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[quote=Anonymous][quote=Anonymous][quote=Anonymous]To avoid a FAR Cost Accounting Standards violation, the FFRDC must consistently classify this new labor category (Direct vs. Indirect) and must update their estimates and disclosures. Failure to maintain this consistency and transparency risks significant cost disallowance.[/quote] I disagree with this conclusion. The risk of disallowance is high if that new labor category is [b]performing work similar to direct-charged FFRDC employees but is classified and accounted for differently[/b], especially if [b]it it exists in an organizational 'silo' with unique (and lower) indirect cost structures that the FFRDCs[/b]. Any inconsistent classification of costs, even in less extreme scenarios, is a direct CAS violation. Nobody with any common sense would sign off on this type of extreme arrangement in my experience.[/quote] I think GER is doing this.[/quote]
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