Here at LRRI we consider fringe, overhead & fee proprietary and don't divulge to people we subcontract to, only directly to Federal sponsor.  We do that on both CPFF and FF contracts.  The fully loaded amount invoiced reflects the actual costs plus fixed fee for the period we are charging but we only give the bottom line cost for each line item.  The same holds true for people we sub to who are commercial, they submit the same way, so it shouldn't be a problem.  As long as their rates are reviewed and approved by DCAA there should be no problem with you accepting and paying fully loaded invoices.  If you have questions about their charges you can ask them to submit fully disclosed information directly to your federal sponsor for review.

Janet Holmberg
Grants & Contracts Specialist
Lovelace Respiratory Research Institute
505 348-9507

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Greg Schmidt
Sent: Wednesday, October 27, 2010 11:24 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Question: subcontract with Lockheed

No, you wouldn't, but that doesn't mean its a good idea to have the clause.

What they are trying to avid is showing things like their G&A on labor, contracts admin fee, overhead rates, etc.

Is the subcontract a CPFF type?  If so, they need to show the actual costs.  Sounds like they want to turn it into a FPC.

"Watkins-Wendell,Kathryn A" <xxxxxx@UAKRON.EDU> wrote:

>
>A Colleague has asked me to post this question to the Listserv:
>Please respond to Rebecca directly.  Thanks.
>Katie.
>
>
>" I'm in the process of finalizing a subaward contract with Lockheed Martin and they want wording in it that says: "Subcontractor shall not be required to include any elements of cost in its invoice to Prime Contractor; however, all such invoices shall be subject to audit by the US DCAA (Defense Contract Audit Agency." Our Budget Director who is in charge of contracts wonders if we wouldn't be violating federal circulars if we don't have the authority to review their books or even see supporting documentation. Have you had this situation before and, if so, how did you resolve it?"
>
>
>
>Rebecca Priest
>Senior Director of Emerging Technologies & Strategic Grants
>Stark State College
>6200 Frank Ave. NW
>North Canton, OH   44720
>Phone: 330.494.6170 Ext. 4319
>Fax: 330.305.6612
>Email: xxxxxx@starkstate.edu<mailto:xxxxxx@starkstate.edu>
>
>
>
>
>
>
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