Thursday, September 13, 2018

Veterans Affairs - Revised Cost Principles for Education Contracts

Most of our readers have at least a passing familiarity with FAR (Federal Acquisition Regulations) cost principles (FAR Part 31). Less known are cost principles published by and unique to other executive agencies. For example, the Defense Department has added a few of its own cost principles. So has NASA, the Energy Department, and a few other agencies. Its always a good idea to familiarize yourself with those cost principles applicable to your specific contract.

The Department of Veterans Affairs has just amended its FAR Supplement (VAAR or VA Acquisition Regulations) to revise a few of its own cost principles. These particular cost principles, codified at 48 CFR 831.70000 address cost under vocational rehabilitation and education contracts. The areas covered include:

  • Tuition
  • Special services or courses
  • Books, supplies, and equipment required to be personally owned
  • Medical services and hospital care
  • Consumable instructional supplies
  • Reimbursement for other supplies and services.
So for example, to be allowable, tuition and enrollment fees must meet certain criteria:
  1. It cannot exceed the tuition charged to similarly circumstanced non-Veteran students.
  2. It must be equal to the lowest price offered or published for the entire course, semester, quarter, or term
  3. Costs must be offset by any amount waived by a State or other government authority
  4. Costs must be offset by any amounts the Veteran student receives from a fellowship, scholarship, grant etc.
If you are in the business of contracting with the VA for educational services, these changes are critical. You can read a summary of the changes here.

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