Public Comments 2006-D057-A.Chvotkin

Ms. Sandra Morris: On behalf of the Professional Services Council (PSC), I am pleased to submit the attached comments on the second interim DFARS rule entitled “Excessive Pass- Through Charges” published in the Federal Register on May 13, 2008 (73 F.R. 27464). This interim rule replaces the first version of this interim rule published in the Federal Register on April 26, 2007 (72 F.R. 20758). The Professional Services Council (PSC) is the principle national trade association of the government professional and technical services industry. While this second interim rule makes valuable improvements to the April 2007 interim rule, there are still significant inconsistencies that must be addressed. PSC recommends further improvements and clarifications to the second interim regulation, including clarifying definitions, modifying the reporting requirements, addressing the recovery mechanisms and applying the flow-down requirement to subcontractors. Since this second interim rule is already in effect, we urge the department to act expeditiously to resolve these comments. Thank you for your attention to these comments. We would welcome the opportunity to meet with appropriate departmental officials to discuss these concerns in greater detail or to convey them in a public meeting if the department were to schedule such a session. In the interim, if you have any questions or need any additional information, please do not hesitate to let me know. I can be reached at (703) 875-8059 or at Chvotkin@pscouncil.org.