RFI_DFARs 252.204-7006 Billing Instructions-Cost Vouchers.docx
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This document is a response to a Request for Information from the Naval Air Systems Command Naval Air Warfare Center regarding DFAR 252.204-7006, Billing Instructions-Cost Vouchers. The response provides information on current use of "other" payment instructions under DFARS PGI 204.7108(d)(12) and projections of impacts from removing this provision. It outlines potential impacts to timelines for invoice preparation and submittal, quality assurance of financial deliverables, overhead costs due to increased contract line item numbers to manage, financial management tools and processes, and management of hours, costs and fees across more line items. The respondent also offers recommendations for alternative contract structures or financial management methods to achieve the intended goals.
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| DFARS_252.204-7006.pdf | Revision not stated | VENTILATION CLEANING OF US SUBMARINE |
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Response to Request for Information in regards to DFAR 252.204-7006, Billing Instructions-Cost Vouchers
Contractor Name: _______________________________ Contractor Cage: _______________________________ Contractor Point of Contact (POC): _______________________________ Contractor POC email address: _______________________________ Contractor Address: _______________________________ Contractor Phone Number: _______________________________ Contractor Size Status under NAICS code 541330 ($47M): _______________________________ A. Do any of your current contracts utilize the DFARS PGI 204.7108(d)(12) “other” payment instructions?
B. Provide a projected impact with the removal of DFARS PGI 204.7108(d)(12) “other” payment instructions.
1. Provide a projected impact of the timeline for the preparation and submittal of invoices / cost vouchers
2. Provide a project impact on the preparation and quality assurance activities associated with financial Contract Data Requirements List (CDRL) deliverables
3. Provide a projected impact on Industry's overhead costs as it relates to the increased number of CLINS to be managed (or task orders to be managed in the case of IDIQs) in place of TDLs combined with payment “other”? If able to do so, please provide a projection assuming 80-100 CLINS per year on “C” type contracts. As for IDIQs, assume 8-10 task orders per year with approximately 10 CLINs on each.
4. Provide a projected impact on your financial management tools and processes to accommodate this change.
5. Provide a projected impact on the management and traceability of Hours, Cost, and Fee across the increased number of CLINs, specifically with regards to managing re-alignments, de-obligations, and other activities.
6. Is there anything additional the Government should be aware of as it relates to a potential impact to Industry of the deletion of DFARS PGI 204.7108(d)(12) “other” payment instructions?
C. Provide any recommendations to alternative approaches to CLIN structures or other contract financial management methods to achieve the intended goal.
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