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  • Question

    Can the cost for closeout efforts incurred after the POP be billed to the government and paid to the contractor? Regardless of the contract being a Term or Completion type?


    Answer

    Costs for closeout efforts after the POP can be billed to the government provided they are allowable and relevant to the contract effort. For example, FAR 4.804-1 gives the time standards for closing out different types of contracts. A cost contract should be closed within 6 months after the date on which the contracting officer receives evidence of physical completion.  So there is a period of time where the period of performance is completed, but closeout actions have not begun. 
     

    FAR 4.804-5 lists the administrative procedures for closeout.  Some of them may incur costs after performance of the contract, such as settling subcontracts by the prime, or interim costs.  For example, the final payment of rented equipment may take place after delivery of the last item.  If it is an allowable cost, then it can be submitted for payment, pending the contracting officers' approval. The contractor should also review what's in their disclosure statement regarding billing for direct or indirect costs.  

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