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    1. Appropriateness of a tech data withhold for CDRLs when the Govt declines to fund the effort to completion. How is the contractor to complete the CDRLs to an acceptance level when we no longer fund the effort. 2. Appropriateness of rejecting entire incurred cost vouchers to exercise the tech data withhold 3. Is it a normal business practice to deobligate funds with a withhold in place (due to the Govt exercising tech data withhold) to apply the money to a separate effort that needs the funds


    Answer

    1.  The contractor should not be expected to complete the CDRLs when there is no longer funding on the contract. 
    2.  When you refer to the "tech data withhold", is it FAR 52.227-21.  This clause states how much payment can be withheld $100,000 or 5% of contract, which is less if the contractor fails to meet certian requirements. Bounce this amount to what was rejected on the invoice amount. 
    3.  I cannot speak to if it is normal business practice to deob funds with a withhold in place, but in my experience it is not normal practice to deobligate funds on one contract if they will be potentially needed in the future on that same contract.

    You will want to speak with your legal counsel on this issue.

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