Comments on Proposed Changes to Profit Policy (DFARS Case 2000-D018)

In July 2000, the Department of Defense published a proposed revision of its guidelines for developing profit objectives used in contract negotiations. The existing profit policy guidelines address investment in facilities and equipment, performance risk, and contract type risk. For each profit factor, the contracting officer determines an appropriate value and applies it against a specified base to develop the profit objectives. The proposed revision would make the following changes to the profit guidelines: (1) include a fourth element--cost efficiency, that would allow the contracting officer to reward cost reduction efforts; (2) eliminate profit on investment in buildings and reduce the amount of profit derived from equipment investment; (3) increase the amount of profit based on performance risk; and (4) add general and administrative expenses to the cost base used to compute profit for performance risk, contract type risk, and cost efficiency. The decrease in profit for investment in facilities would be offset by the increased profit derived from performance risk and the inclusion of general and administrative expenses.