The Department of Defense has issued a final DFARS rule requiring contractors to engage in technical interchanges with the DoD before such costs are generated. These interchanges are required to “improve the effectiveness of independent research and development (IR&D) investments by the defense industrial base” that are reimbursed as allowable costs.
DFARS 231.205-18, Independent Research and Development and Bid and Proposal Costs, has been revised stating that “for annual IR&D cost to be allowable –
- The IR&D projects generating the costs must be reported to the Defense Technical Information Center (DTIC) using the online input form and instructions at https://defenseinnovationmarketplace.dtic.mil;
- The input must be updated at least annually and when the project is completed;
- Copies of the input and update forms must be made available for review by the cognizant ACO and DCAA auditor to support allowability; and
- For IR&D projects initiated in the contractor’s fiscal year 2017 and later a prerequisite for subsequent determination of allowability the contractor shall –
- Engage in a technical interchange with a technical or operational DoD Government employee before IR&D costs are generated. If there is no point of contact for such technical exchange the contractor can contact the OASD R&E at: https://www.acq.osd.mil;
- Use the DTIC input form to document the technical interchange.
Contractors not meeting the threshold of a major contractor are encouraged to use the DTIC online input form to report IR&D projects to provide DoD technical content visibility and to enable determination allowability.