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CMC200 FEES, FINANCING, AND PAYMENTS
CMQ101 - Course Introduction 9/17/2018 CMC200 FEES, FINANCING, AND PAYMENTS Module 3: Contracts with Interim Financing Lesson 2: Contracts with Interim Financing through Performance-Based Payment Requirements
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Lesson 3 Introduction: TLO
Given a Government contract and/or modification(s) with interim financing through Performance-Based Payments, correctly apply Performance-Based Payment requirements as needed. Graphic: business men and women reviewing a document together. 2
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What’s In It For Me (WIIFM)
This lesson will provide you with basic information to perform contract administration on contracts with Interim Financing through Performance-Based Payment requirements. Graphic: accounting documents, pen, and calculator. 3
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Lesson 2: ELOs Given a Government contract and/or modification(s), with performance-based payments, correctly determine contractor and contract eligibility. Given a Government contract and/or modification(s) with performance-based payments, correctly perform risk assessment. Given a Government contract and/or modification(s) with performance-based payments, correctly apply performance- based payments. 4
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Lesson 2 Topics Eligibility Contract Administration and Procedures
Risk Payment, Verification, and Controls
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Topic 1: Eligibility Eligibility
Contract Administration and Procedures Risk Payment, Verification, and Controls
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Why Financing? Graphic: screenshot of FAR website. 7 7
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Performance-Based Payments (PBP)
Provide financing to contractors performing under fixed-price, non-commercial contracts, or fixed-price items on a mixed type contract Paid based upon contractor performance of definitive criteria uniquely established in each contract Represent expenses that the contractor could reasonably be expected to incur in order to achieve completion of each defined criteria or event 8
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PBPs, Cont. PBPs are NOT: Advance Payments
Payments for deliverable goods or services Government acceptance of contract deliverables Inducements to contractors to achieve performance levels that exceed contract requirements For services Graphic: hands exchanging money. 9
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CMQ101 - Course Introduction
9/17/2018 Knowledge Review What accurately describes PBPs? (Select all that apply.) Provide financing to contractors performing under fixed-price, non-commercial contracts Paid based upon contractor performance A method of Advance Payments Government acceptance of contract deliverables 10
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Authority to Use PBPs FAR Subpart 32.10: Performance-Based Payments
FAR (a): Policy-- Performance-Based Payments are the preferred Government financing method when the CO finds them practical, and the contractor agrees to their use Clause at FAR : Performance-Based Payments Graphic: small screenshots of FAR clauses. 11
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PBP Policy IAW DFARS 232.10: Performance-Based Payments
PBPs never exceed total cost incurred The CO will consider the contractor’s accounting system beforehand IAW DFARS PGI (a): Contracting Officer Action, PBPs-- Are not practical for all fixed-price contracts Require considerable effort between the contractor and Government 12 12
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PBP Clauses Cumulative PBPs shall not exceed cumulative incurred contract costs. Graphic: Screenshot from FAR website. 13 13
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When Are PBPs Used? Large business: contract is valued at or greater than $2.5M Small business: contract is valued over the simplified acquisition threshold - now $150K Contractor is not expected to be able to bill for delivery of products for substantial time after work begins: Large business – normally six months Small business – normally four months Graphic: paper money and dollar signs. 14
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Benefits Benefits to contractor: Improved cash flow
Reduced costs of oversight and compliance Management team focus on technical and schedule progress Benefits to Government: Oversight and compliance costs may be reduced Risk of overpayment may be reduced Graphic: paper money and US capitol building. 15
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Risks Risks to contractor:
No payment if PBP event not successfully completed Usually bears risk for property loss, theft, destruction or damage Comparable to Progress Payment requirement Potential risks to Government: Poor completion events Poor completion criteria Event values not commensurate with milestone activities Front loading of event values 16
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PBPs and PPs: Similarities
Criteria for eligibility – FAR (d)(2)&(3): 2.5M or greater for large business Over 150k small business (simplified acquisition threshold) Fixed-price contracts, fixed-price CLINs on mixed-type contracts Recoverable in case of default
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PBPs and PPs: Differences
Basis for payment: PP: 80% of actual incurred costs PBP: Predetermined estimated amount on milestone events not to exceed actual costs Entitlement to Payment: PP: Submission of allowable costs commensurate with progress made PBP: Successful and verifiable completion of performance events Profit: PP: excluded PBP: Some allowed before April 1, 2014.
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PBPs and PPs: Differences, Cont.
Accounting system: PP: must be approved PBP: consider the adequacy of the accounting system Frequency of payment: PP: not more than monthly PBP: not more than monthly, may have more than one event per month Alternate liquidation rate: PP: yes, under certain circumstances PBP: not available
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CMQ101 - Course Introduction
9/17/2018 Knowledge Review Which of these instances is not a requirement for PBPs? Large business isn’t able to bill for twelve months Large business contract valued at or over $2.5 million Small business contract is valued over $150K Small business does not have deliveries for four months 20
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Defense Procurement Acquisition Policy Guidance
OSD/AT&L Memo – Policy and Guidance on Performance-Based Payments (04/17/2014) The primary focus of the policy is to ensure that Performance-Based Payments (PBP) are used in a manner that offers a win-win scenario to the contractor and the Government. The PBPs Guide and the DoD PBP Analysis Tool have been updated for the current policy, and are located on the DPAP website at: Graphic: Screenshot of a memo. 21 21
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PBP Clauses At no time shall cumulative PBPs exceed cumulative incurred contract costs. DFARS – Performance-Based Payments – Whole Contract Basis DFARS – Performance-Based Payments – Deliverable Item Basis 22 22
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Flippant: Description and Task
CMQ101 - Course Introduction 9/17/2018 Flippant: Description and Task Open: ‘Eligibility Flippant Group – Student’ from Blackboard. Complete the assignment in the time provided. Discuss with the class. 23
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Gross: Description and Task
Open: ‘Eligibility Gross Individual– Student’ from Blackboard. Complete the assignment in the time provided. Discuss with the class. 24
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Topic 2: Contract Administration and Procedures
Eligibility Contract Administration and Procedures Risk Payment, Verification, and Controls
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Steps Toward Incorporation of PBP Milestones
PCO confirms that both contract and contractor are PBPs eligible Contractor provides proposed PBP milestones to the PCO to negotiate PCO enlists ACO to help: Not mandatory, but highly recommended ACO reviews milestones to ensure they meet the FAR requirements PCO incorporates the milestones: Into the basic contract Per bilateral modification to the contract Adds FAR Clause (if not in the basic contract)
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ACO Negotiation of PBPs
PCO may delegate negotiation of: Performance criteria Successful event completion Event value Board of review at DCMA Region level The ACO may renegotiate a contract PBP schedule, with PCO concurrence, when a Government-caused delay (e.g., stop work orders, change in scope, failure to provide Government furnished material) prevents completion of individual events 27
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PBP Procedures: FAR 32.1004(b): Establishing Performance-Based Payment Amounts
The CO prior to adding Performance-Based Payments to a contract must : Establish a complete, fully defined schedule of events or performance criteria and payment amounts when negotiating contract terms Adjust the PBP schedule appropriately if a contract action significantly affects the price, event or completion criterion What We Found Contracting personnel did not properly evaluate and negotiate schedules. Specifically, they did not: • establish appropriate events for 1,807 events out of 2,356 total events on 57 approved Performance-Based Payment schedules, and determine whether the event value fairly represented contract performance for 44 schedules; • clearly define the criteria for successful completion in 33 schedules, identify events as severable or cumulative in 23 schedules, and specify completion dates in 21 schedules; DODIG 28
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PBP Procedures: Three Key Steps
Establish appropriate and verifiable payment events Accurately define event completion criteria Determine commensurate payment event values The contractor will have adequate cash flow The contractor will have appropriate levels of motivation Achieving the payment events will lead to successful completion of the contract Graphic: Paper money exchanging hands. 29
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Requirements for Good Criteria
Establishing appropriate PBP criteria requires: Thorough knowledge of product and processes required to build product Coordination between: Customer and DCMA Technical and business communities Graphic: Group of people sitting at a table having a discussion. 30
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Requirements for Good Criteria: FAR 52
Requirements for Good Criteria: FAR : Invitation to Propose Performance-Based Payments Graphic: Screenshot from FAR websute. 31
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What is a Payment Event? A PBP event:
Entitles the contractor to receive a performance-based financing payment after verification that an activity has been successfully completed during the performance of a contract Represents: Pre-planned definitive milestone toward contract completion Right item, right time, right price True value added Events structured on whole contract or line item basis 32
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Milestone Examples Inappropriate Milestone Examples:
Milestone 1: Kick-off Meeting $5, Approx. 3/31/14 Milestone 2: Place POs $9, Approx. 3/31/14 Appropriate Milestone Examples: Milestone 3: Receipt of 90% of Bill of Material Value (all critical parts delivered) Milestone 4: Completion of Subassembly $41, Approx. 7/31/14 $20, Approx. 10/31/14 33
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Milestone Example: Appropriate
CMQ101 - Course Introduction 9/17/2018 Milestone Example: Appropriate Graphic: Example of an appropriate milestone. 34
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Number of Events No magic number More events not necessarily better
Should be selected to: Provide adequate cash flow for contractor – monthly events not necessary Reduce administrative effort for contractor and Government 35
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Types of Events IAW FAR 32.1004(a)(2): Establishing Performance Basis
PBP events may be: Severable: Execution independent of any other event Payment independent of any other event Cumulative: Dependent upon accomplishment of previous event Cannot be paid until the last dependent event successfully completed Contract milestone schedule may include severable and/or cumulative events 36
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Types of Events Cumulative Assembly Series
2 1 6 4 5 3 Severable Events Cumulative Events Aircraft Delivery * Rough Machining of MLG Bulkhead Frames Receipt of Aft Pressure Bulkhead Details Completion of Wing Spars Completion of Wing Spars Completion of Wing Halves Cumulative Assembly Series Completion of Four Major Sub-Assemblies Completion of Final Assembly *Aircraft Delivery – Delivery not a PBP event. All PBPs are liquidated by deducting them from delivery payment. 37
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Types of Events: Sample of Milestone Event Schedule
Graphic: Excerpt Performance-Based Payment Event Matrix from a contract. 38
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Payment Milestones Clear milestones:
May represent a physical change in the product Shall indicate added value Shall not be surrogates for incurred costs May not exceed incurred costs Graphic: Checklist with first item checked, pen. 39
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Payment Events Appropriate payment events – those indicating:
Receipt of material Product leaving fabrication Completion of first article testing Completion of a sub assembly Machining, forging, or fabricating parts Graphic: Red checkmark and red pencil. 40
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Payment Events, Cont. Inappropriate payment events – those indicating:
Typical administrative actions: Signing of contract or modification Attendance at management system review Passage of time or incurring of costs: 6 months before delivery 100,000 hours charged to work order 90% of actual costs incurred prior to payment Other: Initiate testing of software Initiate machining Graphic: Woman sitting at a desk writing on a document. 41
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Classroom Discussion We have received a contract that involves paying the contractor for CLINs in accordance with the following payment schedule. The PCO asks you to review the terms and provide comments. Payment Event % CLIN Price Cumulative % 1. Aircraft enters paint 75% 2. Acceptance of Aircraft (DD 250) 25% 100% 42
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Classroom Discussion, Cont.
What are the problems with the proposed terms of this payment schedule? What corrections do you recommend? Payment Event % CLIN Price Cumulative % 1. Aircraft enters paint 75% 2. Acceptance of Aircraft (DD 250) 25% 100% 43
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Event Completion Criteria
Be flexible when developing completion criteria. Establishing successful PBP event completion criteria: Understand product and processes Describe event completeness clearly and thoroughly in the contract Successful completion of event must be: Readily measurable and verifiable Identified in the contract with a detailed description of what constitutes successful performance of the event 44
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Completion Criteria Example (Simple)
Simple completion criteria: Event: APU Engine Delivery Completion Criteria: Subcontractor delivery of APU engine to prime contractor. The APU Engine must be delivered and accepted defect free. Graphic: Man standing at a board, drawing a circle graph while talking to another man sitting at a table. 45
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Completion Criteria Example
Complex completion criteria: Event: Belly Skins & 820 Bulkhead Complete Completion Criteria: Remove skins 11 L&R and 18 L&R. Repair and/or replace substructure as required . Re-install skins 11 L&R and 18 L&R. Remove and replace (R&R) left and right station 820 bulkhead fitting in accordance with Service Bulletin (SB) 2912 if required. Skins 11 L&R & 18 L&R must be removed and reinstalled permanently, cargo doors and landing gear must be removed. Event 1 shall be complete. (Cumulative event) 46
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CMQ101 - Course Introduction
9/17/2018 Knowledge Review PBP events may be: (Select all that apply.) Independent of any other event Dependent on incurred costs Dependent on accomplishments of previous events Paid before dependent events are completed 47
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Event Completion Criteria
The Government has a contract with a manufacturer of medium-sized trucks who uses a standard automotive assembly line approach Using the four-event criteria, develop event completion criteria: Sample Event # 1 Completion Criteria: 100% of critical parts received, and 90% of remaining material received Event #1: Material Received Event #2: Cab Assembly Completed Event #3: Engine Installed Final Delivery Event #4: Wheels Attached 48 48
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Event Completion Criteria, Cont.
Event #1: receive material: Event completion criteria: 100% of critical parts received 90% of remaining material Event #2: Cab assembly completed Event #3: Engine installed Event #4: Wheels attached Event #1: Material Received Event #2: Cab Assembly Completed Event #3: Engine Installed Final Delivery Event #4: Wheels Attached 49
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Event Value Rules and Restrictions
Payment amount must be clearly defined in the contract IAW FAR (b)(3): Establishing Performance-Based Finance Payments Amounts: The contract shall state the amount of each PBP as either a dollar amount or a percentage of the identified price The PBP amounts are commensurate with the values of the performance events IAW FAR (c)(2): Invitation to Propose Performance- Based Payments — the PBPs are limited to: 90% of contract price, if on whole contract basis 90% of delivery item price, if on delivery item basis 50
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Notional Aircraft Cost Profile
Event Value Rules and Restrictions: Performance Events with PBP Billing Percentages Graphic: Example graph showing Notional Aircraft Cost Profile against Quarter Mid-points. Aircraft Delivery Notional Aircraft Cost Profile 51
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Event Value Rules and Restrictions, Cont.
When the Performance-Based Finance amount is established on a deliverable line item basis, each event or completion criterion must be part of the performance necessary for that deliverable item. Graphic: Large golden dollar sigh, several contract pages. 52
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Event Value Rules and Restrictions
All payment amounts must provide for liquidation upon delivery IAW FAR (d): Liquidating Performance-Based Finance Payments Performance-Based Financing payments must be liquidated by deducting either a percentage or a designated dollar amount from delivery payments DFAS will make deductions Payment requests can only be submitted once in any given calendar month Each request can, however, cover payment for multiple events 53
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PBP Schedule Requirements
CMQ101 - Course Introduction 9/17/2018 PBP Schedule Requirements Event # Event title or description Event value Cumulative or severable: If cumulative – list of prior events Line item – if PBP are on a line item basis Fund type Event completion criteria Event completion date Graphic: Man standing at a board, talking towards audience. 54
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Review the Contract IAW FAR (c): Criteria for Use-- Contracts cannot provide both Progress Payments and PBPs If contract provides for both Progress Payments and PBPs: Issue a CDR in EDA to request a modification to correct the contract A BOA may have both clauses listed but the order can only include one type of financing Graphic: File folder and form. 55
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Review the Contract, Cont.
Event payment amount must be clearly defined in contract, provided as either: Dollar value Percentage of negotiated total CLIN amount PRODUCTION UNITS CLIN ACRN Description Event Acceptance Location % $ $ Total CLIN 0100AB AB Inventory in-house Severable Review of invoices by DCMA QA Origin 29.74% $277,029.16 $931,503.57 Receipt of Short-lead materials (QTY. 20) 19.32% $179,966.49 Completion of K-10 Trailer IAW Drawing 3847AS300 40.94% $381,357.56 56
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Review MOCAS Inputs Compare information in contract/modifications to MOCAS data. Entering rates into MOCAS automatically generates special provisions code C - Performance-Based Payments Authorized. This code cannot be deleted. Standard ACO Coded Remark (R9) 38 – Performance-Based Payments Enter contract ceiling, payment and liquidation rates on the Provisions Data Record, or line item data inquiry as appropriate 57
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Review MOCAS Inputs: PBP Rates in MOCAS
Graphic: MOCAS screenshot. N C6255 58
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Review MOCAS Inputs: PBP CLIN
Graphic: MOCAS screenshot. N C6255 59
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Knowledge Review Who is responsible for ensuring that payment instructions are entered correctly in MOCAS? PCO ACO Industrial Specialist DCAA 60
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Post Award Orientation Conference (PAOC)
ACO determines need for PAOC Does contractor plan to invoke PBP clause? Ensure all parties understand: What the events are How the events are determined to be completed What value is associated with each event Payment and liquidation process Graphic: Three people working together on a document. 61
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Topic 3: Risk Eligibility Contract Administration and Procedures Risk
Payment, Verification, and Controls
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Risk Management Review key contractor processes to determine if they are adequate to calculate, prepare, and substantiate PBPs: Management of PBP request preparation and submittal Contractor’s financial condition Contractor’s accounting system Graphic: photo of a calculator. 63
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Risk Management IAW FAR 32
Risk Management IAW FAR (c): Administration and Payment of Performance-Based Payments The ACO: Determines what reviews are required for protection of the Government’s interests Considers the contractor’s experience, performance record, reliability, financial strength, and the adequacy of controls for the administration of PBPs Requests post-payment reviews and verifications based upon the risk to the Government Graphic: group of people sitting at a table working on documents. 64 64
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Risk Management IAW FAR 32
Risk Management IAW FAR (c): Administration and Payment of Performance-Based Payments, Cont. The ACO needs to consider: Pre-award survey Development of PBP terms Post-Award Orientation Conference Type of technical evaluations/validations that must occur DCMA Surveillance plan Graphic: person sitting at a desk, looking at a document, recording voice notes. 65
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Risk Management Resources
MOCAS Technical reviews and event completion evaluation Review and approval of PBP Request Liquidation application and adjustment, if appropriate Payment verification/validation Graphic: photo of three people working in an office setting. 66
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Risk Management: Document Retention
The ACO should retain the following documentation: PBP transactions and correspondence Reports and information (e.g., from DCAA, DACO, other ACOs, and officials, etc.) Risk analysis Risk monitoring results Recommend use of DCMA Form 325 – Contract Financing Administrative Record Updates as applicable Graphic: people working together on documents at a table. 67
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Risk Management: Potential Increased Risk Situations
Exceeding incurred costs Liquidation errors Reduction or suspension of PBPs -- refer to FAR : Suspension or Reduction of Payments Conversions from Progress Payments to PBPs Graphic: contract cartoon character holding a red flag. 68
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Simpleton: Description and Task
Open: Risk Simpleton Group – Student Blank DCMA Form 325 Complete the assignment in the time provided. Discuss with the class. 69
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Clandestine: Description and Task
CMQ101 - Course Introduction 9/17/2018 Clandestine: Description and Task Open: Risk Clandestine Individual – Student Blank DCMA Form 325 Complete the assignment in the time provided. Discuss with the class. 70
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Topic 4: Payment, Verification, and Controls
Eligibility Contract Administration and Procedures Risk Payment, Verification, and Controls
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PBPA058 Payment Submittal
The contractor should assign a properly structured 7-character, alphanumeric invoice/shipment number on each PBP request. PBPA: 4 character prefix for US funded PBPB: 4 character prefix for FMS funded; also must include break-out by country code Last 3 characters are numeric and should be sequentially numbered, e.g., PBPA001, PBPA002 PBPA058 72
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Payment Submittal, Cont.
IAW FAR (m): Content of Contractor’s Certification — Performance-Based Payment request must include contractor certification. Key points for certification: Prepared from contractor’s books and records Subcontractors have been paid No encumbrances that impair Government’s title No adverse change in financial condition Signature Graphic: hand writing on documents with a pen. 73
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PBP Clauses DFARS 252.232-7012 and 252.232-7013
Graphic: form from DFARS 74
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Verification Total incurred costs ($315,000) are greater than negotiated value of PBP events ($244,550). ACCEPTABLE Graphic: form from DFARS 75 75
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Verification, Cont. Total incurred costs ($225,875) are less than negotiated value of PBP events ($244,550). Contract will be paid only $6,375 which is smaller than the entire event amount. Graphic: form from DFARS 76 76
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Request Review and Approval
Designated government official Confirms completed payment event Provides findings to ACO ACO verifies: Receipt of documentation Amount is less than or equal to incurred cost ACO approves or rejects Graphic: stamp with red text, ‘REJECTED’, and blue text, ‘APPROVED’. 77
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Payment Controls FAR 52.232-32(c)(2): Approval and Payment of Requests
Payment under PBP clause is a contract financing payment under Prompt Payment clause and not subject to interest penalty provisions. Graphic: several contract pages sitting on a desk top. Two pens. 78
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Payment Controls DFARS Subpart 232.10 – PBPs, 232.1001(d) - Policy
The CO shall use the later of the following standard prompt payment terms for PBPs: The contractor entitlement, if any, specified in the contract 14 days after receipt by the designated billing office of a proper request for payment Graphic: Man sitting at a desk looking at a computer monitor. 79
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PBP Withholds Graphic: stamp with red text, ‘REJECTED’, blue text, ‘APPROVED’. 80
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DFAS Rejections DFAS does not automatically notify ACO of payment rejection. Forms of notification: Contractor notifies ACO directly CA/ACO reviews payment in MOCAS CA/ACO reviews payment in iRAPT Recommendation: ACO should recheck iRAPT 10 days after initial payment approval for payment status Graphic: woman sitting at a desk on the phone, while reviewing documents. 81
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PBP Request Transmission
ACO maintains the working copy of requests that have been manually processed in the official contract file in IWMS iRAPT maintains electronically submitted requests Prompt standard payment terms for PBP payment submittals are 14 days after DFAS receives a proper request for payment. Graphic: close up photo of hands typing on a computer keyboard. 82
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CMQ101 - Course Introduction
9/17/2018 Knowledge Review How many days after receiving a proper request shall the Government pay the contractor’s PBP? 7 14 21 30 83
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Validate Payment Verify successful PBP disbursement in MOCAS:
MOCAS YINV – invoice inquiry screen MOCAS YCPM – contract payment modernization SDW COGNOS 10 Finance and Payment eTool Did appropriate ACRN distribution occur? Were special payment instructions followed by payment office? MOCAS PGI II Brief located in Bulletin Apr 2013 Incorrect payment requires DCMA Form 1797 submitted to DFAS for correction 84
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Disbursement Data Verification/Recording
CMQ101 - Course Introduction 9/17/2018 Disbursement Data Verification/Recording The contract disbursement history inquiry screen in MOCAS is another method used to view disbursement data. Graphic: MOCAS screenshot C6255 85
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Suspension or Reduction of Payments: FAR 32
Suspension or Reduction of Payments: FAR : Suspension or Reduction of Performance-Based Payments The ACO may reduce or suspend PBPs: When contractor: Fails to comply with material requirement of the contract Fails to progress Becomes financially unsound Is delinquent in paying subcontractors Uses disapproved business systems When PCO requests Graphic: individual sitting at a desk reviewing documents. 86 86
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Notification ACO should notify the PCO if contractor:
Fails to meet scheduled performance event Jeopardizes contract completion due to financial deterioration Enters into a financial agreement encumbering property title Graphic: individual sitting at a desk, typing on calculator, on the phone. 87
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Martin Mfg.: Description and Task
CMQ101 - Course Introduction 9/17/2018 Martin Mfg.: Description and Task Open: PBP Event Assessment Martin Mfg. Group – Student PBP Event Assessment Martin Mfg. Events Group – Student PBP Event Assessment Martin Mfg. Expenditure Profile Group Complete the assignment in the time provided. Discuss with the class. 88
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XYZ Corp.: Description and Task
CMQ101 - Course Introduction 9/17/2018 XYZ Corp.: Description and Task Open: ‘PBP Schedule XYZ Individual – Student’ from Blackboard. Complete the assignment in the time provided. Discuss with the class. 89
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CMQ101 - Course Introduction
9/17/2018 Questions? Graphic: two red dice, text ‘Q & A’. 90
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CMQ101 - Course Introduction
9/17/2018 Lesson Summary Graphic: screenshot from FAR website, gold dollar sign, graph, paper money and capitol building. 91
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CMQ101 - Course Introduction
9/17/2018 Up Next Graphic: Contract cartoon character holding a pencil. Text, ‘NEXT’. Reconciliations
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