Quick Hitter: DFARS Part 231

Just as with my Quick Hitters with the FAR and GSAR, my Quick Hitter on the DFARS is meant to simplify contracting business with the government. This time with DoD.

DFARS 231.205-70 External Restructuring Costs

This part defines allowable and unallowable costs on DoD contracts. That is not an outlier in DoD, but this subpart is.

Scope

DoD is allowed to externally restructure costs if it saves them money. Examples include relocating plants or equipment. Projected savings must be at least double the cost (10 U.S.C. 3761).

Allowability

This DoD specific regulation must not limit R&D costs and costs of proposal preparation. Make sure to know what applies to foreign contracting.

For major contractors (>$11M) to be approved for allowable costs, they must report R&D costs on DTIC, and update DTIC annually (NLT 3 mo. after contractor’s fiscal year ends) as well as after the project is completed.

R&D Costs

These costs should not exceed what has been deemed allowable by the CO as well as those of similar scope. They must match current and future plans of DoD.

Non-Major Contractors

They are encouraged to report R&D in DTIC to educate DoD on technical aspects of the project. Costs of R&D/B&P costs are not reported as indirect costs.

We were taught allowable costs at the VA Acquisition Academy. These are determined by your CO. Federal regulations lay them out clearly.

I’ve heard stories about this being a very heated topic between the government and its contractors. Not if you read the FAR.

If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation. 

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