1(e).

3.1.2.1 Recency

The Offeror provided information on contract efforts that completed a minimum of three (3) years of experience during the past five (5) years from the date of the issuance of this solicitation. Past Experience information that fails to meet this criterion will not be further evaluated and will be considered Unacceptable."

The apparent prohibition of indirect burdens on CR CLINs under the resulting ABAD IDIQ award may serve to discourage potential Offerors, as they will not be reimbursed for their valid indirect costs. It also runs counter to FAR Clause 52.216-7, Allowable Cost and Payment, which is included in Section I of the solicitation and in the RADCL Task Order (Attachment 05 of the solicitation). Section (b)(1)(ii)(F) of FAR 52.230-7 specifically allows for the reimbursement of "[p]roperly allocable and allowable indirect costs, as shown in the records maintained by the Contractor for purposes of obtaining reimbursement under Government contracts".

Question: For task orders issued under the resulting ABAD IDIQ contract, is the Government prohibiting the successful Offeror from receiving reimbirsement for indirect costs incurred under CR CLINs ("that would otherwise be properly allocable and allowable for reimbursement as shown in the records maintained by the Contractor for purposes of obtaining reimbursement under Government contracts")? No. The Government agrees that the Contractor should be reimbursed for indirect costs incurred that are reasonable, allocable, and allowable. The intent of that paragraph is to ensure that the value for each CR CLIN is unchanged between offerors for evaluation purposes.