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B-173639 1 (1971-10-13)

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                      COMPTROLLER GENERAL OF THE UNI1 'IT9!0
                                WASHINGTON. D.C. 20348
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   B-173639                                                OCT 1    1
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   Dear Senator Dominick:

        By letter dated July 8, 1971, you requested that we provide you
   with a report on our reactions to certain Department of Transport'tion
   cost accounting procedures. Your letter enclosed copies of letters to
   you from Mr. 0. E. Bartoe of Ball Brothers Research Corporation and from
   the Office of the Secretary of Transportation concerning the Department's
   policy on allowable costs under prime contracts for systems management.

        Mr. Bartoe, in his letter to you, expressed his concern that the
   Department of Transportation was deviating from uniform Government pr-
   curement practices in a manner which could result in (I) a contractor
   not recovering all reasonable and necessary costs associated with a con-
   tract, or (2) an inequitable allocation of a contractor's costs among its
   various customers. Mr. Bartoe's concern arose from a provision in a
   request by the Department for proposals for management services which
   stated:

        It is the governments desire to subcontract as much of
        the effort as possible. In addition, the Department of
        Transportation does not wish to pay the prime contractor
        a fixed fee, overhead or G&A charges on subcontract work.
        In order to benefit from the contractor's organization,
        a fixed amount or nominal charge arrangement may be con-
        sidered against subcontracts.

        Department officials advised us that this provision was not included
   in the request in an attempt to preclude any contractor from recovering
   the reasonable and necessary costs associated with a contract. They stated
   that the provision was included because of the Department's recognition
   that the type of systems management contract it planned to award varied
   considerably from conventional research and development type contracts--
   which call for extensive in-house effort--and that under the planned con-
   tracting arrangements, up to 80 percent of the total prime contract dollars
   would relate to subcontractors' work. The Department has indicated that a
   considerable portion of a contractor's indirect costs, necessary and rea-
   sonable to support in-house work, would not be of direct benefit in the
   management of the subcontracts, and has concluded that, if it followed
   the normal contracting practice of applying a standard fixed rate to sub-
   contract dollars for a contractor's overhead and general and administrative
   expense, a very substantial and unwarranted additional cost to the Govern-
   ment would be incurred.






                           50T H ANNIVERSARY 1921-1971-

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