NAVAIR Request for Information in regards to DFAR 252.204-7006, Billing Instructions-Cost Vouchers

Introduction and Overview THIS IS A REQUEST FOR INFORMATION ONLY. THERE IS NO SOLICITATION ASSOCIATED WITH THIS REQUEST. The Naval Air Systems Command (NAVAIR) is requesting information pertaining to Final Rule: Payment Instructions (DFARS Case 2017-D036) effective 25 May 2023 and to be implemented starting 1 Oct 2023. Specifically, the subject of this request pertains to the impacts of the following change: - paragraph (d)(12) of the Procedures, Guidance, and Information (PGI), which previously allowed the Contracting Officer to insert - other payment instructions, has been deleted. Therefore, use of payment instructions not outlined in the DFARS PGI is no longer authorized. The purpose of this RFI is to assess the predicted impact to industry of this change and to solicit industry inputs on potential alternative solutions. Background Financial reporting requirements are increasing in complexity due to DOD/NAVY's audit readiness programs. This amounts to traceability of funding from a variety of customers to the work being performed for those customers. Due to the large number of funding sources, appropriation types, and unique individual programs supported, the government's traditional service contract structures do not allow for a single fund line on each CLIN for sequential payment of ACRNS or prorated payment against all ACRNs. The principle method to ensure this traceability in all types of Naval Air Warfare Center-Aircraft Division (NAWCAD) Contracts and Task Orders was the utilization of - Technical Direction Letters and INFOSLINs combined with the NAVAIR Clause 5252.242.9502 Technical Direction (Variation) in Section H of the contract and the insertion of - other payment instructions by the Contracting Officer. The - other payment instructions, in accordance with the now deleted DFARS PGI 204.7108(d)(12), provided an accurate alignment of work completed and funds expensed. The tailored instructions allowed flexibility for payments to be made in accordance with shifting requirements and customer needs without the need of a bi-lateral contract modification to realign ceiling on CLINs and/or Sub-CLINs. Contractors were directed to identify the CLIN, SLIN, and ACRN on each invoice based on the unique customer funding requirement, PCO instructions, and/or Technical Direction Letter (TDL). The intention of this method was to reduce the complexity of the overall contract CLIN structure while maintaining the appropriate traceability of funding to the actual work performed. The deletion of DFARS PGI 204.7108(d)(12) - other payment instructions remove the ability of the Government to effectively utilize TDLs in structuring and financially administering the contract. Recent contracts issued by NAWCAD included a simplified CLIN structure by APPN and utilized TDLs with numeric INFOSLINs to provide segregation of funds and tasking. For example, using a single appropriation type: CLIN 0001 RDT&E Labor SLIN 000101 RDT&E Labor - Project - A/TDL 0001 SLIN 000102 RDT&E Labor - Project - B/TDL 0002 CLIN 0002 RDT&E Travel SLIN 000201 RDT&E Travel - Project - A/TDL 0001 SLIN 000202 RDT&E Travel - Project - B/TDL 0002 CLIN 0003 RDT&E Material SLIN 000301 RDT&E Material - Project - A/TDL 0001 SLIN 000302 RDT&E Material Project - B/TDL 0002 Theoretically, utilizing a requirement that provides services to 19 different funding sources, 5 different appropriation types, 5 years of performance using 1 base year and 4 option years, and three charge types (labor, travel, material), a requirement utilizing TDLs would result in 125 basic CLINs. With the deletion of the - other payment, a unique CLIN would be required for each configuration of purpose/project, appropriation, performance year, and type resulting in 1,425 unique CLINs by Line Of Accounting (LOA) as defined in DFARS 204.7103-1, to achieve the same level of fiscal traceability. RFI Response Instructions Responses to the RFI should be submitted electronically to amy.g.davis.civ@us.navy.mil no later than 1100, 21 AUG 2023. The information shall be submitted as UNCLASSIFIED. Do not submit any documents (letters, corporate statements or marketing information) other than the directly requested information. The Government may elect not to discuss submissions received in response to this RFI with individual responders or the collective summary of responses with Industry as a whole. Please complete and return the following RFI questionnaire in MS Word or .PDF format. 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. Provide a projected impact of the timeline for the preparation and submittal of invoices / cost vouchers Provide a project impact on the preparation and quality assurance activities associated with financial Contract Data Requirements List (CDRL) deliverables 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. Provide a projected impact on your financial management tools and processes to accommodate this change. 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. 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.