FAR 31.205-33(a) defines professional and consulting services costs as services rendered by persons who are members of a particular profession or possess a special skill and who are not officers or employees of the contractor. These can be services to enhance the contractor’s legal, economic, financial, or technical position, but contractors should place special emphasis on the phrase “special skill” in that definition to properly categorize the services as consulting or purchased labor. To support consultant and professional service costs, FAR 31.205-33(f) contains three requirements for evidence to ensure the allowability of professional and consultant service costs: (1) details of all agreements; (2) invoices or billings and (3) consultant work product and related documents. While the regulations do not require written documentation, DCAA has had a history of requiring written documentation, particularly in the area of work product. Contractors have had difficulty maintaining this level of support because some consultant agreements may be verbal or the work performed by the consultant did not result in a physical work product.
Read the full article by Dixon Huges Goodman HERE.
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