When using R&D 3600 funds does the different type of work being completed and provided for need to be separated by separate CLINs for 6.1 through 6.7 funding or can it be included on one CLIN? How must the work be separated on the contract or can it all fall under one CLIN since it is still 3600 funding?
The following response is based solely on the question and background information provided. As we do not have all the facts particular to your situation, we highly recommend you consult, as applicable, your contracting officer, Comptroller/BFM, and/or Legal Office for further guidance.
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The question revolves around R & D 3600 funds having to be separated by different CLINs for 6.1 through 6.7 funding. There are two different perspectives that are identified below:
From a contracting perspective:
Separate CLINs for separate deliverables
DFARS 204.7103-1 Criteria for establishing.
Contracts shall identify the items or services to be acquired as separate contract line items unless it is not feasible to do so.
(a) (4) Single accounting classification citation.
(i) Each contract line item shall reference a single accounting classification citation except as provided in paragraph (a)(4)(ii) of this subsection.
(ii) The use of multiple accounting classification citations for a contract line item is authorized in the following situations:
(A) A single, nonseverable deliverable to be paid for with R&D or other funds properly incrementally obligated over several fiscal years in accordance with DoD policy
From a Financial Management perspective:
The budget exhibits that you submit to Congress each year provides the explanation of the use of the funds that will be appropriated. The budget exhibits for RDT&E are detailed down to the Program Element Number. The particular purpose of those funds will be described within the narrative of the different RDT&E budget exhibits. The important point to remember is that the Statement of Work (if identified in each CLIN) would be the reason to separate down to the CLIN level instead of at the major contract level.