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However, your inquiry is much more in-depth than first meets the eye, and it should be. So let’s look beyond the obvious...
The DDP memorandum states that costs incurred for ineligible dependent health care are unallowable under FAR 31.201-3 and violate the selected cost principle at FAR 31.205-6(m);However, these unallowable costs are not expressly unallowable. Therefore, auditors should not pursue application of penalties under FAR 42.709 to the questioned ineligible dependent health care benefit costs. Accordingly, auditors also should not cite contractors that fail to exclude these costs from Government contracts for noncompliance with CAS 405.
Paul, can you address the impact on our contractor work force of the Executive Order issued on 21 Dec which I believe declared the 24th of December a National Holiday. Government was very unclear and fractious on how contractor work force and contractors should deal with this "holiday."