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B-202254 1 (1981-05-19)

handle is hein.gao/gaobabjcg0001 and id is 1 raw text is: 

                     UNITED STATES GENERAL ACCOUNTING OFFICE
                             WASHINGTON, D.C. 20548


OFFICE OF GENERAL COUNSEL
                                     May 19, 1981
        B-202254




        Mr. James T. Brannan
        Director
        Defense Acquisition Regulatory Council
        Office of the Under Secretary of Defense
        for Research and Engineering

        Dear Mr. Brannan:

           By letter of February 17, 1981, you requested our
        ments on proposed modifications to per-ag-r-a-h-E-5-2-1
        efr-the Defense Contract Financing RegulationsJ(Defense
        Acquisition Regulation Appendix E),regarding milestone
        billing arrangements. -3

           LThe purpose of a milestone billing arrangement is to
        alleviate inordinately high contractor financing that
        would otherwise result by limiting payments to custom-
        ary progress payments in the performance of a defense
        contract with exceptionally long lead time between ini-
        tiation of contract performance and commencement of
        deliveries of contract end items. The stated objective
        of the proposed changes is to assure greater consistency
        in the application of such arrangements to individual
        contracts.:-

           CWe believe that the proposed modifications represent,
        for the most part, an improvement over the existing regul-
        ations. However, in our opinion, the proposed rules do
        not provide adequate guidance on the important concept of
        contractor investment.D The stated policy of the Depart-
        ment of Defense is that contractors should maintain an
        appropriate level of investment in their contract work-
        in-process inventories at all times. In this regard,
        authorities responsible for approving milestone billing
        arrangements will evaluate each request on its individual
        merits with this DOD policy in mind. Specifically, the
        proposed revision provides that:

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