Government Contracts DoD Removes Requirement for Technical Interchange on IR&D Costs
Wednesday, September 12, 2018

DoD Removes Requirement for Technical Interchange on IR&D Costs

By Government Contracts Editorial Staff

The Department of Defense has removed from the Defense Federal Acquisition Regulation Supplement a requirement for major contractors to have a technical interchange with the government prior to generating independent research and development costs. The final rule (DFARS Case 2017-D041) removes the text at DFARS 231.205-18(c)(iii)(C)(4), which requires major contractors to engage in and document a technical interchange with the government, prior to generating costs for IR&D projects initiated in fiscal year 2017 and later, in order for those costs to be determined allowable. This requirement caused contractors to expend time preparing for a discussion, contacting appropriate government personnel, and discussing the IR&D project. Since contractors commonly pool all of their IR&D project costs to develop a single billing rate, this requirement would necessitate contractors having to discuss all of the IR&D projects contained in their billing rate. This change supports a recommendation from the DoD Regulatory Reform Task Force. The rule supersedes Class Deviation 2017-O0010 (¶70,245.74). For the text of the final rule, which went into effect on August 24, 2018, see ¶70,016.950.

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