Public Comments 2006-D066-A. Edgerly

1. The current text of DFARS 232.007(a), last sentence, states the following: "For interim payments on cost-reimbursement contracts for services, see 232.906(a) (i)." The proposed rule moves the text regarding interim payments on cost- reimbursement contracts for services to 232.906(a)(ii) [moves from (i) to (ii)]. I would recommend DoD correct the cross-reference if the proposed rule is adopted in its current format. 2. DFARS 216.307, 232.007, 232.906, and 232.908, all speak to the same subject...interim payments on cost reimbursement contracts. One needs to read all four sections to get the complete picture of the regulations on this subject. I fear that many people will not find or seek out all four references. For example, FAR 32.901 states that FAR 32.9 does not apply to contract financing payments. Therefore, how would a person know to look for text on contract financing in DFARS 232.9? I would suggest that DoD place all the text regarding payment and cost-reimbursement/contract financing, in one location in the DFARS, and then add cross-references in the other locations back to the complete text. I don't have a preference, but here's an example: Place all the text in DFARS 232.007, and then place a cross-reference to DFARS 232.007 at 216.307, 232.906, and 232.908.