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Contractor invoice format for Research and Development

thank you for joining us today for jennifer schatz and associates in our webinar wednesday program coming to you live from washington dc we are uncovering each part of the d bars for defense federal acquisition regulation supplement every wednesday at 12pm eastern as you know the defaults are the rulebooks for contracting with the defense department we've been moving sequentially so we started with cfar's part 201 in january and we'll be finishing with part 253 in december our webinars are every wednesday and are provided complimentary they are recorded and can be downloaded from our website and youtube channel which now holds over 450 of our government contracting webinars in the interest of time we do not take questions so if you do have questions for our speaker we will make sure to have your information on the last slide of the presentation today virginia ptac at gmu offers free one-on-one counseling to firms in virginia on federal state and local procurement topics online 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website i also wanted to inform you of a new series that we're holding we have lunch we have launched a monthly series called the govcon live q a cafe and this is a live webinar series held each month and these will take place on the second friday of each month in this 2021 at 12 pm eastern and we have assembled a group of four panelists who are subject matter experts on a specific federal contracting topic panelists will make a short presentation about the topic listed here on your screen and then take your live questions about that topic our panelists include attorneys consultants and other industry professionals and you can sign up on our website under the q a cafe tab sponsorships are available for these webinars please email hello at jennifers.com for a media kit with pricing details also please note that you can use code g bars for a 15 discount on each of these webinars so these are the webinars that we're holding for the rest of the year so on friday september 10th our speakers will be covering oral presentations led by rena troye andres and debra in october we are covering set-asides with anna erikssai and tim on friday november 12th our speakers will be covering pricing with michael marsha tracy and jeff and lastly in december our speakers shirley joshua kate and brad will present on mna an additional reminder that you can use code bars for a 15 discount bringing your cost to 20 and please join us for a complimentary webinar as we kick off the fiscal new year on friday october 1st hear from industry leaders about best practices in areas of compliance marketing market research and more sponsorships are available please contact us at hello at jennifershouse.com for information or simply register on our website under the event section and now to introduce our speaker susan warshaw ebner welcome susan we are glad to have you here with us today and i'll now turn the floor over to you thanks very much i appreciate it so for those of you who don't know me i'm susan warshaw ebner i chair the government contracts and investigations practice group at stinson llp i'm also the immediate past chair of the american bar association public contract law section and regularly advising council clients including small and large businesses and nonprofits and consortiums in research and development topics as including contracts grants other transactions technology investment agreements and cooperative agreements also council land represent clients in traditional government contracts areas including compliance programs protests claims audits and investigations next slide so today we're going to be talking about dfr part 235 research and development is an important element of government contracting as we see increasing threats emerge and instability arising we know the government is looking to develop the next offset strategy and new tools equipment and supplies to carry that out recent dod budgets and proposed budgets for example indicate that the government's looking at areas such as cyber security communication spectrum matters hypersonics artificial intelligence environmental considerations as well as better manufacturing supply chain risk management and more research and development funding is also something that uh you as a somebody who's involved in government contracting will really need to know about because the benefits to the government of getting new technologies cause it to enter into contracts grants and other types of agreements in order to develop those it also provides contractors not only funding to develop those new technologies but the opportunity to showcase their capabilities and customers let's move on to the next slide please so what is research and development contracting so d4 part 235 is one of those sections that deals with this it's not the only section every agency has its own version of a research and development section that supplements the far and there are additional uh guidance instructions as well as things that are in appropriations and authorization acts that make control and statutes but efforts here for research and development they involve fundamentally a number of different topic areas as you can see here one is basic research basic research is that systematic study directed toward greater knowledge or understanding of fundamental aspects of phenomena and observable facts it doesn't deal with specific applications or processes for products but rather it's a fundamental knowledge and understanding type of research uh basic research may lead to applied research and advanced technology developments uh but at its heart it's not covered by it's not usually restricted under export control laws and it's something that many universities for example carry out applied research is the second topic that's a more systematic study to understand things to meet recognized and specific needs it's a systematic application of knowledge to develop useful materials devices and systems or methods it may ultimately lead towards design development and prototyping of new processes and products to meet mission requirements the third topic is advanced technology development that area is where there is actual development of subsystems and components and efforts to integrate subsystems and components into system prototypes in order to conduct field experiments or tests advanced technology development is usually conducted in a simulated environment that's in comparison to the next topic which is advanced component development and prototypes under acdd kinds of things efforts there or to evaluate integrated technologies representative prototype systems in a high fidelity realistic operating environment the emphasis here is we're actually trying to be as realistic as possible to test and see do these things work the next one is system development and demonstration sdd programs have basically passed milestone b approval uh they're conducting engineering and manufacturing development tasks to meet validate requirements prior to full rate production so when you have a research and development contract you'll have the basic research you may have applied research and then if that proceeds in some cases particularly if you're dealing with other transactions you may be able to proceed to lrip which is low rate initial production and then full production these sdd activities occur before you get to lrip rdt and e that's management research development test and evaluation efforts that's in order to develop the test ranges military construction or maintenance of the facilities operations aircraft that are being studied under the research and development topic they also may include military construction activities as well next slide what i have on the next slide is uh basically the technology readiness levels uh you'll see the next two slides there are nine technology readiness levels that currently are listed in the default one is the basic principles observed and reported this is basic research proof of concept simulated as we talked about the next technology readiness level is technology concept or application formulation these are basic principles um they are limited to analytic studies as you proceed down to three and four you're moving more towards looking at you know more proof of concept art are these things working together you know but still in the um low level technology research and development you're not at that point where you're actually technically covering things like prototypes research and development it's more that initial what's the concept what is it i want to prove um you know what is it that i might be able to accomplish if i proceeded to a higher level of research and development technology readiness level five you're talking about component and breadboard validation in a realistic environment but it is still a simulated kind of environment next slide as you move on to technology readiness six seven six is a prototype that's really where we start seeing prototypes where they're actually testing prototypes in the relevant environment the idea is for example you have another transaction agreement you're gonna be starting at a trl level six or seven where you're testing and proving concepts of using something that may exist testing it in that relevant environment to see if that works maybe doing further research and development work on that model or prototype or issue whatever it is uh level seven is the operational environment testing that's a little bit more advanced prototype divesting and that's usually right before you go into an lrip phase levels eight and eight really are we're talking qualification test demonstration and then you get to nine and you're talking low rate initial production and then you're dealing with full production if you're going that far next slide so when we want to do research and development basic concepts when we're doing a far-based procurement are that we have to have an equitable and sensible allocation of program risk between the government and the contractor what does that mean that means that you've got to figure out whether or not the program can be conducted with a reasonable level of risk and realistic pricing so the default typically is i'm doing research and development i don't know what it is that i'm going to ultimately end up with or maybe i have an idea of what i want to do but there's a lot of risk there because i don't know how things are going to happen and there's programmatic risk that has to be addressed when the programmatic risk is such that you can't reasonably mitigate it or the item that's being researched is too complex the end product you're seeking there's high levels of risk and whether you're going to achieve it those are usually the types of research and development projects that are going to be handled on a cost reimbursement basis on the other hand there are programs where we can capture the risk we can figure out how to mitigate the risk we understand what the the aim of the program is we understand how it's going how much it's going to cost to get it done the more likely you are to be able to put that research and development project into a box where you can capture or mitigate risk you can capture and mitigate the cost the more likely it may be a suitable candidate for fixed price research and development i would say you know one of the things we always worry about is putting a research and development contract into a fixed price box the government has tried that a number of times it's sort of the pendulum swinging back and forth in the 90s we saw a lot of fixed price contracting to try and get research and development done in a box of here's how much it's going to cost a12 i don't know how many people are familiar with the a12 aircraft program that the navy was running in the 1990s it had started um it was to develop the next generation stealth aircraft it was done as a fixed price research and development project it was going to be billions of dollars um the project ran into a lot of problems uh ultimately there turned out to be a real dispute as to whether or not the project could even be accomplished based on uh what was technologically feasible um and there was tons of litigation those of you who are charles dickens fans bleak house jaundice and journalists where the parties just kind of litigated like crazy till they used up all the costs well a12 was one of the cases where the parties litigated like crazy and at the end of the day after going back forth on appeal up down litigating a very a variety of issues the supreme court ruled that the parties were just going to stay in place the way they were and they were just going to end the contract as is nobody got more money nobody got money back because there were state secrets involved and they couldn't disclose those so that there could be litigation so fixed price contracting does have its perils so when we talk about fixed price contracting we also talk about you know program risk program risk is just really important in order to determine whether you're going to do a fixed price versus cost reimbursement research and development project there has to be a written determination by the responsible contracting official depending upon the dollar size you know lower than 25 million it could be something that's determined by the contracting officer above that it's going to require the uh the under secretary of defense for acquisition and sustainment to make a determination as to whether or not uh this should be a fixed price research and development type of project you need uh usd ans approval uh before the negotiations happen which means before you that broad agency announcement hits the stands uh and they say this is the type of research and development contract we're going to have there has to be a plan and acquisition strategy that's determined are we or aren't we going to go cost reimbursement or fixed price um there are milestones that have to be set up in order to do that for those of you who haven't seen it a couple of months ago i did a major weapon system um uh presentation uh for jennifer schauss and associates i believe that's on youtube you might want to go back and look at that it talks about all the different levels that you have to go through in terms of milestone planning for different acquisitions one of the key things to think about when we're thinking about cost reimbursement is for major defense acquisition programs you can't proceed to do a cost reimbursement project until there's a written certification that the cost reimbursement line items are needed for required capability and in order to um deliver in a timely and cost-effective manner otherwise um you know there may be issues with proceeding in that way too next slide so uh 235 uh 0 0 6-70 deals with manufacturing technology programs there are a lot of different programs that deal with research and development but this is one where we we certainly have been talking a lot in the last year about supply chain risk the covid virus has made things very difficult to get it's caused limits and availability of supplies and materials uh the more global the manufacturing process and supply chain the more problems we've had this year with covid there has been a lot of focus in the proposed budgets for last year and this year on manufacturing to bring back technology into the united states or its allies to ensure that we're going to have a secure supply chain the manufacturing technology program is one that the secretary of defense establishes you know there's a strategic plan that's developed every five years they start developing it four years out probably takes about a year to develop the plan and the plan basically is one where they work in conjunction with dod laboratories and also the joint defense manufacturing technology panel and other local activities in order to figure out what manufacturing programs they really need those kinds of manufacturing programs may include for example manufacturing processes or tools or equipment practices that would be essential to the national defense it also might include things like repair and remanufacturing in support of system commands depots air logistics centers and shipyards and so forth these programs when they're put in place they need to be competed so if you have a manufacturing technology program it's coming out they want to go in and solve one of those manufacturing types of problems they will issue some form of announcement could be a broad agency announcement could be a request for proposal where they're going to want to compete the program requirements and they're also going to be asking for cost share so those of you who have worked in the space that's not far like the other transaction agreement space you might be very familiar with this concept of cost share from some of those statutes they all mandate that there be cost share in this area where we're talking manufacturing technology programs we're also looking at a cost share and in fact these kinds of arrangements may come out in terms of grants um agreements or contracts so when you're looking at this it doesn't all have to be a far based procurement but the basic concept is it has to be completed and there has to be cost sharing when we talk about the joint defense manufacturing technology council that panel is one that is chaired by um somebody who's been appointed on a rotating basis from among the military departments and defense agencies that have manufacturing technology programs there are typically people from each of the military departments on that as well as potentially others uh the panel will uh the panel is charged with identifying and integrating the requirements for the program as i said before looking to make a comprehensive review and assessment of what are the defense related manufacturing issues out there and what are potential programs to go and carry them out next slide so evaluation for award we talked about this a little bit uh this requires competitive procedures as i said before could come out through a baa a broad agency announcement or a request for proposals it's going to assess cost share between agency and off-roads if you're familiar with ots in terms of cost share you know small businesses for example non-traditional defense contractors are usually um able to avoid having to pay cost share those that are cast covered contractors are required to offer some form of cost share or to show how they're using to a great extent uh non-traditionals in those projects that may be something that's considered in a particular research and development project especially if it's going to be another transaction agreement but cost share will be covered in some way in addition for evaluation for award um there is a provision in here i i don't know if many people know about this but lead systems integration this is the concept where you have someone who's a large prime who is basically overseeing putting together all the different pieces and parts to develop a program so we've seen that in like a12 we may have seen that in the future combat systems those are huge programs where there's a lead systems integrator functioning as a prime contractor overseeing and pulling in all the different pieces if you are going to go after one of these procurements uh lead systems integrators under 10 usc 22 2410p you're prohibited from having any direct financial interest in the development or construction of any individual system or element or system of systems so what does that mean that means that if you're a lead systems integrator or you're applying to b1 under one of these procurements you can't have a financial interest in the work of your subcontractors the only way that you can is if there's a competitive selection and if the other potential conflicts of interest organizational conflicts of interest are addressed or if you're at a lower tier operating as a lead systems integrator having retained or brought in a subcontractor that if the subcontractor then selects the lead systems integrator to be one of its subcontractors that that process has done without the control of that lead systems integrator so dod will not award a new contract for lead systems integrator functions for major systems if the major system has proceeded beyond low rate initial production so you won't be seeing new lead systems integrated procurements where they've already bypassed the lrip process so if you were going to see them it would have to be before that in addition there would have to be a secretary of defense determination writing that it's not practicable to carry out the acquisition without having a lead systems integrator function so those are some of the things that are holding up the use of lead systems integrators in addition let's say you have a lead systems integrator research and development type of contract um one of the things that it does prohibit we know we've been concerned about do does the lead systems integrator have an interest financially in any of its subcontractors in the underlying systems and components that go into the project if during the course of the lead systems integrate contract the lead systems integrator plans to acquire an interest in one of the individual systems or elements of that they have to notify the contracting officer then the establishment will determine does an exception apply to the prohibition of having a lead systems integrator have a financial interest or can they firewall avoid or mitigate that a lot of cases out there that deal with that from the standpoint of things like the ftc or the department of justice looking at conflicts of interest from an anti-trust perspective as well um so if the if the matter can't be fire weldable avoided or mitigated and the government doesn't want to proceed they can terminate they actually can even terminate for default if they have that option otherwise if they do want to undertake some remedial measures to address this they may set conditions on what can be done by whom there may be some conditioned divestiture in the planned acquisition there could be firewalls established there could be all sorts of organizational things that are done to make sure that any potential conflict of interest is mitigated really a development here is that on july 9th by the initial executive order in which he asked for increased anti-trust enforcement i bring that up because right after that the department of justice and the federal trade commission also announced that they're going to conduct a higher level of scrutiny on mergers and acquisitions so under that program they actually could block a merger or acquisition or require divestiture or other kinds of requirements so that if you had a lead systems integrator that had a financial interest or was seeking to merge or acquire as part of that those would be issues that would need to be addressed this is particularly important in light of the fact that we're now in a position where there is a real need for research and development and there is a shrinking defense industrial base we want to make sure that those things are handled correctly next slide next slide so next is scientific and technical reports if you've done any research and development you know there's always going to be a scientific and technical report dtec the department of defense technical information center is the repository for all scientific and technical reports used to be able to go online to dtec and pull things down now they say it may be accessed by eligible entities so those who get research and development contracts you'll see in your contracts that you get that you will be able to have access to dtec and the reason for that is that the government wants to make available prior research that's been done on the topic so that if it's useful to you they get the benefit of you using it as well next slide research facilities educational institutions have lots of research facilities almost every university major university has some form of research facility some are better known than others johns hopkins has them you know the johns hopkins applied physics lab we've got mit et cetera so educational institutions are there to furnish facilities for the performance of defense contracts far part 31.3 cost standards covers how to reimburse these institutions under the research programs allowances though are really conditioned on the satisfaction of several things in order to get paid to be assisting in these processes the research facility has to be determined to be essential to performance of the dod contract it has to be an existing that existing facilities are not there to meet program requirements practically or effectively uh furnishing the government-owned facility is not practical it's not desirable and in addition the proposed use of the educational institutions facility is essential to the government research there may be something special about it that's really needed in order to accomplish particular government research so those are things that all conjunctively have to be satisfied in order for an educational institution to get one of these special use allowances other key points here are how they get paid they only get paid in the years when the government actually has a contract using the facility that's not surprising uh the other thing is that if as is typical in educational institutions they're doing a lot of research some private some government uh the allocation of that allowance is going to be prorated uh for how that facility is being used so they may not get the full allowance that they might otherwise be entitled to if they're doing research for others as well it will be prorated it's sort of like that concept of when you're keeping track of time uh unless you're full-time accounting where you're tracking every hour of the 24 hours it's usually prorated for your eight hour day and even if you're tracking 24 hours remember you can never bill an invoice for more than 24 hours so some restrictions on that allowance process they will never pay more than the acquisition cost so if they were going to buy it then they can't pay more than that next slide so in addition to using research facilities at educational institutions we've got federally funded research and development centers ffrdc's these are research laboratories that dod sponsored uh the institute for defense analysis mit's lincoln laboratory carnegie mellon software engineering institute's typo there sorry about that those are all ffrdc's uh one of the things that to note is they are required to have a conflict of interest policy which covers organizational as well as personal conflicts of interest so that if members on the ffrdc also serve on a board or as a trustee of a profit making company then they will have to mitigate avoid or get a waiver for any actual or apparent conflict of interest next slide research and development contracts may involved high-risk endeavors i mean for anybody who was watching a few weeks ago when we saw the launch of the spaceship um going into space you know sometimes these things are highly risky so there's room for indemnification and limitation of liabilities and research development contracts how much you can get indemnified whether you are eligible for it or how much you can have liability limited or protected in some way really is one that depends on the circumstances 10 usc 2354 is the provision that applies to research and development contracts there are other provisions such as public law 85 804 which deals with indemnification for ultra hazardous um and unusual uh events so under 10 usc 2354 you've also got the far clause 252 235 7000 and 252 235 7001 which deal with indemnification of fixed price research and development and cost reimbursement research and development these allow for indemnification but in order to have that clause in there it's got to be authorized by the secretary of the service or agency as just and reasonable so what kinds of indemnification does that provide it provides third-party claims for death or bodily injury or property loss it also provides for contractor property loss claims but not lost profits um it can result from the defined unusually hazardous risk remember if you're putting in this indemnification provision it's because you have defined and identified and gotten approved here's this unusual hazardous risk we are approving indemnification for that purpose so any event that's going to occur has to be shown to tie to the purpose of that indemnification and whatever indemnification there is it has to be in direct performance of that contract or subcontract typo here sorry about that where it says indirect performance of the subcontract it should be indirect performance of the contract or subcontract so this is a clause that will slow down it will slow down if the government approves the use and flow down of an indemnification provision under 10 usc 2354 and inclusion of that clause at the subcontractor level again if you're doing a research and development project you want to make sure that you're capturing your risk you're really defining this and identifying what you need to know about who's going to have that risk and where those clauses should be put this is one of those clauses that you want to make sure that if it is accessible to you that you do get the right to have that the scope of indemnification is if it if the problem arose from willful misconduct or bad faith you're not going to be able to get indemnification if you are compensated by insurance to the extent that the insurance covers that um you won't be compensated but beyond the insurance compensation level if there are property losses or damages those would be compensable if the clause was in place and the other restriction of course is the government never pays twice for the same thing or at least not intentionally and so if you are being compensated by other means under for example that um you know truly has hazardous public law 85 804 indemnification then to the extent that you're indemnified that way you won't be able to access the 2354 indemnification and as i mentioned before a request for use of the clause and indemnification has to be approved i would also note that if there is an occurrence that arises where there is this indemnification need the contractor has an obligation to provide prompt notice and proof of loss to cooperate with the government and in fact you may very well see where there is this intense hazardous risk event that occurs that the government may very well want to be involved and may want to direct certain activities since it is indemnifying i mentioned before flow down is a key component the government will allow the subcontractor to get a slowed down indemnification provision but only if the contracting officer has given prior written approval to the contracting officer that this provision can be included in the subcontract the contracting officers approved the indemnification provision and the indemnification provision contains all those restrictions that applied at the prime contractor level as we discussed before next slide so we've got other provisions we could spend a lot of time on this but basically i think the key points here are export control when we're talking about different levels of research and development uh you really have to worry about not just you know the normal protection of information but you also have to worry about any dissemination or use or disclosure of export controlled information or material and that means you have to worry about it from the standpoint of the personnel who will be able to engage in the research under your agreement or contract the personnel who will be recipients of any of the future information on it your technical reports or if you want to use this in advance all of this research and development you need to comply with the export control rules and that may include the itar since we're dealing with dod contracting not just the ear dealing with whether something is going to be considered export controlled whether it's going to be subject to the ear which is the department of commerce rules on export controls or the itar which is the international traffic and arms regulations which are administrated by dod and state department will depend working with the contract personnel program personnel will help you identify the nature and extent to which these things will be export controlled and the restrictions that will apply also very interesting when you do research and development sometimes you may have foreign subcontractors who are involved in the research and development or you may have foreign prime contractors involved in research and development when we talk about export control that gets much more complicated and there may be vehicles in which there can be sharing of information and the development activities but there are a lot of hoops to go through to address that so if you have that kind of situation not only these provisions but others may also apply other provisions that you may want to know about would include acknowledgement of support and disclaim those are key because you've got to make sure that whenever you're sending something out you're writing about the subject of your research and development you're getting approval and authorization to disseminate it but more importantly that you're actually making sure that you're doing it timely before the disclosure occurs and you're including that appropriate disclaimer and support acknowledgement in the appropriate places in the documentation that you're generating final scientific and technical reporting i always talked a little bit before about scientific and technical reports final reports are something that has to be done that's the kind of thing that's going to go into dtic at the end if you have any actual or potential inventions uh you may have to submit invention reports the final scientific and technical report needs to be the repository for what have you what have you done what have you accomplished are there any patentable inventions have you proceeded to go and get patents does the government get its government purpose license rights to use it are there any things that you need addressed under that so that's an important provision there in addition maybe other clauses that would apply depending upon uh precisely what it is that you're doing uh and as as i said before um depending upon the nature of the kind of work you're doing uh whether there are more things to worry about besides export control we've seen distribution requirements we've seen restrictions on the personnel have been work on it we've actually also seen sometimes research and development requires you to go outside of the united states so a variety of provisions that may apply to that kind of research you know if there's battlefield research and development you know such as the rapid advanced prototyping we saw under uh the you know most recent wars in iraq and afghanistan you know we saw a lot of rapid prototyping to try and solve problems through research and development of experimenting with prototypes those also involved when people that are contractors out in the field you know getting permissions for them to be there getting all the different terms and conditions needed to have personnel in the battlefield and uh addressing training now with the cyber security threats that are out there we're seeing a lot of clauses now coming in in terms of requiring training so that personnel who are working on these kinds of sensitive programs are aware of the risks there of foreign air of the surreys or others trying to access the research and development and steal it uh so training in order uh to identify potential threats and potential reporting requirements so those are some of the additional provisions that might be in a contract next slide so in conclusion research and development you've gotten a little bit of knowledge today on research and development how it may present and some of the rules that are out there there are many other rules that may dot the landscape here as i mentioned before major weapon systems have a whole set of rules on how and at what point you decide how you're going to be procuring research and development projects and how that's going to work into the major weapon system type of project or there are other types of research and development projects that will have specific rules like small business innovative research those are sibers sbir small business technology transfer those are small business and academia joint technology endeavors other transaction agreements technology investment agreements tias grants cooperative agreements and more public-private partnerships are something that uh we are hearing about in terms of the infrastructure builds that are coming out there uh the need for addressing some of these uh advanced manufacturing needs may very well be something that we could see in the future being the subject of a p3 a public-private partnership uh those are a little bit more complicated uh they may or may not be done under the far but stay tuned because uh there is an increasing effort to see how the government can do more get more research done but do it without paying as much having the contractor community more engaged and involved in doing that kind of research and development in the future so this is an area where negotiation may be very important scoping out your risk will be incredibly important and figuring out what your costs are going to be so uh research and development uh an important area one that's going to be growing in importance as we try to develop new offset strategies so i hope you found this uh presentation useful and if you have any questions don't hesitate to reach out it's susan.ebner at stinson.com i look forward to hearing from you and i wish you all a very good day thank you so much susan for a great presentation of today i mean definitely reach out with any questions that you can have the information on your screen now and to everyone who joined us for this webinar um the recording will be on our website youtube channel in the next 24 hours and please join us next week as we cover more parts have a good week everyone