![]() ![]() How else would this be charged if not to IRAD? I'm not up to speed on accounting practices (but need to get there quickly!). The 2018 DoD OTA Guide allows an OTA performer to use IRAD as an acceptable form of resource sharing (new term for 'cost share'). Reviews Mobile Apps Cobra iRadar 200 (for iPhone and Android) Review 3.0 Average By Jamie Lendino The Bottom Line Cobra's latest radar detector, the iRadar 200, offers a compelling. In any event, I believe it would be inappropriate to charge an OTA holder's cost share to IRAD based on the definition of IRAD in FAR 31.205-18 because that work is required by the terms of a "contract." Instead, they are commercial arrangements between the OTA holder and the subcontractor.Īs for your second question, look at the terms of the OTA. Because the FAR does not apply to contractors or OTAs, subcontracts issued under an OTA are not considered subcontracts under FAR covered contracts. The FAR does not apply to contractors, but only provides guidance to the government when conducting an acquisition. The FAR only applies to procurement contracts as described in FAR 2.101. Such common law contracts are not subject to the FAR. Under an OTA, is there anything that prohibits charging direct for the government funded portion of the work (to include fee) and indirect (to IRAD) for a cost sharing contribution? CAS should not apply to an OTA, so assume the rules that you can’t charge both direct and indirect to the same cost objective also do not apply.Īppreciate your thoughts on the above matters.Īn OTA is a common law contract just as a grant or cooperative agreement is a common law contract. I don’t see how we can be performing 90% of the work under an OTA arrangement and have our subcontract FAR based while our prime’s contract is not. Our prime has stated we have a subcontract under an OTA. Our prime is a small business who was awarded an OTA. Additionally, we will be performing 90% of the work under the OTA. Others say it’s an OTA subcontract because the subcontract contains OTA flowdown terms and the OTA terms are first in the order of precedence. I have a couple questions on OTAs and was hoping to get some feedback from the folks on this forum.Īre subcontracts issued under a Prime Contractor’s OTA considered an OTA also? Some folks say we have a standard subcontract because OTAs are only let by the Government to Primes and a Prime cannot let an OTA subcontract to a subcontractor.
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