Implied Duty to Manage Subcontractors Does Not Include Incurred Cost Audits; ASBCA No. 59508, Appeal of Lockheed Martin Integrated Systems

Motion to dismiss the government’s claim for unsupported subcontractor costs is granted, where the government identified no contractual obligation or duty on the part of the prime contractor to audit its subcontracts or require its subcontractors to submit incurred cost submissions, and the government did not otherwise allege that the contractor did not adequately substantiate its billings during performance of the contract, that the subcontract services were not provided to its satisfaction, or that the costs billed were not incurred by the prime contractor.