ACO CORB QUESTIONS AND ANSWERS
What are the responsibilities of an ACO? - Answer -The ACO should ensure that the
best interests of the Government are protected by ensuring the terms and conditions of
the contracts are appropriate. all parties execute the contract according to the terms
and condition
Examples of responsibilities of an ACO? - Answer -Conduct post award conferences,
negotiate forward pricing rate agreements, determine allowability of costs, establish final
indirect costs and billing rates, process novation and name change agreements, and
perform administrative closeout procedures.
What is the difference between an ACO and CA? - Answer -The ACO has a warrant
that binds the Government. The ACO's decisions and documents are binding. The CA
prepares documents up to signature but cannot bind the Government.
What is the relationship between the prime and subcontractor? - Answer -Privity - If the
Government has a contract with the prime contractor; there is privity of contract
between the Government and the prime. If the prime has a contract with its
subcontractors, privity of contract exists between the prime and its subcontractor. No
privity of contract exists between the Government and the sub (unless there is another
contract with them). If no privity, you cannot negotiate directly with the sub or direct the
sub to take any action.
Generally speaking how long are funds available before they cancel? - Answer -5 years
Who can authorize the use of Advanced Payments? - Answer -PCO
What is the difference between finance payments and invoice payments? - Answer -
Finance payments are payments made to a contractor prior to acceptance of
product/service, while invoice payments are made based on acceptance of
product/service.
Examples of financing payments - Answer -Progress Payments based on cost or
completion of work, Performance Based Payments, Advanced Payments or Interim
Payment/Voucher for cost type contracts.
What is the least preferred method of financing. - Answer -Advanced Payments
What would be reasons for an ACO to suspend or reduce progress payments? FAR
32.503-6, Clause 52.232-29 - Answer -1. Non-compliance with material requirement of
contract (ex. Approved Accounting system)
2. Unsatisfactory financial condition
3. Inventory in excess of contract requirements (unreasonable)
4. Failure to make adequate progress
5. Delinquent in paying subs
,6. Operating in a loss condition
What are Performance Based Payments? - Answer -Payments based on achievement
of specific, measurable events or accomplishments that are defined and valued in
contract. These events should be identified as cumulative or stand alone events, clearly
describe the events and how they will be validated, and the value for each accepted
event. • Not used for smaller contracts
Not used for contracts less than 6 months
What does it mean when it's said progress payments are self-liquidating? - Answer -
The Government recoups contract funds through the deduction of payment of invoices
at the time of completed contract line items. When invoicing for supplies/services, the
debt is paid by taking a percentage of the invoice. When the contractor submits a
progress payments on the DD1443 form the contractor will not bill for the amount of
there liquidating rate. The total billed amount will be added and totaled in WIP. Upon
delivery of the product, the contractor submits an invoice for the total amount of the
contract or line item and DFAS will empty the WIP amount recouping those funds and
paying and the amount billed minus the WIP amount for the total amount owed.
What are the ACO's responsibilities for Progress Payments? - Answer -1. Determine if
the use of progress payments are pratical
2. Ensure contractor meets FAR 32.104(d) requirements
a. Small business (90%)
i. can't bill for first delivery prior to 4 months
ii. exceeds SAT ($150,000)
iii. Demonstrates an actual financial need
b. Not a small business (80%)
i. Can't bill for first delivery prior to 6 months
ii. Contract price exceeds $2.5M
iii. Demonstrates an actual financial need
3. Ensure MOCAS Prog Pay Master is updated to reflect rates, distro, etc
4. Ensure progress payment requests (PPRs) are processed promptly
5. Validate and approve/disapprove all PPRs
6. Ensure Progress payments are limited to interim financing of non-commercial FFP
Contracts, orders or line items
PBP Steps - Answer -1. Identify PBP events (contractor proposed)
2. Establish completion criteria
3. Obtain/evaluate contractors expenditure profile
4. Establish event values
5. Determine the type of event: severable or cumulative
6. Incorporate PBP Arrangements into table/special provision
Criteria that should not be used for PBP's: - Answer -• Signing of a contract or contract
modification
, • Exercise of contract options
• The passage of time
• Attendance at meetings, conferences, seminars
• The expenditures of funds
• A surrogate for incurred costs
• Delivery of material, supplies or services via DD250
• Payment for cost-reimburseable line items
• Payment for goods or services
• Payment for partial deliveries
• An incentive arrangement
• Equal payment for each event/performance criteria
What is the difference between expiring vs canceling funds? - Answer -Expiring Funds
can no longer be obligated but can be used to pay contractors
Canceled funds can no longer be obligated or paid
Expiring Funds - Answer -can no longer be obligated but can be used to pay
contractors
Canceling funds - Answer -Canceled funds can no longer be obligated or paid
What are the ACO's responsibilities for PBP? - Answer -1. Determine if PBP is practical
2. Limit recommendation of new/revised events to parameters express by PCO
3. At no time negotiate/establish finance terms without written concurrence of PCO
4. Determine adequacy of accounting system
5. Process PBPs promptly (within 14 days)
6. Ensure functional specialists who provide PBP support follow contract/FAR/DFARs
7. Ensure PBPs not submitted more frequently than monthly
8. Ensure MOCAS has sufficient funds under ACRN
There are a large number of physically complete FFP contracts, upon reviewing the list
of contracts some are showing ULO's and negative ULO's. What would you do? Does
this concern you? - Answer -Yes this would concern me. FFP contracts should not
have money remaining at physical completion. I would start by reviewing the list to see if
there is a common thread such as the same contractor. I would then start a data
integrity review. I would start by reviewing MOCAS and WAWF, checking to make sure
the contractor has submitted a final invoice and all invoices have been paid. I would
want to check that no invoice was incorrectly paid by DFAS, I would review MOCAS for
any clues to why a invoice hasn't paid. Reviewing codes that DFAS inputs. A SDW pull
would also assist in the invoice reconciliation. I would then start a modification
reconciliation. Checking for any modifications that weren't processed correctly in
MOCAS especially deobligation mods or mods that are removing work from the
contract. One additional resource I would check is IWMS to see if there is any
documents filed in the record that might assist in figuring out what the problem is.
What are the responsibilities of an ACO? - Answer -The ACO should ensure that the
best interests of the Government are protected by ensuring the terms and conditions of
the contracts are appropriate. all parties execute the contract according to the terms
and condition
Examples of responsibilities of an ACO? - Answer -Conduct post award conferences,
negotiate forward pricing rate agreements, determine allowability of costs, establish final
indirect costs and billing rates, process novation and name change agreements, and
perform administrative closeout procedures.
What is the difference between an ACO and CA? - Answer -The ACO has a warrant
that binds the Government. The ACO's decisions and documents are binding. The CA
prepares documents up to signature but cannot bind the Government.
What is the relationship between the prime and subcontractor? - Answer -Privity - If the
Government has a contract with the prime contractor; there is privity of contract
between the Government and the prime. If the prime has a contract with its
subcontractors, privity of contract exists between the prime and its subcontractor. No
privity of contract exists between the Government and the sub (unless there is another
contract with them). If no privity, you cannot negotiate directly with the sub or direct the
sub to take any action.
Generally speaking how long are funds available before they cancel? - Answer -5 years
Who can authorize the use of Advanced Payments? - Answer -PCO
What is the difference between finance payments and invoice payments? - Answer -
Finance payments are payments made to a contractor prior to acceptance of
product/service, while invoice payments are made based on acceptance of
product/service.
Examples of financing payments - Answer -Progress Payments based on cost or
completion of work, Performance Based Payments, Advanced Payments or Interim
Payment/Voucher for cost type contracts.
What is the least preferred method of financing. - Answer -Advanced Payments
What would be reasons for an ACO to suspend or reduce progress payments? FAR
32.503-6, Clause 52.232-29 - Answer -1. Non-compliance with material requirement of
contract (ex. Approved Accounting system)
2. Unsatisfactory financial condition
3. Inventory in excess of contract requirements (unreasonable)
4. Failure to make adequate progress
5. Delinquent in paying subs
,6. Operating in a loss condition
What are Performance Based Payments? - Answer -Payments based on achievement
of specific, measurable events or accomplishments that are defined and valued in
contract. These events should be identified as cumulative or stand alone events, clearly
describe the events and how they will be validated, and the value for each accepted
event. • Not used for smaller contracts
Not used for contracts less than 6 months
What does it mean when it's said progress payments are self-liquidating? - Answer -
The Government recoups contract funds through the deduction of payment of invoices
at the time of completed contract line items. When invoicing for supplies/services, the
debt is paid by taking a percentage of the invoice. When the contractor submits a
progress payments on the DD1443 form the contractor will not bill for the amount of
there liquidating rate. The total billed amount will be added and totaled in WIP. Upon
delivery of the product, the contractor submits an invoice for the total amount of the
contract or line item and DFAS will empty the WIP amount recouping those funds and
paying and the amount billed minus the WIP amount for the total amount owed.
What are the ACO's responsibilities for Progress Payments? - Answer -1. Determine if
the use of progress payments are pratical
2. Ensure contractor meets FAR 32.104(d) requirements
a. Small business (90%)
i. can't bill for first delivery prior to 4 months
ii. exceeds SAT ($150,000)
iii. Demonstrates an actual financial need
b. Not a small business (80%)
i. Can't bill for first delivery prior to 6 months
ii. Contract price exceeds $2.5M
iii. Demonstrates an actual financial need
3. Ensure MOCAS Prog Pay Master is updated to reflect rates, distro, etc
4. Ensure progress payment requests (PPRs) are processed promptly
5. Validate and approve/disapprove all PPRs
6. Ensure Progress payments are limited to interim financing of non-commercial FFP
Contracts, orders or line items
PBP Steps - Answer -1. Identify PBP events (contractor proposed)
2. Establish completion criteria
3. Obtain/evaluate contractors expenditure profile
4. Establish event values
5. Determine the type of event: severable or cumulative
6. Incorporate PBP Arrangements into table/special provision
Criteria that should not be used for PBP's: - Answer -• Signing of a contract or contract
modification
, • Exercise of contract options
• The passage of time
• Attendance at meetings, conferences, seminars
• The expenditures of funds
• A surrogate for incurred costs
• Delivery of material, supplies or services via DD250
• Payment for cost-reimburseable line items
• Payment for goods or services
• Payment for partial deliveries
• An incentive arrangement
• Equal payment for each event/performance criteria
What is the difference between expiring vs canceling funds? - Answer -Expiring Funds
can no longer be obligated but can be used to pay contractors
Canceled funds can no longer be obligated or paid
Expiring Funds - Answer -can no longer be obligated but can be used to pay
contractors
Canceling funds - Answer -Canceled funds can no longer be obligated or paid
What are the ACO's responsibilities for PBP? - Answer -1. Determine if PBP is practical
2. Limit recommendation of new/revised events to parameters express by PCO
3. At no time negotiate/establish finance terms without written concurrence of PCO
4. Determine adequacy of accounting system
5. Process PBPs promptly (within 14 days)
6. Ensure functional specialists who provide PBP support follow contract/FAR/DFARs
7. Ensure PBPs not submitted more frequently than monthly
8. Ensure MOCAS has sufficient funds under ACRN
There are a large number of physically complete FFP contracts, upon reviewing the list
of contracts some are showing ULO's and negative ULO's. What would you do? Does
this concern you? - Answer -Yes this would concern me. FFP contracts should not
have money remaining at physical completion. I would start by reviewing the list to see if
there is a common thread such as the same contractor. I would then start a data
integrity review. I would start by reviewing MOCAS and WAWF, checking to make sure
the contractor has submitted a final invoice and all invoices have been paid. I would
want to check that no invoice was incorrectly paid by DFAS, I would review MOCAS for
any clues to why a invoice hasn't paid. Reviewing codes that DFAS inputs. A SDW pull
would also assist in the invoice reconciliation. I would then start a modification
reconciliation. Checking for any modifications that weren't processed correctly in
MOCAS especially deobligation mods or mods that are removing work from the
contract. One additional resource I would check is IWMS to see if there is any
documents filed in the record that might assist in figuring out what the problem is.
