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Change Order Accounting for Federal Subcontractors: Separate the Costs Before They Blur

A legitimate change can become difficult to recover when changed and unchanged costs are mixed together in the same labor, equipment, and material records.

Change documentation is not just a claims exercise performed months later. The strongest cost record usually starts on the day the changed work begins, when crews, quantities, equipment, and disruption can still be separated from base-scope performance.

Federal change-order accounting rules provide a useful model for subcontractors even when the exact clause is not flowed down.

The FAR can require separate accounts

FAR 52.243-6 permits the Contracting Officer to require separate change-order accounting when the estimated cost of a change or related series exceeds $100,000. The contractor must maintain separate accounts of segregable direct costs allocable to changed and unchanged work until the adjustment is resolved.

Official source: FAR 52.243-6 — Change Order Accounting.

Use the discipline at subcontract level

  • Create a unique cost code for each directed change.
  • Track labor hours by employee or crew and date.
  • Separate equipment hours, rentals, materials, freight, and subcontractor invoices.
  • Preserve credits for deleted work.
  • Record schedule and productivity impacts contemporaneously.
  • Keep the written direction and notice tied to the same change file.

Watch for proof standards that exceed the prime's own records

Prime subcontracts sometimes demand detailed proof as a condition of payment for changes. Review whether the required format is feasible and whether the prime can reject otherwise documented costs solely because a particular daily form was missed.

Do not wait for final pricing to start the file

A change may proceed before the parties agree on price. That makes contemporaneous segregation more important, not less. Pair cost records with reservation-of-rights language and the applicable notice process so performance does not silently become acceptance of uncompensated scope.