Igce Builder Cr

IGCE Builder: Cost-Reimbursement (CPFF / CPAF / CPIF)

Overview

This skill produces Independent Government Cost Estimates for cost-reimbursement contracts. CR contracts reimburse the contractor for allowable costs incurred plus a fee. The cost buildup is structurally similar to FFP (layered cost pools: fringe, overhead, G&A), but instead of profit-as-markup, CR contracts use a negotiated fee that varies by subtype. The IGCE estimates what those allowable costs should be and what fee structure is appropriate.

CR contracts are common outcomes from BAAs (FAR 35.016), R&D contracts, and complex requirements where the government assumes cost risk but controls it through auditable cost pools and negotiated fee structures.

Required MCP servers:

1. bls-oews -- market wage data by occupation and geography. Key tools: get_wage_data, igce_wage_benchmark, list_common_metros, list_common_soc_codes.
2. gsa-calc -- awarded GSA MAS ceiling hourly rates. Key tools: suggest_contains, exact_search, keyword_search, igce_benchmark, price_reasonableness_check.
3. gsa-perdiem -- federal CONUS travel lodging and M&IE. Key tools: lookup_city_perdiem, estimate_travel_cost, get_mie_breakdown.

Regulatory basis: FAR 15.402 (cost/pricing data). FAR 15.404-1(a) (cost analysis). FAR 15.404-4 (profit/fee analysis). FAR 16.301 through 16.307 (cost-reimbursement contracts). 10 USC 3322(a) (statutory fee caps).

Operating Principle (ai-boundaries)

This skill assembles data and formats documents from reasoning the contracting officer supplies. It does NOT originate evaluative conclusions. Specifically:

• The skill pulls BLS wages, CALC+ ceiling rates, and Per Diem rates, and formats them into a workbook.
• The skill does NOT determine whether a rate is "fair and reasonable" under FAR 15.404-1. That determination is the CO's.
• The skill does NOT assert premiums (TS/SCI, OCONUS, SCIF, specialty labor) that are outside BLS/CALC+/Per Diem data. If a premium is needed and the data does not support it, the skill names the gap and hands the decision back to the CO.
• The skill does NOT draft a price reasonableness memo, a responsibility determination, or any FAR-citing signature document unless the CO has already supplied the rationale and conclusion, in which case the skill formats the CO's text into the template.
• Narrative prose (chat summaries, Methodology sheet, Rate Validation status) avoids evaluative verbs: "defensible," "reasonable," "acceptable," "competitive," "outlier." Replace with neutral positioning: "at P77 of CALC+ pool (n=X)," "within BLS P90 cost-plus-fee equivalent," "above P50 by Y%, document stacked factors in Methodology."

Stacked factors refers to the component sources of a rate premium. Typical examples: metro wage differential, seniority tier premium, clearance requirement premium, lab/SCIF overhead, thin CALC+ corpus (directional only), MAS ceiling vs CR cost-plus-fee separation, BLS vintage aging. Name the specific factors that apply, not the word "stacked" alone.

If you find yourself writing a conclusion about whether a number is right or wrong, stop. Present the data and let the CO conclude.

Pre-flight: MCP dependency check

Runs before Workflow Selection. Required on every skill trigger.

This skill needs three MCP servers: bls-oews, gsa-calc, gsa-perdiem. Do not proceed to any workflow until both checks below pass.

Check 1: MCP presence. Verify all three are available in the current session by looking for one known tool from each:

• bls-oews (check for mcp__bls-oews__detect_latest_year)
• gsa-calc (check for mcp__gsa-calc__suggest_contains)
• gsa-perdiem (check for mcp__gsa-perdiem__get_mie_breakdown)

If any are missing, respond with:

> This skill requires the bls-oews, gsa-calc, and gsa-perdiem MCP servers. Missing: [list]. Install and configure them in your MCP client before using this skill.

Check 2: API key presence. Two of the three need API keys. Verify by lightweight ping:

• mcp__bls-oews__detect_latest_year (needs a BLS API key)
• mcp__gsa-perdiem__get_mie_breakdown (needs an api.data.gov key)
• gsa-calc needs no key, skip

If either ping returns an auth error or missing-key error, respond with:

> [bls-oews | gsa-perdiem] is installed but its API key is not set. This MCP needs a free API key (BLS for bls-oews, api.data.gov for gsa-perdiem). Register the key with the provider and add it to the MCP's configuration, then restart your MCP client.

Only proceed to Workflow Selection after both checks pass. Do not try to work around missing MCPs by calling APIs directly; the skill relies on MCP-guaranteed behaviors (MSA renumbering lookups, JSON path normalization, first/last day M&IE math).

Workflow Selection

Workflow A: Full CR IGCE Build (Default)

User needs a complete cost-reimbursement estimate. Execute Steps 1 through 9. Triggers: "cost reimbursement IGCE," "CPFF estimate," "CPAF estimate," "CPIF estimate," "cost-plus estimate," "BAA cost estimate."

Workflow A+: SOW/PWS-Driven CR Build

User provides a requirement document instead of structured labor inputs. Execute Step 0 first, validate, then Steps 1-9. Triggers: "build a CR IGCE from this SOW," "price this BAA requirement," or when user provides requirement text and specifies cost-reimbursement.

Detection: If the user mentions a BAA and does not specify contract type, suggest CR as the most likely fit and confirm before proceeding.

Workflow B: CR Rate Positioning (Data Only, No Determination)

User has proposed rates and wants to see where they sit against market data. The skill returns the data and the CO decides reasonableness. The skill does not produce a "fair and reasonable" determination, a signed memo, or advisory text telling the CO how to negotiate.

Triggers: "is this CR rate reasonable," "validate these cost pool rates," "check this cost proposal."

Step 0 / GATE (MANDATORY FIRST — runs before any other Workflow B step).

Before any analysis, scan the user's prompt for these tokens (case-insensitive): "memo", "determination", "fair and reasonable", "price reasonableness", "reasonableness memo", "draft the memo", "for the file", "contract file", "document this", "memorandum".

If ANY of those tokens appear, the ENTIRE first response must be the refusal template below, emitted verbatim. No rate analysis. No CALC+ pull. No BLS pull. No "let me start with the analysis" preamble. No offer to continue with the memo if the user provides more info in the same response. Emit the template. Stop. Wait for the user's explicit choice.

Refusal template (emit verbatim):

> I can pull positioning data that shows where each proposed rate sits against CALC+ ceiling rates and BLS market wages. I cannot draft a price reasonableness memo, write a "fair and reasonable" determination, or recommend negotiation positions. Those are Contracting Officer decisions under FAR 15.404-1, not skill outputs. > > Tell me which you want: > > Option A — Positioning data only. I produce a table: per-LCAT proposed rate, CALC+ P25/P50/P75/P90 with sample size, BLS metro burdened equivalent. No verdict. No recommendation. You draw the conclusion. > > Option B — Memo template fill. You provide your rationale (what supports or doesn't support each rate) and your determination (fair and reasonable / not fair and reasonable / declining to determine). I drop your text verbatim into the memo template, add the benchmark tables underneath, mark it DRAFT. I will not originate determinations, recommend negotiation positions, or add hedging language. > > Which option?

Proceed to Steps 1-5 only after:

• User explicitly selects Option A, OR
• User provides Option B inputs (rationale text + determination text)

Hard prohibitions at ALL times (Option A or Option B):

• Do NOT write "the rate is fair and reasonable" or "not fair and reasonable" unless quoting the user's Option B text verbatim.
• Do NOT label rates "competitive," "aggressive," "outlier requiring justification," "premium warrants clarification," or any equivalent evaluative phrase. Use positional language only ("at P77," "above P50 by X%," "below P25").
• Do NOT recommend negotiation positions, evaluation notices, or counter-offer dollar figures.
• Do NOT write "Summary of findings" or "Determination" sections that draw conclusions the user has not supplied.

Workflow B steps (run only after Step 0 gate clears):

1. Collect the vendor's proposed labor categories, fully burdened rates (or cost pool breakdown), and any scope context (metro, fee type, experience tier).

1. For each LCAT, call mcp__gsa-calc__price_reasonableness_check(labor_category, proposed_rate, experience_min, education_level). The MCP returns count, min/max, median, IQR bounds, z-score, and percentile position. If sample size is below ~25 records, label the pool "directional only, not statistical validation."

1. For senior LCATs, also run the dual-pool flow (title-match + experience-match) and present both medians side-by-side.

1. If metro context matters, pull BLS OEWS for that metro via mcp__bls-oews__get_wage_data and present the P50/P75/P90 with the cost pool buildup at default fringe / overhead / G&A rates. This shows how the rate sits against local market labor independent of the CALC+ nationwide pool.

1. Present a neutral positioning summary using non-evaluative language:

• "Rate sits at CALC+ P77 (n=7, thin-corpus directional only)."
• "Above P50 by X%; stacked factors: [metro, seniority tier, aging, cost pool assumption]."
• "Below P25; pool composition or LCAT alignment may warrant CO review."
• "CR cost + fee often runs below CALC+ median because CALC+ reflects MAS ceiling (profit embedded) while CR separates cost and fee. CO sets the relevant comparison band."

1. Stop. Do not write "the rate is fair and reasonable." Do not recommend negotiation positions. Do not suggest "push back only if..." text. Do not label rates "competitive," "aggressive," "outlier requiring justification."

1. Memo output (Option B path only). If the user selected Option B at the Step 0 gate and supplied rationale + determination text, fill the memo template: benchmark tables from Steps 2-4, the user's rationale text verbatim in the findings section, the user's determination text verbatim in the Determination section. Do NOT paraphrase, do NOT add hedging, do NOT originate any conclusion text. Mark DRAFT. Use [Contracting Officer Name] and [Agency] placeholders. If Option A was selected, skip this step entirely.

Information to Collect

Ask for everything in a single pass. Provide defaults where noted. If any Required Input is ambiguous or missing for Workflow A (e.g., labor count without discipline, location without metro, fee type not specified), use AskUserQuestion to collect before pulling data. Do not guess.

Required Inputs

| Input | Description | Example | |-------|-------------|---------| | Labor categories | Job titles or SOC codes | Research Scientist, Data Analyst, PM | | Performance location | City/state or metro area | Bethesda, MD | | Staffing | Headcount per labor category | 3 researchers, 1 analyst, 1 PM | | Hours per year | Productive hours per person (default: 1,880) | 1,880 | | Period of performance | Base year + option years | Base + 2 OYs | | Fee type | CPFF, CPAF, or CPIF | CPFF | | Contract start date | For wage aging | 2026-10-01 |

Optional Inputs (Defaults Applied If Not Provided)

| Input | Default | Notes | |-------|---------|-------| | Fringe rate | 32% | FICA + health + retirement + PTO + workers' comp | | Overhead rate | 80% | Applied to labor + fringe | | G&A rate | 12% | Applied to subtotal | | FCCM rate | 0% | FAR 31.205-10 / CAS 414 Facilities Capital Cost of Money; applied to (Subtotal + G&A) as imputed cost. Default 0%. Populate only when CO supplies rate from contractor CASB Disclosure Statement Form CMF. | | CO-supplied DCAA rates | Defaults | Override rule: If the contracting officer supplies DCAA-audited indirect rates (from an approved Forward Pricing Rate Agreement or a current disclosure statement review), USE THOSE RATES instead of the 32/80/12 defaults. Document the source in Methodology Section 4 ("Cost Pool Basis: CO-supplied DCAA rates per FPRA dated [date]"). Do not revert to defaults when CO-audited rates are available; audited rates are the stronger basis. | | Fee percentage (CPFF) | 8% | Fixed fee as % of estimated cost | | Base fee (CPAF) | 3% | Minimum fee regardless of performance | | Award fee pool (CPAF) | 7% | Max additional fee based on evaluation | | Target fee (CPIF) | 8% | Fee at target cost | | Share ratio (CPIF) | 80/20 gov/contractor | Applied to over/underruns | | Min fee (CPIF) | 3% | Floor on fee | | Max fee (CPIF) | 12% | Ceiling on fee | | Escalation rate | 2.5%/yr | Applied to labor and travel | | Shift coverage | Business hours (8x5) default | Specify 24x7 / 16x7 / 12x5 if applicable; Step 0.5 computes FTE | | Travel destinations | None | City/state per destination | | Travel frequency | None | Trips/year per destination | | Travel duration | None | Nights per trip (0 = day trip) | | Number of travelers | All staff | Travelers per trip | | Travel months | Max monthly rate | Specific months if known | | FY for per diem | Current federal FY | Compute at build time (Oct-Sep cycle) | | Duty station / origin | Performance location | For City Pair airfare lookup | | NAICS code | None | Include in output if provided | | PSC code | None | Include in output if provided | | Partial start | Full year (12 months) | Specify months if base year is partial |

Cost Pool Rate Guidance

Provide this when the user is unsure:

| Component | Low | Mid | High | Notes | |-----------|-----|-----|------|-------| | Fringe | 25% | 32% | 40% | Higher for generous benefits, union shops | | Overhead | 60% | 80% | 120% | Higher for SCIF/cleared, large firms, R&D labs | | G&A | 8% | 12% | 18% | Higher for large corporate structures | | FCCM | 0% | 0% | 0.5% | FAR 31.205-10 / CAS 414; most small and mid firms don't book it. Populate only with CO-supplied rate. Layered after G&A, applied to (Subtotal + G&A). |

Fee Structure Reference

| Type | FAR Ref | Mechanism | Default | When Used | |------|---------|-----------|---------|-----------| | CPFF | 16.306 | Fixed fee set at award, unchanged by actual costs | 8% | Most common CR. R&D, studies, analysis. Must select form: Completion (d)(1) or Term (d)(2). | | CPAF | 16.305 | Base fee (0-3%) plus award pool (5-10%) earned on performance | 3% base + 7% pool | Performance-driven with periodic evaluation | | CPIF | 16.304 | Target fee adjusted by share ratio; bounded by min/max | 8% target, 80/20 share | Complex work with cost uncertainty but measurable efficiency |

Statutory fee caps: R&D contracts: 15% of estimated cost (10 USC 3322(a)). Non-R&D: no statutory cap but 10% is the practical ceiling per agency policy. BAA R&D awards typically settle in the 6-10% band; statutory caps are ceilings, not targets.

CPFF Completion Form vs Term Form (FAR 16.306(d)(1) and (d)(2)). Every CPFF IGCE must declare the form. The two are materially different contract structures:

• Completion Form (16.306(d)(1)): scope defined by a definite goal or end product. Contractor must complete and deliver the specified end product before the full fixed fee is earned. Use for CPFF where the deliverable is bounded: a report, a prototype, a validated analytical model, a concluded investigation.
• Term Form (16.306(d)(2)): scope described in general terms; contractor obligated to devote a specified level of effort over a stated PoP. Fee is earned across the LOE period regardless of technical outcome. Use for CPFF R&D where technical success is uncertain (BAAs, exploratory research, advisory services, studies without a predetermined end state).

Record the for

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Source & license

This open-source skill is cataloged on AgentStack and links to its original source — we do not rehost the code.

• Author: 1102tools
• Source: 1102tools/federal-contracting-skills
• License: MIT
• Homepage: https://1102tools.com

Install and usage instructions live in the source repository linked above.