An August 27th letter to the FAR Council by the Council of Defense and Space Industry Association (CODSIA) opposes certain sections of the June 25th proposal to amend the Defense Federal Acquisition Regulation Supplement to improve billing and payment instructions.  The comments address the proposed requirement that billing amounts by Contract Line Item Number (CLIN) “best reflect” costs.  CODSIA states that all cost type contracts funded by a single appropriation should be excluded from having to separately identify a payment amount for each CLIN since the billing and payment process for contracts containing only one appropriation can be highly automated and would meet statutory requirements.  For separately funded CLINS, CODSIA disputes the assertion that the rule is not expected to have a significant economic impact on substantial numbers of businesses.  CODSIA states it will be necessary for contractors to establish new systems and processes for more detailed reporting.  Further since “best reflect” has not been defined, the term will lead to “unattainable compliance requirements” arising from inconsistent interpretations by contracting and audit offices.

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