FCC Contract Administration & Compliance 3 â Questions and Answers
Question 1: Which of the following best describes an undefinitized contract action (UCA)?
- A contract awarded without competition
- A contract where work begins before price is finalized (Correct answer)
- A contract that lacks a statement of work
- A contract executed without legal authority
Correct answer: A contract where work begins before price is finalized
A UCA authorizes a contractor to begin performance before contract terms, specifications, or price are agreed upon, creating cost control risks.
Question 2: The Equal Access to Justice Act (EAJA) allows small businesses to recover attorney fees when they prevail against the government in certain disputes. What condition triggers fee recovery?
- The contractor must prove bad faith by the contracting officer
- The government's position must not have been substantially justified (Correct answer)
- The contractor must have a claim exceeding $100,000
- The dispute must have reached the Court of Federal Claims
Correct answer: The government's position must not have been substantially justified
Under EAJA, a prevailing small business may recover fees unless the government demonstrates its position was substantially justified.
Question 3: A contractor requests a no-cost time extension due to unusually severe weather. Which FAR clause most directly supports this request?
- FAR 52.249-10 (DefaultâFixed-Price Construction) (Correct answer)
- FAR 52.243-1 (ChangesâFixed-Price)
- FAR 52.215-14 (Integrity of Unit Prices)
- FAR 52.232-1 (Payments)
Correct answer: FAR 52.249-10 (DefaultâFixed-Price Construction)
FAR 52.249-10 excuses delays caused by unforeseeable causes beyond the contractor's control, including unusually severe weather, entitling a time extension.
Question 4: Under the Contract Disputes Act (CDA), how long does a contractor have to appeal a contracting officer's final decision to the appropriate Board of Contract Appeals?
- 30 days
- 60 days
- 90 days (Correct answer)
- 120 days
Correct answer: 90 days
A contractor must file a notice of appeal with the cognizant Board of Contract Appeals within 90 days of receiving the contracting officer's final decision.
Question 5: Which standard governs whether a cost is allowable on a cost-reimbursement federal contract?
- FAR Part 31 cost principles (Correct answer)
- GAAP accounting standards
- OMB Circular A-11 budget guidance
- The contractor's disclosed accounting practices only
Correct answer: FAR Part 31 cost principles
FAR Part 31 cost principles establish the allowability, allocability, and reasonableness standards that determine which costs the government will reimburse.
Question 6: What is the primary purpose of a defense contract audit agency (DCAA) forward pricing rate agreement (FPRA)?
- To set fixed labor rates for union workers on federal projects
- To establish pre-negotiated indirect cost rates for use in pricing future contracts (Correct answer)
- To audit a contractor's compliance with cost accounting standards
- To authorize progress payments on large fixed-price contracts
Correct answer: To establish pre-negotiated indirect cost rates for use in pricing future contracts
An FPRA is a written agreement negotiated between the government and a contractor establishing rates to be used in pricing proposals for a future period.
Question 7: A construction contractor modifies the design slightly to avoid a differing site condition claim. Later the government discovers the change. Under FAR, which best describes this situation?
- The contractor validly avoided a constructive change
- The contractor may have waived its right to a differing site condition equitable adjustment (Correct answer)
- The government owes a deductive modification for the design change
- The contractor must submit a value engineering change proposal
Correct answer: The contractor may have waived its right to a differing site condition equitable adjustment
Proceeding without proper notice and failing to assert a Type I or II differing site condition claim can constitute a waiver of the contractor's right to an equitable adjustment.
FCC Contract Administration & Compliance 3
Which of the following best describes an undefinitized contract action (UCA)?