Is our local contracts team interpreting the DFARS 204.7103-1 (4) Single accounting classification citation correctly? In my opinion, this rule means that there must be One CLIN/One ACRN on a line item. I believe we are adhering to that rule because each funded CLIN ACRN LOA combination is treated and billed as a separate line item. I also believe that the same LOA can fund multiple line items.
Is it true that a CLIN with multiple accounting classification citations cannot be executed through SPS?
What is the definition of the line item? The DFARS states that on non-severable CLIN can have multiple accounting classification citations on a SINGLE line item. The example the DFARS gives is below:
Item No Supplies/Services Quantity Unit Unit Price
0001 Air Vehicle 1 EA $6,700,0000
000101 ACRN AA
000102 ACRN AB
000103 ACRN AC
DFARS states: Informational subline items established to identify multiple accounting classification citations assigned to a single contract line item.
I don't believe we are doing this on our current contract. First off, we don't have any non-severable CLINS. Second, we are not funding one single line item as a PARENT and having CHILD ACRNS total the total funding on the parent CLIN. We are treating each ACRN/LOA/CLIN combination as a new separate line item.
Sorry for being long winded, I just wanted to give you the full context because this is an issue I want to resolved.
You have the correct DFARS PGI citation but what you may not be aware of is the technology challenges i.e. PD2, IRAPT, etc. or any internal Agency CLIN/SLIN policy. Your decision to set up the proper CLIN/SLIN is dependent on your Service policy, agency policy letters, and ultimately is your Contracting Officers decision. Recommend that your contracting officer and program office sit down and address all of the issues and possible solutions.
Open full Question Details