Comment on FR Doc # 2011-09515

Document ID: FAR-2010-0010-0003
Document Type: Public Submission
Agency: Federal Acquisition Regulation
Received Date: April 22 2011, at 12:01 PM Eastern Daylight Time
Date Posted: July 1 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: April 20 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: June 20 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c35ea9
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This is comment on Proposed Rule

Federal Acquisition Regulations: Service Contracts Reporting Requirements

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The proposed rule is not clear on which threshold applies to fixed unit price IDIQ contractors. Our pricing is based on a fixed unit price per test. Labor hours are not easily assigned to tests, since the analysts work on batches of samples at the same time. A batch may contain samples from a government contract, as well as samples from non-government clients. For ARRA, we calculate FTE by dividing average FTE by total revenue over the previous year, then multiplying by ARRA revenue. This yields only an approximation. Would such a calculation be acceptable for this new reporting requirement?

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Comment on FR Doc # 2011-09515
Public Submission Posted: 07/01/2011 ID: FAR-2010-0010-0003