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Welcome to Apogee Consulting, Inc.

Reforming the Pentagon’s “Fourth Estate”

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The story (which may be apocryphal) goes like this:

Alanis Morissette’s 1995 album, “Jagged Little Pill,” was a huge hit (selling more than 33 million copies); it won five Grammy awards (including album of the year). The album spawned six singles, including “You Oughta Know,” “All I Really Want,” and “Ironic”. The lyrics of “Ironic” are famous for generating a two-decade long debate about whether, in fact, the situations described in the song were ironic. The consensus is that they were not. They were not ironic. Isn’t that ironic?

UK Interviewer: Ms. Morissette, let’s talk about your song, “Ironic.” The lyrics are puzzling. “A black fly in your chardonnay?” “rain on your wedding day?” “good advice that you just didn’t take?” Et cetera. None of those are ironic. Most are just coincidence.

Morissette: Okay.

UK Interviewer: Isn’t this misuse of the word ‘irony’ just another example of the failed American educational system?

Morissette: Actually, I was born and raised in Canada. I’m not American by birth or education.

UK Interviewer: Uh ….

Morissette: Isn’t that ironic?

Whether you call it irony or coincidence, we couldn’t help but notice that the very day after we submitted our most recent blog post—the one that included criticism of the Pentagon regarding its failed efforts to reform its own backoffice bureaucracy (the so-called “Fourth Estate”)—a new report was released from the Pentagon’s Office of the Chief Management Officer (OCMO) that addressed progress to reduce costs in that very area.

Why the report? Well, Section 921 of the 2019 National Defense Authorization Act (NDAA) requires it. Specifically, it requires the OCMO to reduce costs in certain “covered areas” by 25 percent by GFY 2020, or to justify why doing so would create unacceptable inefficiencies. And that same Section of the public law requires the OCMO to issue a periodic report on progress being made. So here it is…

Let’s cut to the bottom-line. Quoting from the report:

In order to meet Congressional intent, this report focuses on reforms and financial savings in the four covered activities within the Fourth Estate, including Defense Agencies and DoD Field Activities (DAFA). While the OCMO projects that it will not meet the 25 percent savings targets in all of the four covered activities in FY 2020 against the FY 2019 baseline, the OCMO forecasts an average 5 percent cost reduction for each of the covered activities in the Fourth Estate.

So: Mission not accomplished.

One thing that we noticed—which should be no surprise to those who follow Pentagon business reform efforts—is that a new group was created to oversee the reductions to bureaucracy. The new group is called “Fourth Estate Management Office” (FEMO). As noted in the report, FEMO is supported by outside consultants.

That’s right. The first action taken in the effort to reduce bureaucracy was to create a new bureaucratic entity.

We further noticed that the ability to reduce Fourth Estate costs was tied to the definition of which entities comprise the Fourth Estate. Thus, adding the Washington Headquarters Services to the definition of the Fourth Estate—and then declaring a goal to reduce WHS costs by 30 percent—means that the other functional aspects of the Fourth Estate don’t need to be cut as much.

That strategy is consistent with a bureaucracy protecting itself.

Is this a big deal? Not really. It’s just interesting to observe how the Pentagon protects itself. Former SECDEF Gates called for cuts in this area. Congress called for cuts in this area via public law. You’d think there would be some accountability for failing to deliver. Not so far.

The Pentagon bureaucracy seems to be avoiding the hard decisions in an apparent effort to protect certain fiefdoms, despite being told to make those hard decisions by people who would seem to have authority in the chain of command.

Isn’t that ironic?


Peering Into the Future

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Recently I had an opportunity to attend an industry briefing, given by a senior DOD acquisition policy official. (I need to be vague here because the briefing was on a “non-attribution” basis, meaning that no direct quotes are permitted.) In that briefing, the senior official cited to the 2018 U.S. National Defense Strategy.

The National Defense Strategy (NDS) is the successor to the Quadrennial Defense Review. As such, it is produced very four years. It provides broad guidance to the Pentagon in areas such as military planning, military strategy, force posturing, force constructs, force modernization, etc. The Pentagon takes that guidance and, through the Joint Chiefs of Staff, creates the National Military Strategy (NMS), which provides detailed guidance for theater campaign planning, modernization, force posturing, and force structure. The NMS is classified; while most of the NDS is not.

Thus, when this senior DOD acquisition policy official cited to the latest NDS, he was citing to the highest level of U.S. military strategic planning. It was interesting to see an acquisition official cite to military guidance, but it made sense—because the military objectives are intertwined with acquisition objectives.

The 2018 NDS includes eleven strategic objectives. We’re going to list just two of them, because they seem relevant to the topic. They are:

  • Continuously delivering performance with affordability and speed as we change Departmental mindset, culture, and management systems

  • Establishing an unmatched twenty-first century National Security Innovation Base that effectively supports Department operations and sustains security and solvency

The first bullet point listed above is an old topic, much repeated. We first noted it way back in 2009, when we reported to readers that the Defense Science Board had told SECDEF that the DOD acquisition process was too bureaucratic to meet the needs of the warfighters. In the intervening decade, not much has changed, though some Section 809 Panel recommendations, if adopted, might move the needle a bit.

The second bullet point is also interesting from a nomenclature perspective. Historically, the defense industrial base has been referred to as just that—“the defense industrial base.” In fact, the official Pentagon component that works in that space is the “Industrial Policy Office.” So to see the description change to “National Security Innovation Base” is interesting and speaks to what the Pentagon is hoping to get.

Importantly, the NDS devoted a significant amount of verbiage to acquisition reform. (Only it wasn’t called that.) The NDS stated—

The current bureaucratic approach, centered on exacting thoroughness and minimizing risk above all else, is proving to be increasingly unresponsive. We must transition to a culture of performance where results and accountability matter. … Current processes are not responsive to need; the Department is over-optimized for exceptional performance at the expense of providing timely decisions, policies, and capabilities to the warfighter. Our response will be to prioritize speed of delivery, continuous adaptation, and frequent modular upgrades. We must not accept cumbersome approval chains, wasteful applications of resources in uncompetitive space, or overly risk-averse thinking that impedes change. Delivering performance means we will shed outdated management practices and structures while integrating insights from business innovation. …

Better management begins with effective financial stewardship. … We will continue to leverage the scale of our operations to drive greater efficiency in procurement of materiel and services while pursuing opportunities to consolidate and streamline contracts in areas such as logistics, information technology, and support services. We will also continue efforts to reduce management overhead and the size of headquarters staff. We will reduce or eliminate duplicative organizations and systems for managing human resources, finance, health services, travel, and supplies.

Naturally, the above objectives are much more easily said than done. Still, most of us would agree they are important objectives that, if met, could make the defense acquisition environment a more efficient (and easier!) marketspace in which to operate.

But as history consistently has shown us, the Pentagon is not comfortable shining a light into its back-office workings. (See this blog article for one example.) As soon as Congress (or the Secretary of Defense) challenges the Pentagon to reduce bureaucracy (and/or costs), the next step is to focus on contractors. That diversion ignores the fact that contractor costs (largely) come out of a different color of money, and it ignores the fact that those who focus on contractors instead of the Pentagon’s “Fourth Estate” are missing the point of the exercise. Still, it’s the traditional approach when faced with a challenge to shrink Pentagon bureaucracy and to streamline business processes.

In what we are sure is an effort completely unrelated to the NDS objectives discussed above, that same senior Pentagon acquisition official noted that it is past time to perform another study of contractor financing and profit. The reported goal is to complete that study by the end of GFY 2020.

Many readers are largely ignorant of the give-and-take between Pentagon leadership, Congress, and the largest defense contractors. That give-and-take involves influencing annual National Defense Authorization Acts (NDAAs), establishing acquisition policy goals, and addressing proposed changes to acquisition regulations. It’s an ongoing process, involving lobbyists, staffers, Pentagon stakeholders, and industry associations (just to name a few). The give-and-take process is happening right now, and it will continue into the foreseeable future.

We trust you’ve enjoyed a glimpse into that process.

Last Updated on Monday, 07 October 2019 17:25

More on Performance-Based Payments

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Reader Dave asked us to expand on our previous post re: PBPs, focusing on the following comment:

Never mind that (from the contractor’s side) use of PBPs leads to enhanced cash flow and reduced audit support efforts. Never mind that (from the government’s side) use of PBPs leads to reduced oversight requirements and increases depth of competition. Nope. PBPs are not well-understood and they are hard to plan, and so the contracting parties have learned to avoid them in favor of the traditional cost-based progress payments that offer reduced cash flow, increased audit oversight …

Dave commented: “I initially read this as PBP lead to enhanced cash flow THAT IS BETTER THAN progress payments (but now I think you mean generally over cost type), and also that there is less audit with PBPs than progress payments (but now I think you also meant this generally over other cost type).”

No, Dave. I meant what I wrote. Use of PBPs leads to enhanced cash flow that IS better than that offered by use of progress payments calculated as a percentage of cost incurred. Or, at least, it should. And there is definitely less oversight on PBPs than there is with progress payments.

Let’s dive in.

Contract Financing

In general, the government provides contract financing payments when the contractor needs funds in advance of delivery. For example, if you have a 24 month-long contract with delivery at the end of 24 months, and the government only pays you on delivery, then you have to wait 24 months to get any cash in the door. That means you have to pay your employees (and suppliers) for two years, while waiting to get the funds to cover those payments. Most contractors don’t have two years of cash flow in the bank and, even if they do, that’s essentially a two-year interest-free loan to the Federal government. Not a good situation.

Thus, the government offers the ability to get paid prior to actual delivery. There are various types of contract financing payments; they are discussed in FAR Part 32. What’s interesting about these payments is that not all contracts are eligible to receive them (see the qualification criteria at FAR 32.104). Also note that contract financing payments are limited to fixed-price contract types; you can’t get them on cost-reimbursement contracts, because the government is already paying invoices based on costs incurred (and not on delivery). Another interesting aspect is that many smaller contractors don’t know about them or are hesitant to request them, even when the contract would qualify. In other words, many of the contractors most in need of enhanced cash flow don’t request contract financing payments.

On the other hand, the bigger contractors know all about contract financing payments and make sure they receive them at every opportunity. After all, “cash is king.”

Progress Payments

Traditional progress payments are a contract financing method that enhances contractor cash flow by reimbursing a fixed percentage of the contractor’s costs, as they are being incurred. Progress payments are discussed (in general) at FAR 32.5, but one needs to review the contract clause (52.232-16) to really understand the duties and obligations of the parties.

According to FAR 32.501-1, “The customary progress payment rate is 80 percent, applicable to the total costs of performing the contract. The customary rate for contracts with small business concerns is 85 percent.” Right there that tells us that a large contractor is on the hook for funding at least 20 percent of costs incurred (15 percent if you’re a small business). Importantly, note that we are talking about costs, not price. Any profit is realized upon delivery and not through progress payments received.

And the contractor cannot just tally up costs incurred, multiply by 0.80 (or 0.85), and then submit a progress payment request via SF 1443. Nope. It’s not total costs, it’s total costs as calculated in accordance with the 52.232-16 contract clause.

For example, “Costs that are not reasonable, allocable to this contract, and consistent with sound and generally accepted accounting principles and practices” must be excluded from the basis on which progress payments are calculated. Remember, this is a fixed-price contract, so normally nobody cares about your unallowable costs. But use of progress payments effectively converts your FFP contract to a cost-type contract, with respect to identification and segregation of costs made unallowable by FAR Part 31. That takes effort.

[Editor's Note: It's important to note that progress payments are not conditioned on cost allowability. When I said "unallowable costs" in the foregoing paragraph, I was speaking about unallocable costs and unreasonable costs. Costs that are not compliant with the requirements of the FAR 31.205 selected cost principles may still be used as the basis for establishing costs incurred for progress payment requests. Just so you know ....]

But we’re not done yet.

Contracts that are in a loss position require that the progress payment request be adjusted, because the government doesn’t want to finance a contractor’s loss. (Losses happen, especially on FFP contract types.) This issue is discussed in great detail at FAR 32.503-6(g). This can be an onerous calculation, as it involves estimates-to-complete and estimates-at-completion. But it is a calculation that must be made, because the government has the right to reduce or suspend progress payments when it believes the contractor is not complying with the requirements associated with them.

In order to do all the back-office accounting associated with properly administering progress payments, the contractor essentially needs to have an adequate accounting system. Normally, accounting system adequacy is a necessary prerequisite associated with cost-reimbursement contracts (or maybe T&M contracts); it’s not usually associated with award of FFP contracts. But use of progress payments (once again) effectively converts your FFP contract to a cost-type contract, because your contract financing payments are associated with costs incurred.

And DCAA will be looking to see how you are doing.

DCAA has an entire audit program dedicated to audits of contractor progress payments requests. They will be looking to ensure you are complying with all the little administrative details associated with that Progress Payment contract clause. Thus, not only must you comply in all respects, but you will need to have trained staff on hand who can respond to audit requests and provide the requested support (including the ETC and EAC information that will inevitably be requested).

Summary: Progress payments can be a good thing! They can enhance cash flow and reduce the stress associated with making payroll and paying suppliers while working to deliver. However, they don’t cover all costs, and they require additional resources, and lead to additional government oversight. They are certainly better than nothing, but I believe that Performance-Based Payments are better.

Performance-Based Payments

PBPs are discussed (in general) at FAR 32.10. PBPs are simple, at least in theory. The contracting parties agree, up front, on “events” that represent significant programmatic or technical milestones. Those events are valued—importantly, they are valued up front and memorialized by the parties. At the end of discussions, the parties have agreed on a series of milestones that represent program performance, each of which has an agreed-upon value. As the contractor achieves the event, it submits a request for contract financing payment equal to the negotiated value of that event.

Simple, right? It was designed to be.

FAR 32.1002 states:

Performance-based payments may be made on any of the following bases:

(a) Performance measured by objective, quantifiable methods.

(b) Accomplishment of defined events.

(c) Other quantifiable measures of results.

Talk about a blank slate! Any quantifiable measure of results can be used! Where else in the FAR do you find an opportunity for the parties so sit down and figure out how to measure program performance? Indeed, the origin of PBPs was the realization in the mid-1990’s that progress payments didn’t correlate to program performance; they correlated to the contractor’s ability to spend money. Hence, PBPs were an attempt to link contracting financing payments to actual program performance and accomplishment.

Another aspect of PBPs is that the cumulative value of all PBP events cannot exceed 90 percent of the contract (or delivery item) price. Price. Price is not cost; price includes anticipated profit. Thus, instead of receiving up to 80 percent of adjusted contract costs, a contractor using PBPs can receive up to 90 percent of the negotiated contract price. Right there, one can see why PBPs enhance contractor cash flow.

However, it needs to be said that PBPs only enhance cash flow if the contractor is making progress. If the program is in trouble, those pre-negotiated milestone events may not be achieved as planned. In such circumstances, the contractor will lack the anticipated cash flow enhancement, and it will be on its own to make payroll and pay suppliers. So PBPs should not really be used on immature technology or where delivery problems are probable.

Other collateral benefits come with use of PBPs. They include: no need to adjust for unallowable costs; no need to adjust for contract losses; no need to have an adequate DCAA-audited accounting system; and no need for DCAA to deep-dive into your books and records. Accordingly, a lot of effort and resource-use (for both government and contractor) is avoided.

The only substantive guidance for valuation of PBPs is found at FAR 32.1004(b). Included therein is this snippet, which needs to be kept in mind as milestone events are being negotiated:

Performance-based payment amounts are commensurate with the value of the performance event or performance criterion, and are not expected to result in an unreasonably low or negative level of contractor investment in the contract. To confirm sufficient investment, the contracting officer may request expenditure profile information from offerors, but only if other information in the proposal, or information otherwise available to the contracting officer, is expected to be insufficient.

Consequently, neither party should be planning on accelerated cash flow (when compared to contractor expenditure profiles). The contractor should not plan on being “cash rich” when PBPs are used. If it happens, it happens. But don’t plan on it happening.

Summary: A bit more work up front to plan and negotiate the value of PBP event milestones. However, that up-front investment is more than offset by the reduced effort to be expected post-award. And, as I hope we’ve demonstrated, the contractor’s cash flow should be accelerated in comparison to traditional progress payments based on costs incurred (all things being equal).

Dave, have I adequately addressed your question?

Last Updated on Tuesday, 10 September 2019 16:43

Cybersecurity and Subcontractors

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In the past few years, there’s been a lot happening with respect to cyber-security and counterfeit electronic parts in program supply chains. At this point, if you don’t have a decent idea about what government customer expectations are, you are not likely to fare well in either competitions or reviews of your Purchasing System.

The thing is, most of this stuff is far from new. Government contractors—especially DOD contractors—have known (or should have known) what the expectations are. We’ve been reporting a lot of those expectations in this blog. For example, our first suggestion that cybersecurity might be a topic of some import was published in 2009 and our first article on the risk of counterfeit electronic parts in the supply chain was published in April, 2010. That’s roughly a decade ago. Our first notice of the final DFARS rule that required “defense contractors to incorporate established information security standards on their unclassified networks and to report cyber-intrusion incidents that result in the loss of unclassified controlled technical information from these networks” was published in November, 2013—nearly six years ago. So none of the focus on supply chain management, whether is be on preventing introduction of counterfeit electronic parts or preventing data breaches—is new, at least to readers of this blog.

What’s new is that your management is finally paying attention.

Your management is paying attention because the DOD has gotten its act together (okay, largely gotten its act together) and is starting to enforce rules and to penalize contractors that aren’t complying with them.

Recently, Ms. Ellen Lord (USD, Acquisition and Sustainment) announced creation of the DOD’s Cybersecurity Maturity Model Certification (CMMC), to be used to evaluate contractors’ compliance with regulations and to evaluate their adoption of good cybersecurity practices. Use of the CMMC reflects Ms. Lord’s belief that “security [is] the foundation to acquisition.” In other words, contractors that are not secure, as defined by DFARS contract clause and by the CMMC, should not expect to win a lot of contracts for cutting-edge technology.

In fact, Ms. Lord stated that “by June 2020, industry will see CMMC requirements as part of requests for information [and] by fall of 2020, CMMC requirements will be included in requests for proposals and will be a go/no go decision.” Essentially, she was telling DOD contractors that they have about one year left to get their act together. A year from now, contractors who score at the bottom of their CMMC evaluations will be at a significant competitive disadvantage, unless they are selling pencils and paper clips.

Which may have caused a bit of panic in your management team, unless they had been on top of the issues and been addressing them for the past few years.

In fact, if you want a quick litmus test of the competency of your leadership team, find out when they started to take this stuff seriously. The earlier they got started, the more competent they are. (Obviously, this is not the only area they need to be worrying about. But it’s turning out to be a critical one for defense contractors.)

As we told readers earlier this year, DCMA reviewers are going to be testing compliance with cybersecurity requirements as part of Contractor Purchasing System Reviews (CPSRs). Importantly, the reviewers are going to look at more than just the purchasing files; they are also going to be looking for examples—and evidence—of transfers of Controlled Unclassified Information (CUI) between prime and subcontractor. While several commenters believe these review activities extend beyond the DFARS adequacy criteria, that belief is not going to stop reviewers from executing their mission—nor will it stop them from failing your Purchasing System if you can’t evidence compliance in this area.

If you want to tackle these issues, start with knowledge and training. Then move into investment. You will need to invest a lot of money to fortify your information technology infrastructure. Once you have your own act together, then you will need to move into your supply chain. Although the government reviews start with the Purchasing System, make no mistake: this is about far more than simply flowing down contract clauses to subcontractors. Prime contractors must actually validate their subcontractors are complying with the requirements, and must be able to provide evidence of that validation.

Finally, this subject is actually wider than achieving competitive advantage and maintaining adequacy of one’s Purchasing System. It’s also about False Claims Act risk.

Cisco recently settled a FCA qui tam suit for $8.6 million. Relators alleged that “improperly sold video surveillance software with known vulnerabilities to US federal and state governments.” This article by Business Insider includes the following statement:

With many contracts including pledges that products meet cyber security standards set by the government, experts have long warned that the claims could expand into that area and punish vendors for the vulnerabilities that are present in many systems.

There is pressure on contractors coming from many fronts, and that pressure may cause some contractors to falsely claim compliance when, in fact, they are not complying with cybersecurity requirements. Prime contractors may falsely claim to be properly managing their subcontractors. Subcontractors may falsely claim (to either their primes or other reviewers) that they are complying with cybersecurity requirements. The pressure, and the propensity for some contractors to take the “easy road” of lying rather than the “hard road” of complying, is likely to lead to more suits under the False Claims Act.

While we are not experts in information technology or cybersecurity, we do know a thing or two about compliance, and risks associated with non-compliance, with contractual requirements. This is an area in which the risks are high, and the consequences are becoming ever more severe.

If you are a contract manager, a government accountant, an auditor, or a compliance professional, this is a topic in which you need to be actively engaged. We suggest you get on it.

Last Updated on Monday, 23 September 2019 17:18

DOD Issues Direction to Deviate from DFARS When Dealing with Performance-Based Payments

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Performance-Based Payments (PBPs): a topic many people, on both the government and contractor sides of the table, are not comfortable with—because use of PBPs involves extra effort. Never mind that (from the contractor’s side) use of PBPs leads to enhanced cash flow and reduced audit support efforts. Never mind that (from the government’s side) use of PBPs leads to reduced oversight requirements and increases depth of competition. Nope. PBPs are not well-understood and they are hard to plan, and so the contracting parties have learned to avoid them in favor of the traditional cost-based progress payments that offer reduced cash flow, increased audit oversight, and keep non-traditional companies from entering the defense marketplace.

The bias against PBPs has been exacerbated by recent DOD policies and DFARS rules that have made it harder to use them. In my view, the DFARS rules and associated DOD policies have been illegal since they contradicted the FAR direction that PBPs are the “preferred” form of contract finance payments—and no agency supplement is permitted to contradict FAR language. And it’s not just me: Congress has expressed its frustration with DOD policy and DFARS language in the past few NDAAs (National Defense Authorization Acts).

The DAR Council finally got around to doing something about the situation. (Interestingly, the most progress in addressing Congress’ comments has been made since Shay Assad departed DOD. Just a coincidence, I’m sure.)

I have been interested in PBPs since the late 1990’s, when Jacques Gansler’s DOD focused on “partnerships” with defense contractors and creating more opportunities for private industry to join the marketspace. It was under his watch that the DOD published its first (and best) User’s Guide to PBPs. Since then, I watched the DOD retreat from the bold policies and guidelines he had established—to the point that, until recently, there was no reason to actually avail oneself of the “preferred” contract financing payment method.

However, recently there has been movement. As we reported to readers, at the end of April the DAR Council issued a proposed rule that would, if implemented as drafted, lead to some significant improvements in the administration of PBPs. However, as we told readers (and as we told the DAR Council in the letter we submitted to them), the proposed rule still had one fatal flaw: it required contractors using PBPs to maintain a job cost accounting system, and thus imposed a requirement unique to government contractors—which violated both the letter and intent of the NDAA language.

We’re not sure what the DAR Council will make of our input, which was but one public comment out of eleven submitted. (We noted that several other commenters made some of the same points we had made.) But whatever the DAR Council does in moving the proposed rule to a final rule, the DOD isn’t waiting around for the final language to be published. As if growing impatient with a DAR Council that is seemingly “taking its sweet time” to follow Congressional direction (in the words of one WIFCON poster), DOD recently issued a Class Deviation that tells its contracting officers how to deal with PBPs—and that Class Deviation seems to address every concern we had with the proposed rule.

Class Deviation 2019-O0011 provides a solicitation provision and contract clause that are to be used (“effective immediately”) to deviate from the current (problematic) DFARS regulatory language. Notably, the clause language contains strong language that supersedes both the current and proposed regulatory language.

For example:

Incurred cost is determined by the Contractor’s accounting books and records, to which the Contractor shall provide access upon request of the Contracting Officer for administration of the clause. An acceptable job order cost accounting system (per DFARS 252.242-7006) is not required for reporting of incurred costs under this clause. If the Contractor’s accounting system is not capable of tracking costs on a job order basis, the contractor shall provide a realistic approximation of the allocation of incurred costs attributable to this contract in accordance with [GAAP] and the Contractor’s accounting system.


If the Contractor’s accounting system is not capable of identifying and tracking through the build cycle the property that is allocable and properly chargeable to the contract, the Contracting Officer may consider acceptance of one or a combination of the following forms of security … and so specify in the contract. [Five alternate forms of security are listed.]

In summary, the use of the Class Deviation solicitation provision and contract clause addresses our fundamental problems with recent DOD administration of PBPs. As such, we welcome their use.

As we noted at the beginning of this article, many acquisition professionals are uncomfortable with planning and/or negotiating PBP plans. We here at Apogee Consulting, Inc. are available to assist you. Why not give us a call?

Last Updated on Tuesday, 27 August 2019 17:51

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Effective January 1, 2019, Nick Sanders has been named as Editor of two reference books published by LexisNexis. The first book is Matthew Bender’s Accounting for Government Contracts: The Federal Acquisition Regulation. The second book is Matthew Bender’s Accounting for Government Contracts: The Cost Accounting Standards. Nick replaces Darrell Oyer, who has edited those books for many years.