We have several completed DoD cost reimbursable contracts requiring closeout. Since the contract period of performance has lapsed, costs incurred post completion are normally unallowable. The question, however, is can direct charging costs to handle closeout actions that are incurred following the completion of the contract and lapse of the period of performance be treated as allocable to the contract being closed and thus allowable in the final voucher? If so, what is the authority for this?
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Probably not. Support for this comes from section 6-202.2 of the DCAA Contract Audit Manual Procedure which states: "The auditor shall not approve for reimbursement any costs incurred by the contractor subsequent to the expiration date stated in the contract, or in excess of contract limitations." If the costs of closeout actions are to be paid by the Government, the contractor should have proposed those costs so the period of performance could accommodate those actions. The statement of work would have included the close-out activities and contract funding provided for them.