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At time of award during which Contracts is accepting the contract and working through the acceptance and set-up in the Accounting system is it proper to charge that effort to the B&P or should it be charged to the actual awarded project?
Answer
This response is based on the information provided. We suggest you discuss with your finance department, contract administrator and/or legal department and the government contracting officer as appropriate.

Given your situation there are several things to consider in determining treatment of setup costs and their allowability. If the effort generating the cost benefits only one cost objective or one contract, it is possible that it may be treated as a direct cost to a single contract. If the "acceptance and set-up" only happens because of the actual project, it might be possible to consider it as a direct cost. Timing of when the cost was incurred (before or after award) impacts its allowability as well. Even though companies have wide latitude in the treatment of costs, they must remain consistent across all contracts and business to preserve the allowability of the cost. Typically a company's disclosure statement outlines the consistent treatment of cost. This may be a good source to understand the way your company accounts for these type costs.

FAR 31.205-18 -- Independent Research and Development and Bid and Proposal Costs should also provide some guidance as it applies to your company's situation.

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