BOARD OF CONTRACT APPEALS U.S. GOVERNMENT PRINTING OFFICE WASHINGTON, DC 20401 In the Matter of ) ) the Appeal of ) ) UNIVERSAL PRINTING COMPANY ) Docket No. GPO BCA 09-90 Jacket No. 563-541 ) Purchase Order K-0469 ) DECISION AND ORDER This appeal, timely filed by Universal Printing Company, Southwest Sales Office, Suite 212, 115 Executive Way, Dallas, Texas 75115 (hereinafter the Appellant or Contractor),1 is from the final decision, dated January 24, 1990, of Contracting Officer, Mr. Richard W. Wildbrett (hereinafter Contracting Officer), of the U.S. Government Printing Office's (hereinafter Respondent or GPO or Government), Dallas Regional Printing Procurement Office (hereinafter DRPPO) denying the Appellant's claim for additional compensation in the amount of $16,620.89 on Jacket No. 563-541, Purchase Order K-0469 (R4 File, Tabs I and L).2 For the reasons which follow, the Contracting Officer's decision is MODIFIED, and the Appellant's claim is ALLOWED to the fair and reasonable amount of $8,310.45.3 I. BACKGROUND4 On December 12, 1988, the DRPPO issued an Invitation for Bids (IFB) to procure 10,050 copies of a four (4) color saddle- stitched pamphlet,5 estimated at 48 pages plus cover, entitled "The Fifth Army Citizen Soldier" (Citizen Soldier) for the Department of the Army (Army) (R4 File, Tabs A). The IFB specifications provided, in pertinent part: MATERIAL FURNISHED: 94 pieces of double spaced, typewritten manuscript copy and approximately 90 to 100 full color photoprints or 35mm color transparencies. COMPOSITION: It is estimated that there will be 48 pages of text matter set flush left and right, on a 14 pica line length, in 11 on 12 point type. Heads will be set in 13 point boldface (upper and lower case) and subheads will be set in 11 on 12 point boldface (upper and lower case). PAGE MAKE-UP: Make up into pages 44 x 61 picas, including folios, (contractor to provide at the time of page make-up) consisting generally of three 14 pica columns. The Department will furnish a lay-out dummy, with the returned galley proofs, to be followed for exact page make-up. CORRECTIONS: All corrections, whether they be contractor's errors or author's alterations must be made prior to production of the final camera repro copy and must be cleanly mortised, spliced or stripped in. Paste over will not be acceptable. COPY PREPARATION: All textmatter prints in black ink. There will be approximately 90 to 100 four-color process illustrations ranging in size from 2-1/4 x 3-1/4" to full 8-1/2 x 11" page size. See "Schedule of Prices". * * * * * * * * * * FORMAT: Covers 1 through 4 print in four-color process. Text prints head to head in four-color process, no blanks. NOTE: This order must be produced on offset press equipment capable of printing four colors on one side of one sheet in one operation (four printing units). * * * * * * * * * * BINDING: Saddle[-]stitch in two places on the 11" dimension. PROOFS AND PRESS SHEET INSPECTION: Reader's galley proofs, page proofs, press progressive proofs, prior-to-production samples and an on-line press sheet inspection are required for this order. GALLEY PROOFS: Prior to page make-up, the contractor must submit for approval four (4) sets of reader's galley proofs, along with all furnished material. One set of the galley proofs must be waxed for mounting. The [Army] will paste up a page dummy for exact placement of the typematter and the halftone illustrations. The proofs and dummy will be withheld no more than fifteen (15) workdays from receipt in the GPO and the photoprints or transparencies for the illustrations will be furnished with the return of the proofs and dummy. PAGE PROOFS: After page make-up and prior to submission of the press proofs, the contractor must submit for approval four (4) sets of page proofs with all elements, text and illustrations in positions. The text may be Xerox or equal copy and the illustrations must be PMT or equal, cropped, sized and pasted in position. The page proofs will be withheld no more than fifteen (15) workdays after receipt in GPO. PROGRESSIVE PROOFS AND SAMPLES: Prior to printing, the contractor must submit for approval 4 complete sets of press proofs, collated in proof books and 6 prior-to- production samples. The proofs and samples must be printed on the paper and in the inks that will be used for the complete production and the samples must be trimmed, folded and bound in exact accordance with these specifications. NOTE: The samples may be hand folded and trimmed. The proofs and samples will be checked for quality and compliance with these specifications, approved or disapproved and returned to the contractor within fifteen (15) working days after receipt in the Government Printing Office, Dallas, TX. If, in the opinion of the GPO, the proofs are not a true representation of the furnished art, (objectionable or serious shift in hue, saturation, or lightness) or contain noticeable defects (misregister, voids, hickies, etc.) they will be rejected and returned to the contractor for correction and reproofing at no additional expense to the Government. The schedule . . . CANNOT be extended to allow for such reproofing. * * * * * * * * * * PRESS SHEET INSPECTION: A Government representative will inspect press sheets ar the beginning of production run to ensure that press sheets match the approved press proof(s) and to approve any required corrections or changes. The inspection will be at the contractor's plant and the GPO must be notified at least five workdays in advance of he commencement of production. . . . Delays caused by the contractor's failure to notify the GPO at least five workdays in advance of the production run or failure of the press sheets to match the approved press proofs will be the responsibility of the contractor and the schedule CANNOT be extended due to these delays. * * * * * * * * * * SCHEDULE: See "Notice of Compliance with Schedules", Article 12, Contract Clauses, GPO Contract Terms, dated December 1, 1987. Material will be furnished by-January 6, 1989 Galley proofs delivered to Dallas RPPO by-January 17, 1989 Galley proofs and dummy returned to contractor by-February 7, 1989 Page proofs delivered to Dallas RPPO by-February 17, 1989 Page proofs returned to contractor by-March 13, 1989 Progressive proofs delivered to Dallas RPPO by-March 24, 1989 Progressive proofs returned to contractor by-April 14, 1989 Ship complete on or before-May 5, 1989 * * * * * * * * * * DETERMINATION OF AWARD: The Government will determine the lowest bid by applying the prices quoted in the "Schedule of Prices" to the following units of production which are the estimated requirements to produce the products specified herein. These units do not constitute, nor ar they to be construed as, a guarantee of the volume of work required. The following item designations correspond to those listed in the "Schedule of Prices". 1. a. 1 2. a. 1 3. a. 3,285 4. a. (1) 1 b. 4 b. 4 b. 4 (2) 100 c. 150 d. 5 b. (1) 1 e. 50 (2) 100 See, R4 File, Tab A, pp. 1-3, 6-7.6 Since GPO Contract Terms was incorporated by reference, the contract also included a supplemental specification concerning "Author's Alterations", which states: Author's alterations consist of all marks made by the author at variance with the original manuscript as submitted to the contractor, but do not include corrections marked by the editor due to the failure of the contractor to follow copy literally. Author's alterations shall be charged on a per-line basis. In tabular matter, each line in a single column will be considered one line. Display lines will be paid for at the original line setting rate. The charge for deleting or transposing type lines without setting and inserting new material will be a one-line charge for each group, regardless of the number of lines in the group. Proofs of any deleted matter must be submitted with the voucher to obtain payment. If, after the pages are made up, the contractor is required to transpose type from one column to another, or from one page to another, the contractor will be entitled to charge only two lines of author's alterations per transposition. If the contractor is required to transpose within a makeup page such components as a table or space for an illustration, he/she will be entitled to charge two lines of alterations for each affected column. For example, transposition of a table which is printed across three columns will result in a charge of six lines. (a) Minimum charge. One minimum charge will be allowed for author's alterations each time proofs are submitted by the Government for alterations. The charge shall be indicated in the specifications. (b) Maximum charge. The maximum charge allowable for author's alterations on any one galley or page shall be an amount equal to the cost of setting that galley or page from manuscript copy. (c) Proof of charge. Charges for author's alterations will not be honored unless the voucher which is submitted to the Government Printing Office is supported by all marked proofs, or facsimiles thereof, showing author's alteration marks. Charges will not be allowed for proofing operations or materials which are due to the fault of the contractor. see, GPO Contract Terms, Supplemental Specifications, Art. 17 (Author's Alterations), as well as the standard GPO "Changes" clause, which provides, in pertinent part: (a) The Contracting Officer may at any time, by written order, and without notice to the sureties, if any, make changes within the general scope of this contract in any one or more of the following: (1) Drawings, designs, or specifications when the supplies furnished are to be specially manufactured for the Government in accordance with the drawings, designs, or specifications. * * * * * * * * * * (b) If any change causes an increase or decrease in the cost of, or the time required for, performance of any part of the work, whether or not changed by the order, the Contracting Officer shall make an equitable adjustment in the contract price, the delivery schedule, or both, and shall modify the contract. * * * * * * * * * * (e) Failure to agree to any adjustment shall be a dispute under article 5 "Disputes." However, nothing in this article shall excuse the contractor from proceeding with the contract as changed. See, GPO Contract Terms, Contract Clauses, Art. 4 (Changes).7 On December 22, 1988, the Appellant submitted the following bid for this job: 1. Composition (including 4 sets of galley proofs) a. First 48 pages (8-1/2 x 11") $ 2,886.00 b. Each additional page (8-1/2" x 11") or fraction thereof $ 57.00 c. Head and Caption lines-18 picas or fraction thereof-per page $ N/C d. Additional Proofs (8-1/2 x 11") if required-per page $ .08 e. Author's Alterations-per line $ .94 (A minimum of 15 lines will be allowed) NOTE: Charges for Author's Alterations will not be honored unless the voucher submitted to GPO is supported by a copy of the proofs showing all changes. 2. Page make-up (Including full page Illustration and 4 sets of page proofs) a. First 48 pages (8-1/2 x 11") $ 1,646.00 b. Each additional page (8-1/2 x 11") or fraction thereof $ 38.55 3. FILMS AND PROGRESSIVE PROOFS: Prices quoted are all- inclusive for the cost of all materials, opaquing and services including stripping of illustrations and positioning for compositioning. All measurements will be based on the printed image size rather than the trim size of the finished films. a. Four-color process separations (per square inch) $ 2.19 b. Four-color progressive proofs (includes one full-color proof and one progressive proof book on the stock and in the inks to be used) (each set) $ 875.00 4. PRINTING AND BINDING: Prices quoted must be all- inclusive for printing, binding and all paper. Makeready/ Running Per Setup 100 copies (1) (2) a. First 48 pages plus cover $ 3,840.00 $ 188.72 b. Additional 4 page signatures $ 1,224.00 $ 8.70 See, R4 File, Tab C; Complaint, p. 1. The Contractor's total estimated cost for the work was $40,461.75 (R4 File, Tab C). On January 4, 1989, the DRPPO issued Purchase Order No. K-0469 to the Appellant, who was the low bidder,8 awarding it the contract to produce 10,050 copies of the Citizen Soldier, at an estimated contract price of $40,461.75 (R4 File, Tab E). Although the Purchase Order indicates that the Appellant was expected to complete production and delivery of the Citizen Soldier by May 5, 1989, as provided in the contract schedule (R4 File, Tabs A, p. 6 and E), the final publication was not shipped until January 31, 1990, nearly nine months later. See, Complaint, p. 3; App. Mem., p. 4, ¶ 23. The reason for this delay is explained by the following undisputed chronology of events: 1. On January 5, 1989, in accordance with the contract schedule, the Appellant picked up the Government furnished material, namely, the typewritten manuscript copy for a 48 page, saddle-stitched pamphlet, with covers, as well as the photoprints and/or transparencies for the color illustrations. Complaint, p. 1; App. Mem., p. 1., ¶¶ 4, 5; Res. Brf., p. 2. 2. On January 9, 1989, after completing the typesetting from the manuscript copy, the Appellant delivered the galley proofs to the DRPPO, well ahead of the contract schedule (January 17, 1989). Complaint, p. 1; App. Mem., p. 1, ¶ 6; Res. Brf., p. 2. See, R4 File, Tab A, p. 6. 3. After the galley proofs were furnished to the DRPPO, the Respondent asked the Appellant to reset the type in two different type sizes so the Army should compare sizes with the original type, and decide which they wanted to use. The Contractor complied with these instructions, and on January 17, 1989, sent the DRPPO two additional galley proofs of the publication with the type changes. Complaint, p. 1; App. Mem., p. 2, ¶ 7. 4. On February 15, 1989, nearly a week later than the date provided in the contract schedule (February 7, 1989), the DRPPO returned the two galley proofs and a dummy layout, and instructed the Contractor to make page proofs. Complaint, p. 1; App. Mem., p. 2, ¶ 8; Res. Brf., p. 2. In order to comply with the DRPPO's directions, the Appellant had to go through the job twice, because the Army had used two different editors in making revisions, and set 164 typed lines of changes. The Contractor figures this additional work took eight (8) hours to accomplish, and none of that time was covered by its bid quote.9 Complaint, p. 1; App. Mem., p. 2, ¶ 8. 5. After making all of the author's alterations, the Appellant composed the pages, sized all illustrations, and then shot and stripped the entire job. On February 23, 1989, the Contractor furnished the required page proofs to the DRPPO.10 Complaint, p. 1; App. Mem., p. 2, ¶ 9. 6. Sometime between February 23, 1989, and July 15, 1989, the Respondent told the Appellant that there would be major changes in the Citizen Soldier, and that the Contractor would be receiving new copy and instructions from the Government. App. Mem., p. 2, ¶ 10. 7. On July 15, 1989, more than two months after the original contract completion date (May 5, 1989) had lapsed, the DRPPO furnished the Appellant with a computer disk, and instructed the Contractor to use it to reset the text, totally replacing the existing type.11 Complaint, p. 2; App. Mem., p. 2, ¶ 11. The art work, transparencies, or illustrations were not given to the Contractor at that time. The Appellant attempted to comply with the DRPPO's new instructions, but because the disk contained numerous unrecognizable codes, the Contract was unable to use it for that purpose, and informed GPO that it would need hard copy of the new type in order to read it. Complaint, p. 2; App. Mem., p. 2, ¶ 11. 8. On July 24, 1989, the Appellant received the hard copy it had requested from the DRPPO, as well as the art work, dummy layout, and other materials which were not furnished on July 15, 1989.12 Complaint, p. 2; App. Mem., p. 3, ¶ 12; Res. Brf., p. 2. Using this material, the Contractor was instructed to rest the type, make up the pages by pasting the new text on the existing art boards, and shoot progressive proofs. Complaint, p. 2; App. Mem., p. 3, ¶ 12; Res. Brf., p. 2. Pursuant to these directions, and following the hard copy as a guide, the Appellant began to reset the job from the furnished computer disk. However, after setting the new type in galley format, the Appellant discovered that the text had been completely rewritten and would not fit the existing page layout. Complaint, p. 2; App. Mem., p. 3, ¶12. As a result, none of the original page layouts could be salvaged, and a major part of the film already produced was unusable. Accordingly, the DRPPO instructed the Contractor to make new galley proofs and submit them along with the original pay layout. Complaint, p. 2.; App. Mem., p. 3, ¶ 12. 9. On August 1, 1989, the Appellant submitted the new galley proofs and the existing art boards to the DRPPO, as instructed. Complaint, p. 2; App. Mem., p. 3, ¶ 13. 10. Between August 1, 1989, and August 29, 1989, GPO and the Army revised the layouts and the art boards to conform to the new type. App. Mem., p. 3, ¶ 14. 11. On August 29, 1989, the Appellant received the galley proofs, as revised, with a new layout from the DRPPO. The new layout confirmed what the Contractor had discovered a month earlier, namely, that the pamphlet had undergone major changes, and that, as redesigned, the Citizen Soldier consisted of 28 pages of text, not the 48 pages specified in the IFB. Complaint, p. 2; App. Mem., p. 3, ¶ 15. Indeed, only the original outside cover was still usable. 12. Between August 29, 1989, and September 28, 1989, the Appellant proceeded to carry out the DRPPO's instructions to prepare progressive page proofs. In that regard, the Contractor unstripped all illustrations, including 48 four- color separations, scrapped all existing line film negatives, shot and stripped new line copy, restripped all four-color illustrations, and produced the progressive proofs. Complaint, p. 2; App. Mem., p. 3, ¶ 16. 13. On September 28, 1989, the Appellant submitted the progressive page proofs and six prior-to-production samples to the DRPPO.13 Complaint, p. 2; App. Mem., p. 3, ¶ 17; Res. Brf., p. 3. 14. On October 2, 1989, the Appellant wrote to the DRPPO asking for a contract modification to cover its additional costs in making the changes to the Citizen Soldier (R4 File, Tab F). See, infra. Complaint, p. 2; App. Mem., p. 3, ¶ 18. Subsequently, the Contractor also submitted separate claims for author's alterations, by letter dated January 9, 1990, and for film charges, by letter dated February 8, 1990 (R4 File, Tabs G and K).14 See, infra. App. Mem., pp. 3-4, ¶¶ 18-19. 15. On December 6, 1989, the DRPPO returned the progressive page proofs, which contained additional author's alterations, to the Appellant.15 Complaint, p. 2; App. Mem., p. 4, ¶ 20; Res. Brf., p. 4. 16. Between December 6, 1989 and December 27, 1989, the Contractor made the required changes, and then scheduled a press inspection. Although the inspection was originally scheduled for December 27, 1989, at the DRPPO's request it was postponed until January 9, 1990 (R4 File, Tab G).16 Complaint, p. 2; App. Mem., p. 4, ¶ 21. 17. On January 9, 1990, the DRPPO and the Army made the press inspection, approved the job, and the Appellant went into press production. Complaint, p. 3; App. Mem., p. 4, ¶ 22. 18. On January 31, 1990, the Contractor shipped the completed job to the Army, in accordance with the contract's distribution instructions (R4 File, Tab G). Complaint, p. 3; App. Mem., p. 4, ¶ 23. See, R4 File, Tab A, pp. 5-6 (Shipping Instructions). There is no dispute that the Appellant fully performed all of the work required under the contract in a timely manner and to the complete satisfaction of the Government. II. THE CONTRACTOR'S CLAIM As indicated above, this dispute began when the Appellant sent a letter to the DRPPO on October 2, 1989, providing the Respondent with information concerning its additional expenses and asking for a contract modification reimbursing it for the costs it would not otherwise have incurred but for the changes and delays connected with the work on the Citizen Soldier (R4 File, Tab F). In that letter, the Contractor itemized its claim, as follows: 1. a. Typesetting initial order per contract $ 2,886.00 e. Author's alterations 164 @ $ .94 154.16 Rerun two galleys @ $48.00 ea[ch] 96.00 2. a. Page make[-]up 1,646.00 Total first set of camera copy $ 4,782.16 1. a. Resetting a total of 32 pages Base price of $2,886.00 less 16 pages @ $ 57.00 ea[ch] (-$912.00) $ 1,974.00 e. Author's alterations 4 @ $ .94 3.76 2. a. Page make[-]up second round Base price of $1,646.00 less 16 pages @ $38.55 ea[ch] (-$616.80) 1,029.20 Total cost to reset and remake $ 3,006.96 Total [c]ost for typesetting $ 7,789.1217 3.a. Price would obviously remain as quoted as this is to be charged per square inch on work actually performed, and up to now, we have not remade any four-color [separations]. b. This price would also remain unchanged as we are still furnishing four sets of progressive proofs as originally specified. 4.a. (1) and (2). These prices would obviously change due to the extensive alterations. We are now running three [different press configuration] signatures plus cover.18 With this in mind, our new prices for these two items are as follows: a. (1) Setup $14,688.00 a. (2) Running per 100 copies 92.75 Provided the [Army] doesn't make additional alterations to the proofs, this should cover all of our additional costs. See, R4 File, Tab F, pp. 2-3. On January 9, 1990, the Contractor submitted another claim to the DRPPO for making the author's alterations indicated in the returned progressive page proofs (R4 File, Tab G). Noting that its higher costs were due to the fact that the changes were made to pages that had already been made up and photographed, the Appellant informed the Respondent that the new charges were: 1. Page 5-Redo process color map to knock out color in highlighted area, leaving the bold and light state borders, and drop back in to print all one color red $450.00 Set new line copy @ 2 lines $ 15.00 Shoot and strip new line copy $ 42.00 507.00 2. Page 7-Set new line copy @ 2 lines $ 15.00 Shoot and strip new line copy $ 42.00 57.00 3. Page 14-Set new copy @ 2 lines $ 15.00 Shoot and strip new line copy $ 42.00 57.00 4. Page 20-Set new line copy @ 2 lines $ 15.00 Shoot and strip new line copy $ 42.00 57.00 5. Page 28-Set new line copy @ 3 lines $ 20.00 Shoot and strip new line copy $ 50.00 70.00 6. Recomposite one set of four-color 40" flats and three black only flats @ $40.00 each 280.00 TOTAL COST FOR AUTHOR[']S ALTER- ATIONS MARKED ON THE PRESS PROGRESSIVE PROOFS $1,028.00 See, R4 File, Tab G, p. 1. In response to these claims, the Contracting Officer sent a letter, dated January 24, 1990, to the Contractor stating that, by his calculations, the changes made to the Citizen Soldier had reduced the contract price to $28,514.11 (R4 File, Tab I).19 In that regard, the Contracting Officer figured the allowable charges for the publication as follows: 1. Composition from manuscript, 48 pages + cover, and associated author's alterations $ 3,040.16 2. Page makeup, 36 pages + cover 1,337.60 3. Composition from new computer disk, 28 pages + cover, and associated author's alterations 1,977.76 4. Page makeup, 28 pages + cover 1,029.20 5. Four-color separation, 46 photographs for a total of 1,066 sq.in. 2,334.54 6. Four-color progressive proofs, 4 sets 2,500.00 7. Print, makeready 3,840.00 8. Print, running 11,426.85 9. Author's alterations to progressive proofs 1,028.00 TOTAL COST FOR THE ORDER $28,514.11 See, R4 File, Tab I. Attached to the Contracting Officer's letter was Contract Modification No. K-1, dated the same day and signed by him, decreasing the price of the pamphlet from an estimated cost of $40,461.75 to "the agreed upon firm cost of $28,514.11" (R4 File, Tab I). The Appellant disagreed with the Contracting Officer's calculations and refused to sign the Contract Modification. Instead, on January 29, 1990, the Contractor set a letter to the Contracting Officer, stating, in pertinent part: Your Contract Modification Number K-1, ... is in error. The total cost we agreed upon was as listed in our two letters, dated October 2, 1989 and January 9, 1990, to your office, not the $28,514.11 in the Contract Modification. Actual bottom line figure we computed was $38,707.00. In a phone conversation with Mr. Bollinger of your office we expressed a willingness to compromise on one minor charge ($96.00 to return galleys) even though that was the amount charged us. We do not agree on any other reduction. See, R4 File, Tab J. The record discloses that the parties discussed their dispute over the telephone on February 7, 1990 (R4 File, Tab K). The following day, the Appellant wrote another letter to the Contracting Officer which confirmed their conversation, and said, in pertinent part: Our charges for Author's Alterations were fair and reasonable. We responded to the alteration in the manner we did for the convenience of the Government, so that prices would flow with the original schedule of prices, and your representative gave verbal approval. The fact is we incurred a greater cost on the order up to the time we were instructed to scrap what we had done and start over than we estimated. But, because your representative requested we reply with a cost quickly, we replied with estimated figures in lieu of actual figures. These estimated figures were low by $6,428.00 but, since we had already furnished them to you, we were willing to honor them. Now, 114 days after your representative accepts our figure, you make a unilateral decision to reduce it $10,192.89. Since you have refused to honor the figures we submitted in October, we submit to you the following: 1. Original estimated cost for forty-eight pages plus cover is $40,461.75. 2. Having done all the typesetting, page make[-]up, camera and stripping on the original copy, we completed approximately 50% of the work to be done. Total invested up to this point [was] $20,230.00. 3. Starting over, we now produce 28 pages plus cover. If you prorate the original cost to the Government (as you apparently did to arrive at your figure) the cost for this is $24,900.00. Add to this the cost of alterations done after the progressive proofs were returned and the cost comes to $25,928.00. 4. In actuality, for all work performed up to the time we started over on this project, the total cost is $15,395.00. 5. The total cost for all work performed to produce the 28 page plus cover version is $29,740.00 bringing a total cost for the order to $45,135.00. We now request the Contract Modification be amended or a new one issued to reflect a total cost of $45,135.00 . . . We also request you make your final decision by February 15, 1990 . . . See, R4 File, Tab, pp. 1-2. By letter dated February 12, 1990, the Contracting Officer answered the Appellant's previous correspondence, reaffirming his decision concerning the allowable charges, and denying the Contractor's request for a new or revised Contract Modification (R4 File, Tab L). The Contracting Officer's reasons for his determination, in pertinent part, were as follows: . . . [T]he charges allowed, as itemized in my letter to you on January 24, 1990, are accurate. Each of those charges has been derived from your original quotation. Except for the charges attributable to author's alterations to press progress proofs, for which you are being paid in accordance with the list of charges in your letter of January 9, 1990, all of the charges allowed represent a proportionate value for work performed. With respect to the actual makeready and running of the end product, it is reasonable to expect that the cost of a 28- page product will be less than the cost of a 48-page product. Again, the reduction in cost is proportionate to the reduction in the number of pages in the finished product versus the number of pages in the original estimate. In every case, the charges I have allowed have been derived directly from your original quotation See, R4 File, Tab L. [Emphasis added.] The Appellant timely appealed the Contracting Officer's decision to the Board by letter dated February 16, 1990 (R4 File, Tab M).20 III. ISSUE PRESENTED The sole question in this appeal is: Is the Appellant entitled to additional compensation as an equitable adjustment because of the changes made in the Citizen Soldier by the Government, and if so, how much? IV. POSITIONS OF THE PARTIES21 The issue before the Board is essentially a question of which pricing mechanism-the Appellant's use of its bid estimates or the Respondent's proportional reduction approach-has the best chance of establishing a fair and reasonable price for the work performed under the contract for the Citizen Soldier before the Government decided to reduce the size of the pamphlet. The positions of both parties on this question, each of whom relies on the Contractor's original bid estimates for support to some extent, can be briefly summarized. In its appeal letter to the Board, the Appellant succinctly stated the heart of its case: [The Contracting Officer] is basing his decision to pay us only $28,514.11 for the order on the fact that ". . . it is reasonable to expect that the cost of a 28-page product will be less than the cost of a 48-page product." We agree wholeheartedly. In fact we are asking payment of $29,740.00 for the 28-page product. What we cannot accept is his decision to refuse payment on the work performed on the original pamphlet. For that we request payment of $15,395.00. See, R4 File, Tab M, p. 1.22 Simply stated, the Appellant wants to be paid for all of the pre-press work it performed on the pamphlet before the Army changed it to a smaller publication.23 See, Complaint, p. 5. First, the Appellant strenuously objects to the method chosen by the Respondent to calculate the revised contract price. Complaint, p. 5; App. Mem., p. 4. In that regard, the Contractor argues that extrapolating the contract price for the 28-page final version of the Citizen Solider by the simple expedient of prorating the original bid estimates for a booklet which was to have 20 more pages, is not only illogical and unreasonable, but the approach is without justification as a matter of industry practice and unfairly penalizes the printer performing the work. Complaint, p. 5; App. Mem., p. 4; RPTC, p. 4. Insofar as the Respondent relies on the language in the "Determination of Award" section of the contract which says that there is no guarantee of any specific units of production or any particular volume of work (R4 File, Tab A, p. 7), the Appellant believes that the contract provision has no relevance to this appeal. App. Mem., p. 4. Thus, the Contractor does not dispute the Respondent's interpretation of the "Determination of Award" language, in principle, but contends that the real issue here concerns how changes to the contract are to be priced when the "Schedule of Prices" is silent on the matter; i.e., all line items in the pricing schedule contemplate in a 48 page publication.24 Complaint p.5; App.Mem., p. 4. In the Appellant's view it is not possible to simply prorate the price for a 48-page pamphlet in order to determine the cost of production of a booklet containing 20 pages less.25 App. Mem., p. 5. Rather, the Contractor believes that its computation of the prices for the revised version of the Citizen Soldier is both fair, reasonable, and unimpeachable when all factors are considered. App. Mem., p. 5. Second, the Appellant contends that it is entitled to be reimbursed for the costs it incurred prior to the revision of the publication because the Contracting Officer did not manage the situation properly. App. Mem., p. 5. In that regard, the Contractor states that two courses were available to the Contracting Officer once he became aware that there would be extensive delays and substantial alterations in the product: (1) terminate the contract for the convenience of the Government, pay the Contractor for the work performed, and rebid the job; or (2) negotiate a firm fixed price for both the work already performed and the printing of the revised booklet before continuing with production under the contract.26 Id. (citing, PPR, Chap. VI, Sec. 3). The Contracting Office took neither step in this case, but rather allowed the job to go to press without any meaningful price negotiations. App. Mem., pp. 5-6. Third, the Appellant contends that the Contracting Officer was only interested in obtaining the Citizen Soldier for the Army at the lowest possible price, and was not concerned with the matter of fair compensation for the Contractor. App. Mem., p. 6. The Appellant says this is particularly true with respect to its claim for $6,427.90 for the cost of unutilized film work on the original specifications. Id. (citing, Complaint, p. 3). Since the Respondent has not challenged the reasonableness of the Contractor's charges,27 it should be liable for the amount claimed because the Government-ordered changes made the previously performed work unusable. Id. Furthermore, GPO's contention that the Appellant should bear the cost of the disputed film work because it was done prematurely without the approval of the Government, is not supported by the facts. The Contractor says that it is uncontradicted that GPO did, indeed, approve the initial composition of the original 48 page pamphlet, subject to author's alterations, which were made prior to performing the film work. Id. See also, RPTC, pp. 7-8. In the Appellant's view, the Respondent's claim that it had not told the Contractor to proceed with the camera work, merely disguises the real reason the films had to be scrapped; i.e., because the original pamphlet was completely redesigned by the Government. App. Mem., p. 6. Accordingly, for these reasons the Appellant asks the Board to overrule the Contracting Officer and sustain its claim. App. Mem., p. 7. The Respondent, on the other hand, argues that the Contracting Officer's conclusion that the Appellant was only entitled to be paid $28,514.11 for the work performed producing the Citizen Soldier is fully justified. Res. Brf., p. 5. The Contracting Officer based his calculations for the job on the Contractor's own initially quoted prices. RPTC, p. 5. Furthermore, the "Determination of Award" provisions of the contract placed the Contractor on notice that the number of pages could vary, more or less, from the contract estimates, and the Government would have to base any equitable adjustment on the bid figures in order to prorate the costs of the actual work (R4 File, Tab A, p. 7). Id. In this case, the Contracting Officer used those bid estimates to compute the amount due th Appellant for the author's alterations and other changes resulting from the Government's reduction of the size of the book (R4 File, Tab I, Items 1-3). RPTC, p. 6. However, the Contracting Officer did not reimburse the Contractor for film work because, at this stage, the Government had not approved anything beyond typesetting. RPTC, pp. 6-7. Consequently, if the Appellant produced negatives and film work which were later unusable, it did so prematurely and the Government did not have to pay for it. RPTC, p. 7. The Respondent also believes that the Appellant's equitable adjustment approach is illogical, undocumented, and insupportable. Res. Brf., p. 6. While the parties are in essential agreement with respect to the amount claimed for composition and page make-up, they disagree on the charges for progressive proofs and printing the pamphlet. Res. Brf., p. 5. As GPO sees it, the Contractor's figures for progressive proofs and setup make no sense, because it asks for the original contract price for fewer pages than estimated, on the one hand, while it says that 32 pages of setup work cost nearly four times more than the original 48 pages, on the other. Id. In any event, the Respondent contends that the Appellant has failed to provide sufficient documentation to support its claim. Id. Finally, the Respondent contends the law holds that when the Government deletes a separately priced item of work from a contract, the stated contract item price, rather than the amount the work would have cost, is the proper measure of the contract price adjustment. Res. Brf., pp. 5-6 (citing, Gregory & Reilly Associates, Inc., FAACAP No. 65-30, 65-2 BCA ¶ 4,918; Groesbeck-Durbin, Inc., DOT CAB No. 70-24, 72-1 BCA ¶ 9,251; Holtzen Construction Company, AGBCA No. 413, 75-2 BCA ¶ 11,378). Even though a contractor may suffer a loss of profit from application of this rule, the parties should be held to the bargained for item price in computing equitable adjustments. Res. Brf., p. 6. Moreover, a reduction in the amount of work does not authorize a repricing of the entire contract. Accordingly, the Respondent urges the Board to deny the appeal, and affirm the Contracting Officer's decision. Id. V. DECISION28 When this appeal was filed with the Board on February 16, 1990, no one expected that more than four years would pass before the Contractor received a decision. Consequently, the appeals process itself has probably compounded the frustration felt by the Appellant with this procurement.29 Some of the delay experienced in processing this case, of course, occurred because the Board, instead of directing an audit of the claim, allowed the parties to fritter away time discussing possible audit schemes.30 On two occasions recently, the Board has expressed its preference for audited claims. See, Banta Company, GPO BCA No. 03-91 (November 15, 1993), Sl. op. at 57; R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90, Decision on Motion for Reconsideration and Order (December 20, 1993), Sl. op. at 14 (hereinafter R.C. Swanson II). The state of this record, which is nothing short of awful, only confirms the Board in that opinion.31 The Board's time is too precious, considering its small staff and the demands of its heavy caseload, to spend doing the work of the parties by sorting out the various aspects of their respective claims. Accordingly, in the future, if in the judgment of the Board the clarification of a claim on appeal is necessary in order to resolve a dispute, it will remand the matter to the Contracting Officer, through Government Counsel, with instructions to have the claim audited, and will dismiss the appeal without prejudice until the audit is complete.32 Board Rules, Rule 13(c). See, National Council of Negro Women, LBCA No. 84-BCA-18, 84-2 BCA ¶ 17,436, at 86,827. The Board is confident that, in the long run, this new policy will buttress a major purpose of the Board's preliminary procedures, namely, obtaining fully disclosure of relevant and material facts. Board Rules, Preface to Rules, ¶ VI.D. The Board admits that it could done a better job policing the time it had allowed the parties to find a path out of the wilderness which is this record. However, the Respondent and the Appellant should also recognize that they are not blameless either. From the Government's standpoint, this procurement was not only plagued by a customer-agency which could not make up its mind, but the DRPPO mishandled the project in the face of the Army's uncertainty, and only made a bad situation worse. Generally, deletions of major portions of work are not authorized by the "Changes" clause. See, Nager Electric Company, Inc. and Keystone Engineering Corporation v. United States [16 CCF ¶ 80,367], 194 Ct.Cl. 835, 851-53, 442 F.2d 936, 945-46 (1971) (hereinafter Nager Electric Company); Capital Electric Company, GSBCA No., 5122, 81-2 BCA ¶ 15,281; Burroughs Corporation, GSBCA No. 5019, 79-2 BCA ¶ 14,083, mot. for reconsid. denied, 80-2 BCA ¶ 14,487; Celesco Industries, Inc., ASBCA No. 22251, 79-1 BCA ¶ 13,604; Toke Cleaners, IBCA 1008-10-73, 74-1 BCA ¶ 10,633. See generally, John Cibinic, Jr. and Ralph C. Nash, Jr., Administration of Government Contracts 2d ed., (The George Washington University, 1986), pp. 292-93 (hereinafter Cibinic and Nash). Instead, where, as here, the Government deletes significant portions of the work by contract modification, or otherwise, the matter is usually treated as a partial termination for convenience. See, J. W. Bateson Company v. United States [8 CCF ¶ 71,867], 308 F.2d 510 (5th Cir. 1962); H. L. Yoh Company, Inc. v. United States [8 CCF ¶ 71,469], 153 Ct.Cl. 104 (1961); Manis Drilling, IBCA No. 2658, 93-3 BCA ¶ 25,931; Celesco Industries, Inc., supra, 79-1 BCA ¶ 13,604; Frederick Construction Company, ASBCA No. 12108, 68-1 BCA ¶ 6,832; Doughboy Industries, Inc., FAACAP No. 67-3, 66-2 BCA ¶ 5,712. As explained by the Department of Interior Board of Contract Appeals: Both the Changes and the Termination for Convenience clauses provide a mechanism for the deletion of contract work. However, when major portions of the contract work are deleted, the Termination for Convenience clause is more appropriate where no additional work is substituted in its place. Similarly, deletion of a minor item of work is considered to be within the ordinary coverage of the Changes clause. Industrial Consultants, Inc., VABCA No. 3249, 91-3 BCA ¶ 24,326 at 121,551. The use of the Termination for Convenience clause is more appropriate for a reduction of the number of units or supplies to be delivered; elimination of identifiable items of work; reduction in the quantity of work required under the contract; or similar reductions in contract tasks. Celesco Industries, Inc., ASBCA No. 22251, 79-1 BCA ¶ 13,604 at 66,682-83. Manis Drilling, supra, 93-3 BCA ¶ 25,931, at 128,980. [Emphasis added.] See also, Skidmore, Owings & Merrill, ASBCA No. 5115, 60-1 BCA ¶ 2,570; Nolan Brothers, Inc., ASBCA No. 43778, 58-2 BCA ¶ 1,910. In this case, the Board finds itself in agreement with the Appellant's argument that rather than proceeding as if this was a normal contract modification situation, the Contracting Officer should have exercised the Government's rights under the contract's "Termination for the Convenience of the Government" clause, GPO Contract Terms, Contract Clauses, Art. 19, once he saw that the extensive author's alterations being made by the Army were causing major disruptions in the contract performance schedule, substantially reducing the product for which bids had been solicited, and increasing the Contractor's costs.33 Compare, e.g., R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90, Decision and Order (March 6, 1992) (a Department of Justice contract for typesetting legal briefs from manuscript copy was terminated for the convenience of the Government by GPO when the customer-agency decided it also wanted to transmit brief copy in an electronic format); Graphic Litho Company, Inc., GPO BCA 17-85 (September 30, 1988) (after extensive delays, a Department of Agriculture contract for the production of maps was terminated for convenience by GPO because the customer-agency still had not indicated when it would have the corrected Government-furnished material ready for the contractor). Certainly, there was ample opportunity for the Contracting Officer to do so, especially between February 23, 1989, and July 15, 1989, a period of nearly five months, when the job was in limbo. The Contracting Officer's failure to exercise his convenience termination authority directly contributed to the subsequent problems experienced by both parties in trying to assess the impact of the changes on the Appellant's costs, and helps to explain why their results are so wildly different.34 Celesco Industries, Inc., supra, 79-1 BCA ¶ 13,640, at 66,682. On the other hand, even though the Board believes that matters would have been cleaner if the Contracting Officer had terminated the contract for convenience at the beginning, instead of trying to fit all of the Army's alterations under the umbrella of the "Changes" clause, it is also aware that in most cases agency boards of contract appeals will not disturb a contracting officer's choice of procedure, particularly where the contractor has not challenged the exercise of that discretion. See, Condor Reliability Services, Inc., ASBCA No. 40538, 90-3 BCA ¶ 23,254; Goetz Demolition Company, ASBCA No. 39129, 90-3 BCA ¶ 23,241; Kinetic Engineering & Construction, Inc., ASBCA No. 30726, 89-1 BCA ¶ 21,397; Celesco Industries, Inc., supra, 79-1 BCA ¶ 13,604. Thus, the ASBCA has said: The question of whether work should be deleted under the Changes clause or the Termination clause is best left to the circumstances of each case and where the parties proceeded by means of a deductive change we will not alter that treatment absent a compelling reason. [Citation omitted.] Here, we see no reason whatever, and none is provided to us by the parties, to disturb the parties' treatment of the termination of identifiable items of work through a deductive change. Goetz Demolition Company, supra, 90-3 BCA ¶ 23,241, at 116,618. See also, Condor Reliability Services, Inc., supra, 90-3 BCA ¶ 23,254, at 116,675; Kinetic Engineering & Construction, Inc., supra, 89-1 BCA ¶ 21,397, at 107,871-72; Celesco Industries, Inc., supra, 79-1 BCA ¶ 13,604, at 66,683. From the outset, this dispute has been treated by the parties as one involving a deductive change under the "Changes" clause, and their respective monetary claims have been crafted with an eye toward traditional equitable adjustment rules. Since the parties have presented this appeal in its "Changes" clause form, and the Board can find no "compelling reason" to take a different approach, consistent with established Board policy it will leave their judgement undisturbed. See, Shepard Printing (1993), supra, Sl. op. at 14-15, fn. 20; Stephenson, Inc., supra, Sl. op. at 19-20, fn. 22; Stabbe Senter Press, GPO BCA 13-85 and 19-85 (May 12, 1989), Sl. op. at 53. The Appellant also made a significant contribution to the confused state of this record. No doubt is was too much to expect the Contractor to submit a pristine claim given the turmoil of the actual procurement. However, the history of this claim shows that the Appellant, both in substance and approach, fell far short of providing the sort of cooperation and assistance that is normally expected from someone asking for money from the Government. In that regard, the claim was deficient in at least three respects. First, the piecemeal fashion in which the Contractor submitted its claim to the Contracting Officer-i.e., the total claim was submitted in three parts over a five month period, on October 2, 1989, January 9, 1990, and February 8, 1990, respectively (R4 File, Tabs F, G, and K)-was hardly conducive to orderly processing. Since GPO's Contracting Officers are required by the agency's procurement rules to attempt to negotiate claim settlements before issuing final decisions, the casual manner in which the Appellant delivered the separate pieces of its total claim only frustrated the regulatory purpose. PPR, Chap. X, Sec. 1, ¶ 4. Second, and perhaps more importantly, the regulations describe a properly filed claim as possessing certain essential characteristics, namely: (1) it must be made in good faith; (2) it must honestly and accurately reflect of the contractor's belief of the contract liability of the Government; (3) it must be prepared from the contractor's books of account in accordance with Government recognized cost principles and accounting practices; (4) it must be accurate, complete, and current as of the date of submission; and (5) it must be prepared for the purpose of furnishing a basis for settlement. PPR, Chap. X, Sec. 1, ¶ 3. These requirements are somewhat mirrored in the Board Rules regarding Complaints. Board Rules, Rule 6(a). However, in this case the Appellant has submitted a claim which, to be charitable, may be described as practically indecipherable. For example, 65 percent of the Contractor's claim is in a single line item- makeready/setup charges (item 4.a(1)).35 Originally, the Appellant estimated that makeready/setup would cost $3,840.00 (R4 File, Tab C). By the time the Appellant had completed making all of the Army's alterations, that figure had ballooned to $14,688.00. To be blunt, the adjusted amount does not inspire much trust or confidence as a proper claim under the regulations because simple arithmetic shows that $14,688.00 is exactly 3.825 times $3,840.00. On the surface, therefore, rather than being an accurate and complete statement of the Appellant's costs as reflected in its accounting ledgers, or at least a rational and honest estimate of them, the revised makeready/setup charge looks suspiciously like the result of some arbitrary formula. Claims prepared on such a basis are uniformly rejected by agency boards of contract appeals.36 See, e.g., Ordnance Materials, Inc., ASBCA No. 32371, 88-3 BCA ¶ 20,910 (a contractor's appeal for an equitable adjustment was denied because his claim was based on the arbitrary formula he used in preparing his bid rather than on the actual increase in his costs stemming from the Government's change order). Lastly, the Appellant has not supported its claim with any relevant or material documentation showing how it arrived at its statement of costs.37 Apart from the material in the R4 File, only two pieces of documentary evidence were submitted by the Appellant in the context of this appeal-the price quotation from Colortek and its preliminary bid estimate for another GPO contract (Program C598-S)-and the Board had rejected both of them.38 See, Appellant's Letter of April 3, 1990, Exhibits A and B. As a consequence, despite the Board's requests from the outset of the appeal for information which would clarify the record either by means of a stipulation of facts or an audit of the Appellant's claim, and the opportunity afforded the parties to provide such evidence, the record in this case is in no better shape than it was when it crossed the Board's threshold four years ago. In the end, the Board is left to puzzle its way through an appeal record which is murky at best. Unfortunately, the Board's analytical powers do not include clairvoyance. However, the Board has a responsibility to put an end to this controversy. See, Banta Company, supra, Sl. op. at 24. See also, Lawrence D. Krause, AGBCA No. 76-118-4, 82-2 BCA ¶ 16,129, at 80,073; Johnson, Drake & Piper, Inc., ASBCA No. 9824, 65-2 BCA ¶ 4868, at 23,073. Accordingly, when the board considers the appeal record in light of traditional equitable adjustment principles, it believes, for the following reasons, that the Appellant is entitled to an additional reimbursement of $8,310.45 from the Government. A. Neither the Respondent's proportional approach nor the Appellant's unsupported estimates furnish an adequate basis for calculating the appropriate equitable adjustment in this case. Instead, the Board Believes that a fair and reasonable equitable adjustment is best determined by use of the "jury verdict" technique. Clearly, when the Government reduced the number of pages in the Citizen Soldier, it expected there would be a concomitant shrinkage in the contract price. See, Plaza Maya Limited Partnership, GSBCA No. 9086, 91-1 BCA ¶ 23,425; Goetz Demolition Company, supra, 90-3 BCA ¶ 23,241; Art Cap Company, Inc., ASBCA No. 3793, 58-1 BCA ¶ 1,623. Therefore, the central issue in this dispute concerns the quantum of relief; i.e., how much of equitable adjustment should the Appellant receive or, in the alternative, how much of a credit was due the Respondent because of the page reduction. Banta Company, supra, Sl. op. at 49. The answer to that question really depends on the scope of the reduction in the Appellant's contract performance which was brought about by the Government's change in the size of the publication. Consequently, when the Board looks at the record in this case, it finds itself in agreement with the ASBCA which remarked, in a similar situation: It is unfortunate that the parties never concentrated on the actual reduction of appellant's specific contractual obligations . . . thereby contributing to their fruitless efforts over a period of four years to reach an amicable resolution. Celesco Industries, Inc., supra, 79-1 BCA ¶ 13,604, at 66,682. At the outset, perhaps it is best to restate certain elemental principles concerning equitable adjustments so that the parties may have a clear understanding of the guideposts followed by the Board in resolving this dispute. First, an equitable adjustment is basically a corrective measure designed to keep a contractor whole when the Government modifies a contract. J.F. Shea Company, Inc. v. United States, 10 Cl.Ct. 620, 627 (1986) (citing, Bruce Construction Corporation v. United States, supra, 163 Cl.Ct. at 100, 324 F.2d at 518); Dick & Kirkman, Inc., VABCA Nos. 1545, 1581, 84-3 BCA ¶ 17,662, at 88,082; CRF, A Joint Venture of CEMCO, Inc. and R.R. Communications, Inc., ASBCA No. 17340, 76-1 BCA ¶ 11,857, at 56,805 (hereinafter CRF, A Joint Venture). Second, the purpose of an equitable adjustment is to place a contractor in the position it would have been in had the change not occurred; i.e., the adjustment also should not alter the contractor's profit or loss position from what it was before the change occurred.39 J.F. Shea Company, Inc. v. United States, supra 10 Cl.Ct. at 627; Pacific Architects & Engineers, Inc. v. United States, 203 Ct.Cl. 499, 508, 491 F.2d 734, 739 (Ct.Cl. 1974); Nager Electric Company, supra, 194 Ct.Cl. at 851-53, 442 F.2d at 945-46; Keco Industries, Inc. v. United States, 176 Ct.Cl. 983, 999-1002, 364 F.2d 838, 849-850 (1966), cert. denied, 386 U.S. 958 (1967); CRF, A Joint Venture, supra, 76-1 BCA ¶ 11,857, at 56,804; Hensel Phelphs Construction Company, ASBCA No. 15142, 71-1 BCA ¶ 8,796. See also, Cibinic and Nash, pp. 544-45. Third, the burden of proof in establishing the total amount of an equitable adjustment falls on the party who is claiming the benefit of the adjustment. See, Cibinic and Nash, p. 504. Thus, a contractor has the affirmative burden of proving the amount of money to which it is entitled. Michael-Mark, Ltd., IBCA Nos. 2697, 2890, 2891, 2892, 2893, 2894, 2895, 94-1 BCA ¶ 26,453; Lemar Construction Company, ASBCA Nos. 31161, 31719, 88-1 BCA ¶ 20,429; Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129; Onetta Boat Works, Inc., ENGBCA No. 3733, 81-2 BCA ¶ 15,279; Globe Construction Co., ASBCA No. 21069, 78-2 BCA ¶ 13,337. Meanwhile, the Government must establish the amount of the credit it took. Michael-Mark Ltd., supra, 94-1 BCA ¶ 26,453; Zurfluh Enterprises, Inc., VABCA No. 1941, 85-1 BCA ¶ 17, 789; CRF A Joint Venture, supra, 76-1 BCA ¶ 11,857; Hudson Garment Company, Inc., ASBCA No. 4645, 60-1 BCA ¶ 2,628. Whether that burden has been met is determined by the "preponderance of the evidence" test. Teledyne McCormick-Selph v. United States, 214 Ct.Cl. 672, 558 F.2d 1000 (1977); Wilbur Smith & Associates, Inc., ASBCA No. 35301, 89-3 BCA ¶ 22,025. See, Cibinic and Nash, p. 504. Fourth, the preferred method for establishing the amount of an equitable adjustment is through the introduction of actual cost data.40 See., e.g., Dawco Construction, Inc. v. United States, supra, 930 F.2d at 882; Cen-Vi-Ro of Texas v. United States, 210 Ct.Cl. 684 (1976); Buck Brown Contracting Co., IBCA No. 1119-7-76, 78-2 BCA ¶ 13,360; Engineered Systems, Inc., DOTCAB No. 75-5, 76-2 BCA ¶ 12,211; Bregman Construction Corporation, ASBCA No. 15020, 72-1 BCA ¶ 9,411. As a rule, actual costs are proved through the introduction of the contractor's accounting records, which will be accepted if they have been audited by the Government and are unrebutted. Celesco Industries, supra, 79-1 BCA ¶ 13,604. However, if the accounting records are not available due to no fault of the contractor, the costs may be established on the basis of estimates, if they are supported by detailed, substantiating data.41 See, e.g., R. G. Robbins & Company, ASBCA No. 27516, 83-1 BCA ¶ 16,420; Leopold Construction Company, ASBCA No. 23705, 81-2 BCA ¶ 15,277; Bailey Specialized Buildings, Inc., ASBCA No. 10576, 71-1 BCA ¶ 8,699. Finally, the touchstone for determining the amount of an equitable adjustment is the difference between what it reasonably would have cost to perform the work as originally required and what it reasonably cost to perform the work as changed.42 General Builders Supply Co. v. United States, 187 Ct.Cl. 477 (1969); Michael-Mark Ltd., supra, 94-1 BCA ¶ 26,453; Zurfluh Enterprises, Inc., supra, 85-1 BCA ¶ 17,789; Dick & Kirkman, Inc., supra, 84-3 BCA ¶ 17,662; Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129; Celesco Industries, supra, 79-1 BCA ¶ 13,604; Jack Picoult, VABCA No. 1221, 78-1 BCA ¶ 13,024. Whether a contractor's costs are reasonable is a question of fact depending on the circumstances.43 Nager Electric Company, supra, 194 Ct.Cl. at 851-53, 442 F.2d at 945-46. The principle claim in this case is a Government claim; i.e., the Respondent issued a contract modification which took a credit for the deleted work (R4 File, Tab I). Goetz Demolition Company, ASBCA No. 39129; 90-2 BCA ¶ 22,756; P.X. Engineering Company, supra, 89-2 BCA ¶ 21,859; ACS Construction Company, Inc. of Mississippi, supra, 87-1 BCA ¶ 19,660; Zurfluh Enterprises, Inc., supra, 85-1 BCA ¶ 17,789. Consequently, the Respondent was obligated to prove how much downward adjustment should be made.44 Nager Electric Company, supra, 194 Ct.Cl. at 853, 442 F.2d at 946; Griffin Services, Inc. v. General Services Administration, GSBCA Nos. 11022, 11178, 92-3 BCA ¶ 25,181; Jackson Engineering Company, Inc., supra, 85-3 BCA ¶ 18,418; R & E Electronics, Inc., VABCA Nos. 2227, 2299, 2300, 85-3 BCA ¶ 18,316; Globe Construction Co., supra, 78-2 BCA ¶ 13,337; G.L. Cory, Inc., GSBCA No. 4383, 77-2 BCA ¶ 12,824. In order to sustain its burden of proof, the Respondent had to show: (1) the extent to which the contract requirements were reduced; (2) the savings which resulted therefrom; (3) the Contractor's effort was, in fact, reduced by the contract change; and (4) the amount of downward price adjustment it took was reasonable.45 R & E Electronics, Inc., supra, 85-3 BCA ¶ 18,316; Zurfluh Enterprises, Inc., supra, 85-1 BCA ¶ 17,789; Celesco Industries, supra, 79-1 BCA ¶ 13,604; Southeastern Services, Inc., ASBCA No. 21278, 78-2 BCA ¶ 13,239; Industrial Textile Mills, Inc., ASBCA No. 18163, 73-2 BCA ¶ 10,232. From its analysis of the record, the Board concludes that the Respondent has not sustained its burden of proof. Specifically, the Government has failed to show that the Appellant's effort was, in fact, reduced by the contract change. See, Banta Company, supra, Sl. op. at 51 (citing, ACS Construction Company, Inc. of Mississippi, supra, 87-1 BCA ¶ 19,660). In that regard, the method chosen by the Respondent to revalue the contract price in this case is similar to the technique used by GPO in Banta Company, an appeal which also stemmed from the Government taking a credit for a reduced number of pages based on a manipulation of the original bid estimates, and the result is equally distorted. See, Banta Company, supra, Sl. op. at 21, fn. 31. The Board rejected the Respondent's theory in that case, reasoning, in pertinent part: . . . [T]he key to the Respondent's argument is its assumption that the changes which reduced the number of printed pages under each contract "undoubtedly" lowered the level of production effort, meant that less raw materials would be needed to perform the contracts, and were the cause of the "dramatic" reduction in the Appellant's potential losses under the contracts. [Citation to Respondent's brief omitted.] However, GPO has offered no evidence to support this premise beyond these mere allegations and self-serving and conclusory statements, which are insufficient to carry its burden of proof on the "level of effort" issue. Cf., Fry Communications, Inc./InfoConversion Joint Venture, GPO BCA 9-85, Decision on Remand (August 5, 1991), Sl. op. 32-33, fn. 31 (citing, Fry Communications, Inc./InfoConversion Joint Venture v. United States, 22 Ct.Cl. 497, 510 (1991); Tri-State Services of Texas, Inc., ASBCA No. 38010, 89-3 BCA ¶ 22,064; Gemini Services, Inc., ASBCA No. 30247, 86-1 BCA ¶ 18,736). . . . See, Banta Company, supra, Sl. op. 51-52. [Original emphasis.] Accord, Griffin Service, Inc. v. General Services Administration, supra, 92-3 BCA ¶ 25,181. Here, as in Banta Company, the fatal flaw in GPO's logic is its assumption that a significant reduction in the number of printed pages also substantially lowered the Appellant's production costs. Such reasoning ignores a basic tenet of the printing trade, namely, the most expensive copy of any book is the first one off the press. Consequently, press time, make- ready, labor, collating and binding costs would not have been significantly affected simply by reducing the number of pages. As the Board sees the pricing structure of the contract, each line item describes an integral part of a production process in which each step had to be accomplished before the next one could begin, whether the final product was 48 pages or 28 pages. Therefore, consistent with its approach in Banta Company, the Board rejects the Respondent's pricing stratagem by which the Government calculates its credit for a reduced number of pages by the simple expedient of prorating the original bid estimates, without making a realistic assessment of the impact of the changes on the contract work.46 Banta Company, supra, Sl. op. at 51-52. The Board recognizes that unlike Banta Company, where GPO solicited single fixed-price bids for the overall contract, here the Respondent asked for prices on a line item basis. However, that fact alone does not militate in favor of a different result. In the Board's view, GPO's use of different bidding schemes in the two contracts merely creates a distinction without a difference. The Respondent cites several cases for the proposition that the item price rather than the cost of the work is the proper measure of an equitable price adjustment when the Government deletes a separately priced item of work from a contract. Res.Brf., p. 6 (citing, Holtzen Construction Company, supra, 75-2 BCA ¶ 11,378; Groesbeck-Durbin, Inc., supra, 72-1 BCA ¶ 9,251; Gregory & Reilly Associates, Inc., supra, 65-2 BCA ¶ 4,918). These cases merely demonstrate the analytical pitfalls which can occur when too much reliance is place on construction contracts where supply or services contracts are involved. In construction contracts, the deleted items are usually complete in and of themselves and severable from the remainder of the contract work.47 See, Holtzen Construction Company, supra, 75-2 BCA ¶ 11,378, at 54,160. Rather, the Board believes that the better analogy to the present circumstances involves the service contract confronted by the General Services Board of Contract Appeals (GSBCA) in Griffin Services, Inc., supra. In that case, a building maintenance contractor was warded a cleaning contract for four Federal buildings. The contract price was an aggregate of monthly prices for the provision of services at all locations involved. At the same time, the contract also contained breakdowns of the monthly maintenance costs applicable to each building. When the Government closed one of the covered buildings, it partially terminated the contract and reduced the total contract price by he amount listed in the offer for that building. The GSBCA rejected the Government's pricing theory because it was inequitable for the following reason: The Government's premise for reducing the appellant's payment by the amount of appellant's offer in its bid for the individual building is that the contract consisted of line items rather than monthly prices. Thus, it maintains, the deletion of one building required the deletion of that line item in its entirety from the contract payment. We have previously held, however, that in contracts containing similar pricing schemes, the price per month must be take as an aggregate offer and not merely as the sum of severable line items. Griffin Services, Inc., GSBCA [No.] 10841, 92-2 BCA ¶ 24,945. Griffin Services, Inc. v. General Services Administration, supra, 92-3 BCA ¶ 25,181, at 125,486. [Emphasis added.] As the Board has already indicated, it believes that because of the integrated nature of the production process under the disputed contract, it is unreasonable to treat each line item task as if it were a severable item within the pricing structure of the disputed contract. Accordingly, for all of these reasons, the Board finds and concludes that the Government has failed to prove its claimed entitlement to a price reduction on the basis taken. As for the Appellant's equitable adjustment claim, that matter is easily disposed of. The Contractor also had a burden of proof in this case. First, it had to show the total amount of money to which it is entitled. See, Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129; Onetta Boat Works, Inc., supra, 81-2 BCA ¶ 15,279; Globe Construction Co., supra, 78-2 BCA ¶ 13,337; Click Company, Inc., GSBCA No. 3007, 70-1 BCA ¶ 8,335; Campbell Company, General Contractor, Inc., IBCA No. 722, 69-1 BCA ¶ 7,574. Second, the Appellant had to demonstrate the causal connection between its increased costs and the changes ordered by the Government. Banta Company, supra, Sl. op. at 55, fn. 69. See also, S.W. Electronics & Manufacturing Corporation v. United States, 228 Ct.Cl. 333, 655 F.2d 1078 (1981), aff'g, ASBCA No. 20698, 77-2 BCA ¶ 12,631; Jan-Beck Associates, supra, 87-2 BCA ¶ 19,831, at 100,322 (citing, Schoenfeld Associates, supra, 87-2 BCA ¶ 19,648). Third, the Contractor had to prove that its costs were reasonable. See, Celesco Industries, supra, 79-1 BCA ¶ 13,604; Triple "A" Machine Shop, Inc., ASBCA No. 21561, 78-1 BCA ¶ 13,065; Cal Constructors, ASBCA No. 21179, 78-1 BCA ¶ 12,992. See generally, Cibinic and Nash, pp. 504-05. The Contractor has shown none of these elements in this case. The Board does not need to repeat its detailed criticisms of the Appellant's claim. Suffice it to say, while the Contractor elected to establish its equitable adjustment costs on the basis of estimates, they are not supported by the detailed, substantiating information which is required. See, e.g., R.G. Robbins & Company, supra, 83-1 BCA ¶ 16,420; Leopold Construction Company, supra, 81-2 BCA ¶ 15,277; Bailey Specialized Buildings, Inc., supra, 71-1 BCA ¶ 8,699. Furthermore, the Board has already expressed its strong suspicion that the Appellant's revised makeready/setup charge is the product of some arbitrary formula, rather than an honest attempt to approximate its actual increase in costs resulting from the Government's change order, and hence is unacceptable on that basis. See, Ordnance Materials, Inc., supra, 88-3 BCA ¶ 20,910. Consequently, the Board has no benchmark by which to determine the reasonableness of the Contractor's costs for performing the work as originally required and as subsequently changed by the Government. Zurfluh Enterprises, Inc., supra, 85-1 BCA ¶ 17,789; Dick & Kirkman, Inc., supra, 84-3 BCA ¶ 17,662; Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129; Jack Picoult, supra, 78-1 BCA ¶ 13,024. Since the Board is unable to determine the reasonableness of the Appellant's costs on the basis of this record, it must also conclude that the Appellant has failed to sustain its burden of showing that its costs were reasonable under the circumstances of this case. Banta Company, supra, Sl. op. at 45 (citing, Michael, Inc., ASBCA No. 35653, 92-1 BCA ¶ 24,412, at 121,863). B. Applying the "jury verdict" method, the Board concludes that the Respondent took too large a reduction in the contract price because of the page deletions, and the Appellant is entitled to additional compensation of $8,310.45 as a fair and reasonable equitable adjustment in this case. Having rejected the cost computation methods advanced by both parties, the Board now finds itself on the horns of a dilemma. On the one hand, the Board cannot ignore the undisputed fact that the Government directed the Appellant to make numerous author's alterations to the Citizen Soldier on at least three separate occasions, caused the Contractor to produce multiple sets of varying galley and progressive page proofs, and otherwise delayed completion of the contract of the contract for nearly nine months. On the other hand, the Board knows that while there is no standard by which to measure the reasonableness of the Contractor's costs, it is nonetheless inescapable that the contract changes ordered by the Respondent had some cost impact. The law, however, provides a way out of this conundrum. In Banta Company, which also arose out of a contractor's claim that the Government took too large a credit for page deletions, the Board, as here, rejected the cost computations of both parties, and applied the so-called "jury verdict" method to establish a fair and reasonable equitable adjustment.48 Banta Company, supra, Sl. op. at 46-47. See also, Maryland Composition, supra, Sl. op. at 6 (Claim I, Group I-Jacket Nos. 356-532, 397-529, 424-224, 470-631, 476-450, 732-414, 461-096-citing, Johnson, Drake & Piper, Inc., supra, 65-2 BCA ¶ 4,868). Under the "jury verdict" technique, where a board or court finds an entitlement to an equitable adjustment but the evidence is incomplete, or the amount cannot be determined with any degree of mathematical precision, it may exercise its discretion to resolve conflicting evidence concerning the claim and arrive at a fair amount of compensation.49 Assurance Company v. United States, 813 F.2d 1202, 1205 (Fed. Cir. 1987); S.W. Electronics & Manufacturing Corporation v. United States, supra, 228 Ct.Cl. at 333, 655 F.2d at 1078; Electronic & Missile Facilities, Inc. v. United States, 189 Ct.Cl. 237, 416 F.2d 1345, 1358 (1969). See also, Dawco Construction, Inc., ASBCA No. 42120, 92-2 BCA ¶ 24,915; Gricoski Detective Agency, GSBCA Nos. 8901(7823), 8922(7824), 8923(7825), 8924(7826), 8925(7827), 8926(7828), 90-3 BCA ¶ 23,131; E.W. Eldridge, Inc., ENGBCA No. 5269, 90-3 BCA ¶ 23,080; Harvey C. Jones, Inc., IBCA Nos. 2070, 2150, 2151, 2152, 2153, 2467, 90-2 BCA ¶ 22,762. The key to the use of the "jury verdict" method is the presence of sufficient evidence to permit the determination of a fair and reasonable approximation of damages.50 J.E.T.S. Incorporated, ASBCA No. 28083, 88-2 BCA ¶ 20,540, at 103,859 (citing, Schuster Engineering, Inc. ASBCA Nos. 28760, 29306, 30683, 87-3 BCA ¶ 20,105). Thus, a trier of fact may allow recovery if it determines that: (1) clear proof of injury exists; (2) there is no more reliable method for computing damages; and (3) there is sufficient evidence to make a fair and reasonable approximation of damages.51 See, Dawco Construction, Inc. v. United States, supra, 930 F.2d at 880 (citing, WRB Corporation v. United States, 183 Ct.Cl. 409, 425 (1968)); Gricoski Detective Agency, supra, 90-3 BCA ¶ 23,131; Harvey C. Jones, Inc., supra, 90-2 BCA ¶ 22,762; J.E.T.S. Incorporated, supra, 88-2 BCA ¶ 20,540; Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129. In the Board's judgment, all of the elements necessary for a "jury verdict" award are present in this case. Consequently, that approach is the appropriate method for resolving this dispute.52 Banta Company, supra, Sl. op. at 49. Accord, Gricoski Detective Agency, supra, 90-3 BCA ¶ 23,131. In Banta Company, unlike here, the contractor's claim had been audited by the Respondent's OIG, and the Board was able to use the audit report, which was part of the record, as a basis for its recalculation of the amount of the Government's deduction.53 Banta Company, Inc., supra, Sl. op. at 57 (citing, S.W. Electronics & Manufacturing Corporation v. United States, supra, 228 Ct.Cl. 333, 655 F.2d at 1078; E.W. Eldridge, Inc., supra, 90-3 BCA ¶ 23,080, at 115,901; Schuster Engineering, Inc., supra, 87-3 BCA ¶ 20,105; Celesco Industries, supra, 79-1 BCA ¶ 13,604; Pavement Specialists, Inc., ASBCA No. 17410, 73-2 BCA ¶ 10,082). Obviously, that is not possible in this case. However, while an audit of the disputed claim would certainly have been helpful, the Board's research discloses that even without an audit report there are other ways to recompute a fair and reasonable equitable adjustment using the "jury verdict" method. One well-accepted device is simply to "split the difference" between the amount claimed by each party. See, Sentry Insurance, A Mutual Company, VABCA No. 2617, 91-3 BCA ¶ 24,094 (50 percent of the contractor's invoiced costs, plus 15 percent for markup); Gricoski Detective Agency, supra, 90-3 BCA ¶ 23,131 (amount which was midway between the contractor's original demand and the final bargaining position of the agency); Parkdale Building Maintenance, ENGBCA No. 5232, 90-1 BCA ¶ 22,319 (average of the contractor's and Government's estimates); Second Growth Forest Management, Inc., AGBCA No. 88-153-3, 89-1 BCA ¶ 21,569 (average of the contractor's and Government's production rates); The Morrison Company, ASBCA Nos. 26746, 26920, 26921, 83-1 BCA ¶ 16,417 (equitable adjustment was midway between the amounts which the parties claimed). See also, Delfour, Inc., VABCA Nos. 2049, 2215, 2539, 2540, 89-1 BCA ¶ 21,394 (50 percent of the amount claimed by the contractor). Given the record the Board has to deal with in this case, a "jury verdict" which sets the Appellant's recovery midway between its claim and the amount offered by the Respondent is the best way to break the deadlock between the parties and resolve the conflicting evidence concerning the amount that would be most reasonable and fair in light of the Government's changes. See, Gricoski Detective Agency, supra, 90-3 BCA ¶ 23,131, at 116,138-39; Parkdale Building Maintenance, supra, 90-1 BCA ¶ 22,319, at 112,094; Delfour, Inc., supra, 89-1 BCA ¶ 21,394, at 107,862; The Morrison Company, supra, 83-1 BCA ¶ 16,417, at 81,675. Accordingly, the Board will allow the Appellant's claim to the extent of $8,310.45, calculated as follows: Appellant's claim $45,135.00 Government's offer 28,514.11 Difference between claim and offer 16,620.89 50 percent of difference $ 8,310.45 The Board doubts that either party will be satisfied with this compromise verdict. However, since they both contributed to the shortcomings with this record, any dissatisfaction with the Board's decision should also be shared equally. VI. CONCLUSION In summary, the Board concludes that while the Respondent was entitled to some credit for the page deletions, it underestimated the impact of the deductive changes and took too much of a reduction in the price of the contract. Banta Company, supra, Sl. op. at 59 (citing, R & E Electronics, Inc., supra, 85-3 BCA ¶ 18,316; Zurfluh Enterprises, Inc., supra, 85-1 BCA ¶ 17,789; Celesco Industries, supra, 79-1 BCA ¶ 13,604). Consequently, while this decision allows the Government less of a credit for the deleted work, the Board believes that its "jury verdict" award represents a fair and reasonable proximation of the Contractor's costs resulting from the Government's page reductions. Id. (citing, E.W. Eldridge, Inc., supra, 90-3 BCA ¶ 23,080; Arctic Corner, supra, 86-3 BCA ¶ 19,304). Accord, Gricoski Detective Agency, supra, 90-3 BCA ¶ 23,131; Parkdale Building Maintenance, supra, 90-1 BCA ¶ 22,319; Delfour, Inc., supra, 89-1 BCA ¶ 21,394; The Morrison Company, supra, 83-1 BCA ¶16,417. Therefore, when the Board considers the quantum of relief issue in light of the evidence, cases, authorities, and applicable regulations, it ALLOWS the Appellant's claim to the fair and reasonable amount of $8,310.45.54 The Contracting Officer's decision is MODIFIED, accordingly. ORDER From the foregoing analysis, the Board finds and concludes that: (1) both the Appellant and the Respondent have miscalculated the appropriate equitable adjustment in this case; (2) the "jury verdict" technique is the best method for determining a fair and reasonable proximation of the Contractor's costs resulting from the Government's page reductions; and (3) applying the "jury verdict" method to this case, the Appellant is entitled to additional compensation of $8,310.45 as a fair and reasonable equitable adjustment. THEREFORE, the Board MODIFIES the Contracting Officer's decision and REMANDS the case with instructions that appropriate arrangements be made to pay the Contractor in accordance with this opinion. Banta Company, supra, Sl. op. at 62; R.C. Swanson II, supra, Sl. op. at 15. It is so Ordered. June 22, 1994 STUART M. FOSS Administrative Judge _______________ 1 The contract in dispute was awarded to the Appellant's central office located at 1701 Macklind Avenue, St. Louis, Missouri 63110. However, this appeal was filed by the Contractor's Southwest Sales Office in Dallas, Texas. 2 The Contracting Officer's appeal file, assembled pursuant to Rule 4 of the Board's Rules of Practice and Procedure, was delivered to the Board on March 22, 1990. GPO Instruction 110.12, Subject: Board of Contract Appeals Rules of Practice and Procedure (GPO Instruction 110.12), dated September 17, 1984 (Board Rules), Rule 4. It will be referred to hereafter as R4 File, with an appropriate tab letter(s) also indicated. The R4 File consists of 13 documents identified as Tabs A through M. 3 By letter dated April 3, 1990, the Appellant advised the Board that it had selected the optional Accelerated Procedure. Board Rules, Rules 12.1(b) and 12.3. However, numerous delays have characterized this case from the beginning. For example, although the Board docketed the Contractor's appeal letter on February 22, 1990, an agency reorganization soon afterward resulted in the reassignment of the Board's only Administrative Judge to another senior position within GPO. Consequently, it was not until March 11, 1991, more than a year after the appeal had been filed, that the Board's new Administrative Judge was able to conduct a prehearing telephone conference in the matter. See, Report of Prehearing Telephone Conference, dated May 23, 1991, p. 1 (RPTC). As a result of that conference, the Board asked the parties to formulate a stipulation of facts and verify the Appellant's claim (which was unaudited) by September 3, 1991, so that the Board could settle the record. Board Rules, Rule 13. See, Universal Printing Company, GPO BCA 9-90, Order (August 16, 1991), p. 2. For the next 30 months the Board had intermittent contact with the parties concerning their progress, and was assured that they were actively discussing the terms of an agreement which would establish a method for clarifying the record and assist the Board in resolving the dispute. Specifically, the Board was told that the parties were exploring the possibility of creating a joint panel to audit the Appellant's claim, and to make recommendations to the Board regarding an appropriate equitable adjustment. Based on this understanding, the Board, in effect, suspended further proceedings in the appeal. On March 25, 1994, the parties sent the Board a proposed stipulation which would have, inter alia, withdrawn the appeal and submitted the issues to binding arbitration. The Board appreciates that the idea of using alternate dispute resolution procedures is currently in vogue, see, 140 CONG. REC. No. 70, S6593-94 (daily ed. June 8, 1994) (statement of Sen. Wellstone); 24 Agencies Sign OFPP Pledge to Use ADR, 61 FED. CONT. REP. (BNA) No. 20, pp. 670-72 (May 23, 1994), although the concept is not without its critics, see, Richard C. Reuben, The Dark Side of ADR, 14 CAL. LAWYER No. 2, pp. 53-58 (February 1994). However, the simple fact is that the Board has no authority to divest itself of its jurisdiction over appeals from final decisions of GPO contracting officers. Board Rules, Preface to Rules, ¶ I. The Board's jurisdiction is not statutory, but rather is derivative and contractual, and flows from the Public Printer's right, as the agency officer authorized by law to contract on behalf of the United States, see, 44 U.S.C. § 502, to delegate his appeal authority to the Board by regulation and the provisions of the contract. See, GPO Instruction 110.10C, Subject: Establishment of the Board of Contract Appeals, dated September 17, 1984, ¶ 3; GPO Contract Terms, Solicitation Provisions, Supplemental Specifications, and Contract Clauses, GPO Publication 310.2, Effective December 1, 1987 (Rev. 9-88), Art. 5(b) (Disputes) (GPO Contract Terms). See also, The Wessel Company, Inc., GPO BCA 8-90 (February 28, 1992), Sl. op. at 32-33; Automated Datatron, Inc., GPO BCA 20-87 (March 31, 1989), Sl. op. at 4-5; Bay Printing, Inc., GPO BCA 16-85 (January 30, 1987); Peak Printers, Inc., GPO BCA 12-85 (November 16, 1986), Sl. op. at 6. Indeed, as an arm of the Legislative branch of Federal Government, GPO is not an "agency" covered by either the Contract Disputes Act of 1978 (CDA), 41 U.S.C. § 601 et seq., or the Administrative Procedure Act (APA), 5 U.S.C. § 551 et seq., including the 1990 and 1992 amendments to the APA concerning alternative means of dispute resolution in the administrative process, 5 U.S.C. § 571 et seq. See, Tatelbaum v. United States, 749 F.2d 729, 730 (Fed. Cir. 1984) (CDA does not apply to GPO contract disputes). Therefore, no legal basis exists for the Board to voluntarily waive its appellate authority over contract disputes involving GPO and the contractors who do business with the agency, and allow the parties to name their own final arbiters from the private sector. Thus, the Board would not approve the proposed stipulation. See, Universal Printing Company, supra, Order Settling the Record (April 15, 1994), p. 3 (citing, GPO Instruction 110.10C, Subject: Establishment of the Board of Contract Appeals, dated September 17, 1984, ¶¶ 4, 5). See also, Board Rules, Preface to Rules, ¶ I (Jurisdiction for Considering Appeals). Since nearly three years had elapsed without any meaningful progress on a stipulation of facts or a method to verify the Appellant's claim, the Board settled the record. See, Universal Printing Company, supra, Order Settling the Record, p. 4. Accordingly, notwithstanding the Appellant's election of the optional Accelerated Procedure, this matter, for all practical purposes, has been processed under the Board's regular procedure for handling cases submitted on the record without a hearing. Board Rules, Rule 11. See, McDonald & Eudy Printers, Inc., GPO BCA 06-91 (May 6, 1994), Sl. op. at 1, fn. 2. 4 Since the parties were unsuccessful in providing the Board with a stipulation of facts, see, note 3 supra, the factual description of this case is based on the R4 File, the Appellant's Complaint, dated March 1, 1990, the Respondent's Informal Brief, dated July 1, 1991 (Res. Brf.), and the Appellant's Post Conference Memorandum, dated July 29, 1991 (App. Mem.). The facts, which are essentially undisputed, are recited here only to the extent necessary for this decision. 5 In pamphlet binding, there are basically two methods of stitching the signatures together after they have been collated; i.e., saddle-stitching and side-stitching. In saddle-stitching, the booklet is placed on a saddle beneath a mechanical stitching head, and staples are forced through the backbone or spine of the booklet. This type of binding it the simplest and least expensive. See, Pocket Pal, International Paper Company, Memphis, Tennessee (14th ed., 1989), pp. 149-50. 6 In addition to being subject to all the terms and conditions of GPO Contract Terms, see, note 3 supra, the contract was also covered by the Respondent's Quality Assurance Through Attributes Program (R4 File, Tab A, p. 1). See, GPO Contract Terms, Quality Assurance Through Attributes Program for Printing and Binding, GPO Publication 310.1, dated September 2, 1986. 7 An examination of the "Changes" clause in GPO Contract Terms discloses that the wording is identical to the standard Government "Changes" clause for fixed-price contracts. See, FAR § 52.243-1 (Changes-Fixed-Price). 8 The bid abstract shows that three other printers competed for the work-Monarch Litho (bid of $151,637,85); Gulf Printing (bid of $85,539,75); and Hart Graphics (bid of $50,647.85) (R4 File, Tab D). 9 At first blush, the Appellant's statement that it did not include the labor and time necessary to accomplish the additional work in its original bid price would tend to discredit its own job estimates. See, KRW, Incorporated, DOTBCA No. 2572, 94-1 BCA ¶ 26,435, at 131,538. However, for at least the past 20 years, in order to avoid the subjective judgments inherent in charging for author's alterations on a time basis, such changes under GPO contracts have been paid for on a "per line" basis. GPO Contract Terms, Supplemental Specifications, Art. 17 (Author's Alterations). See, Maryland Composition, No GPOCAB Docket Number (December 30, 1974), Sl. op. at 7 (Claim II-Jacket No. 465-238). Consequently, the time taken by the Appellant to perform the additional work is not relevant. (It should be noted that Maryland Composition was decided by one of the ad hoc contract appeals panels which considered appeals from final decisions of GPO Contracting Officers prior to the establishment of the Board in 1984. GPO Instruction 110.10C, Subject: Establishment of the Board of Contract Appeals, dated September 17, 1984. Decisions of these ad hoc panels are cited by the Board in its decisions as GPOCAB. While the Board is not bound by the decisions of the ad hoc panels, its policy is to follow their rulings where applicable and appropriate. See, Shepard Printing, GPO BCA 23-92 (April 29, 1993), Sl. op. at 14, fn. 19 (hereinafter Shepard (1993)); R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90 (march 6, 1992), Sl. op. at 28, fn. 30; Stephenson, Inc., GPO BCA 02-88 (December 20, 1991), Sl. op. at 18, fn. 20; Chavis and Chavis Printing, GPO BCA 20-90 (February 6, 1991), Sl. op. at 9, fn. 9.). 10 Under the contract schedule, this task should have been accomplished by February 17, 1989 (R4 File, Tab A, p. 6). However, because the Respondent had returned the galley proofs and dummy layout on February 15, 1989, instead of February 7, 1989, the schedule was automatically extended a like amount of time by operation of the contract, so the Appellant actually set the page proofs to the DRPPO a day or two early. See, GPO Contract Terms, Contract Clauses, Art. 12.(c) (Extension of Schedules). 11 The Contractor notes that the original specifications only called for composition from "typewritten manuscript copy", not from a "floppy disk"; i.e., from hard copy and not by electronic means. Complaint, p. 2; App. Mem., p. 2, ¶ 11. See, R4 File, Tab A, p. 1 (Material Furnished). 12 The Respondent recalls this as occurring on July 21, 1989. Res. Brf., p. 2. 13 The Respondent recalls this as occurring on September 27, 1989. Res. Brf., p. 3. 14 According to the Appellant, all of these charges were either approved by the Contract Administrator or are undisputed. App. Mem., pp. 3-4, ¶¶ 18, 19. See, R4 File, Tab K. In that regard, the record indicates that the DRPPO's Contractor Administrator for the contract in dispute was Bill Bollinger (R4 File, Tabs G and J). See also, Complaint, p. 3. 15 Accompanying the proofs was a letter from the Contracting Officer to the Appellant telling it to proceed with the production run once it made the two necessary corrections; i.e., (1) the author's alterations on pages 5, 7, 14, 20 and 28, as marked on the proofs; and (2) deleting the brown screen from the red screened Fifth Army area of the illustration on page 5. See, Letter from R. W. Wildbrett, Contract Officer to Morey Mast, Universal Printing Company, dated December 6, 1989. The Contracting Officer's letter was not in the R4 File, but rather was furnished to the Board by the Appellant, as an attachment to its letter of June 11, 1991, in which it commented on the RPTC and restated its position in this appeal. See, Letter from Morey Mast, Sales Manager, Southwest Region, Universal Printing Company, to the Board of Contract Appeals, dated June 11, 1991. Although the Board is willing to believe that the Contracting Officer's failure to make this letter part of the R4 File was unintentional, there is also no doubt that this document was pertinent to appeal and should have been included. In that regard, the Government's obligation in preparing the appeal file is to search its records diligently so that it submits to the Board as complete a file as may be assembled under the circumstances. It goes without saying that the Government may not, with respect to those documents actually reviewed during compilation of the appeal file, limit inclusion only to those documents which support its position. It should be emphasized that selective omission of pertinent documents is contrary to the requirements of Rule 4 of the Board Rules. See, P.J. Dick Contracting, Inc., VABCA No. 3177R-82R, 93-1 BCA ¶ 25,263, at 125,838. See also, Bethlehem Steel Corporation, ASBCA No. 29459, 86-3 BCA ¶ 19,159. 16 The Board assumes that the postponement was due to the Christmas-New Year's holiday season. As the Board has remarked in the past, customarily little work is accomplished at that time of year in the typical Government agency or business firm. See, Graphics Image, Inc., GPO BCA 13-92 (August 31, 1992), Sl. op. at 15, fn. 17. 17 On January 11, 1990, the Contractor revised its claim by deleting the $96.00 charge for rerunning two galleys, thus changing the total cost for typesetting to $7,693.12 (R4 File, Tabs F, p. 2, and J). 18 The bracketed words were inserted in place of the word "mixed", which was crossed out (R4 File, Tab F, p. 3). 19 The appeal file contains a handwritten document entitled "Recap-Charges for J 563-541" which shows the computations made by the Contract Compliance Officer in arriving at the revised contract price (R4 File, Tab H). RPTC, pp. 2, 7; Res. Brf., p. 2. Essentially, the Contract Compliance Officer accepted the Appellant's figures for: (a) typesetting the pamphlet as initially ordered and making 164 line of author's alterations ($2,886.00 + 154.16 = $3,040.16); (b) resetting the Citizen Soldier as a 32 page publication and making 4 lines of author's alterations ($2,886.00 - 912.00 + 3.76 = $1,997.76); (c) the page make-up for the revised pamphlet ($1,646.00 - $616.80 = $1,029.20); and (d) the entire claim for making the author's alterations on the progressive page proofs ($1,028.00). On the other hand, the Contract Compliance Officer rejected the Contractor's calculations for: (a) the page make-up on the original order ($1,646.00 for 48 pages); (b) the makeready/setup charges for the revised publication ($14,688.00); and (c) the new running rate of $92.75 (which would have made the cost for printing 1,050 copies of the Citizen Soldier $13,912.50). Instead, the Contract Compliance Officer recomputed these costs. First, he reduced the page make-up cost on the original order by $308.40 (40 pages at the additional page rate in the Appellant's bid of $38.55 per page) to $1,337.60. Then for printing and binding costs, the Contract Compliance Officer: (a) retained the makeready/setup charges in the original bid estimate ($3,840.00); (b) established a new running rate of $180.02 by subtracting the additional rate for four page signatures ($8.70) from the bid estimate for running 100 copies ($188.72); (c) calculated a signature rate of $60.00 (based on a 16 page signature) by dividing the new running rate ($180.02) by the number of signatures in the originally ordered booklet (48 ( 16 = 3); and (d) used the signature rate to compute the cost of running 1,050 copies of the Citizen Soldier in three different configurations ($10,552.50) and the additional rate to calculate the cost of running the covers ($874.35), for a total printing, binding, and distributing cost of $11,426.85. Finally, for the film and proof work, the Contracting Officer: (a) calculated a price for four-color process separations of $2,334.54 by determining that the 46 photographs in the Citizen Soldier totaled 1,066 square inches and then multiplying that figure by the bid estimate price ($2.19); and (b) computed a cost of $2,500.00 for the progressive proofs by applying the bid estimate rate to the four sets of proofs produced (4 sets x $875.00 each set = $3,500.00) and then subtracting the cost of two press forms (there were 7 press forms in each set of proofs, so the cost of each press form was $125.00; i.e., $875.00 ( 7 = $125.00) from each of the four sets ($125.00 x 2 press forms = $250.00 x 4 sets = $1,000.00). See generally, Res. Brf., pp. 2-5. 20 A question arose during the processing of this appeal about whether or not the Contracting Officer's letter of January 24, 1990, was a "final decision" within the meaning of GPO's regulations-a condition precedent to the Board's assertion of jurisdiction in this appeal (R4 File, Tab I). See, Printing Procurement regulation, GPO Publication 305.3 (September 1, 1988), Chap. X, Sec. 1, ¶ 4.d (PPR). See also, Board Rules, Preface to Rules, ¶ I (Jurisdiction for Considering Appeals). The parties, from the outset, have construed this letter to be a final decision, and the Contracting Officer's subsequent letters of February 12, 1990 and April 8, 1994, only reaffirmed that view. See, R4 File, Tab L; Letter from R.W. Wildbrett, Contract Officer to Board of Contract Appeals, dated April 8, 1994. In any event, attached to the Contracting Officer's letter of January 24, 1990, was Contract Modification K-1, dated the same day, decreasing the price of the Appellant's contract from $40,461.75 to the "firm cost" of $28,514.11 (R4 File, Tab I). It is well-settled that a unilateral contract modification by the Government reducing the price of a contract constitutes a formal and final action equivalent to a final decision by the Contracting Officer from which a contractor can appeal. See, Goetz Demotion Company, ASBCA No. 39129, 90-2 BCA ¶ 22,756; P.X. Engineering Company, ASBCA No. 38215, 89-2 BCA ¶ 21,859; Systron Donner, Inertial Division, ASBCA No. 31148, 87-3 BCA ¶ 20,066. Like section 8(e) of the CDA, 41 U.S.C. § 607(e), the Board Rules contemplate the just and inexpensive resolution of disputes without unnecessary delay. Board Rules, Preface to Rules, ¶ VI.C. (Administration and Interpretation of Rules). Consequently, the Board agrees with the Armed Services Board of Contract Appeals (ASBCA) that, as a rule, a contractor is not required to go through the "charade" of filing a claim and requesting a decision from the Contracting Officer where, as here, the Government has issued a unilateral modification reducing the contract price, because that would be an unnecessary, delaying and expensive formality. See, P.X. Engineering Company, supra, 89-2 BCA 21,859, at 109,952. 21 As indicated previously, both parties submitted written briefs setting forth their respective positions on the issues in this appeal. See, note 4 supra. The Board's understanding of the parties is based on the Appellant's Complaint, the formal briefs filed by the parties, and the discussions at the prehearing conference on March 11, 1991. 22 Although it would appear from the appeal letter that the gap between the parties with respect to the contract price for the 28-page pamphlet is only $1,225.89-a modest difference of opinion in the context of this case-in reality, their disagreement is much larger. In that regard, it is clear that the Contractor is willing to accept $29,740.00 only for the 28-page Citizen Soldier, while the Contracting Officer tendered $28,514.11 in payment for the whole job. 23 At the conclusion of the prehearing telephone conference on March 1, 1991, there was no disagreement about the fact that the Government owed the Appellant at least $28,514.11, which had not yet been paid to the Contractor. RPTC, p. 9, fn. 1. GPO's Printing Procurement Regulation provides: "In the event of an appeal, the amount, if any, determined to be payable in the decision of the Contracting Officer, less any portion previously paid, should be paid in advance of any decision by the board without prejudice to the rights of either party or the appeal." See, PPR, Chap. X, Sec. 1, ¶ 5.g. The Board has been advised that since the conference the Contractor has submitted a proper invoice for the undisputed amount of $28,514.00, and has been paid. Therefore, the amount of the original claim still in controversy is $16,620.89 ($15,395.00 + 1,225.89). 24 The crux of the Appellant's argument is that the Government's changes to the publication were so extensive that the apart from the separation of the front and outside covers and restripping, all of the work it had done on the 48-page pamphlet was lost and it had to start the pre-press work afresh. RPTC, p. 4. Thus, the Appellant believes that it is justified in asking the Government to reimburse it for the preparatory work it did on the 48-page pamphlet which could not be salvaged for the final product. RPTC, pp. 4-5, 8. Insofar as the Contractor also contends that the gap between the original order for a 48-page Citizen Soldier and the final 28-page product was so large as to be unconscionable, see, RPTC, p. 8, its argument is tantamount to an allegation that the Respondent was acting in bad faith. However, the Board has held on numerous occasions that because of the strong presumption that Government officials properly and honestly carry out their functions, an allegation of bad faith must be established by "well-nigh irrefragable" proof. See, e.g., Sterling Printing, Inc., GPO BCA 20-89 (March 28, 1994), Sl. op. at 23, fn. 35; Hurt's Printing Company, Inc., GPO BCA 27-92 (January 21, 1994), Sl. op. at 11, fn. 15; Shepard Printing (1993), supra, Sl. op. at 7-8, fn. 11; B. P. Printing and Office Supplies, GPO BCA 14-91 (August 10, 1992), Sl. op. at 16; The Standard Register Company, GPO BCA 4-86 (October 28, 1987); Sl. op. at 12-13. Accord, Karpak Data and Design, IBCA No. 2944 et al., 93-1 BCA ¶ 25,360; Local Contractors, Inc., ASBCA No. 37108, 92-1 BCA ¶ 24,491. The key to such evidence is that there must be a showing of a specific intent on the part of the Government to injure the contractor. Kalvar Corporation v. United States, 543 F.2d 1298, 1302 (Ct.Cl. 1976), cert. denied, 434 U.S. 830 (1977). See, Stephenson, Inc., supra, Sl. op. at 54. In the Board's view, no such "irrefragable" proof of the Respondent's bad faith exists in this record. Certainly, there is absolutely nothing to show that the employees of two separate Government entities-GPO and the Army-set out to harm the Appellant or that they acted in concert to achieve that specific result. See, e.g., Sterling Printing, Inc., supra, Sl. op. at 23, fn. 35; Stephenson, Inc., supra, Sl. op. at 57. 25 Among other things mentioned by the Appellant, the "Schedule of Prices" only asks for makeready/setup and running prices based on "four page signatures" (R4 File, Tab A, p. 9), and not on any other basis. App. Mem., p. 5. Furthermore, the Contractor says that the Contracting Officer ignored the most basic fact in the printing trade; i.e., that on the type of press used for the job, it costs more per page to produce the smaller size book (28 pages) than the larger one (48 pages). RPTC, p. 4. Consequently, reducing the size of the Citizen Soldier from 48 pages to 28 pages would produce savings only in the use of paper and ink, which would be minimal at best, and would not affected the costs for press time, make-ready, labor, collating and binding. App. Mem., p. 5. 26 Indeed, the Appellant says that if the Contracting Officer had informed it earlier in the production process of his intention to reprice the contract for the smaller version of the Citizen Soldier on the basis of prorating the original bid estimates, the Contract itself would most likely have refused to proceed, and demanded a termination for convenience. App. Mem., p. 6. 27 The Appellant enclosed two documents with its letter of April 3, 1990, to the Board, identified as Exhibits A and B, respectively. The first document was a price quotation from Colortek, Inc. (Colortek), a film shop located in Dallas, Texas, showing charges of $6,336.00 for separations and $6,469.00 for stripping work on a 40-page sample, plus cover, of the Citizen Solider. See, Letter from Morey Mast, Sales Manager, Southwest Region, Universal Printing Company to Board of Contract Appeals, dated April 3, 1990 (hereinafter Appellant's Letter of April 3, 1990), Exhibit A. Since Colortek's quote is dated March 27, 1990, it was obviously solicited by the Contractor solely for the purpose of this appeal. The Board assumes that Colortek's quotation is intended to show that the Appellant's charges for the same work are in accord with prices in the industry, and hence its claim for film work is reasonable. The Board would be willing to accept Colortek's price quotation as evidence if the Appellant had subcontracted the work to that firm, see, Fireman's Fund Insurance Company, ASBCA No. 39666, 91-1 BCA ¶ 23,372 (citing, Delco Electronics Corporation v. United States [35 CCF ¶ 75,679], 17 Cl.Ct. 302 (1989)), or there was some other proof of privity of contract between them; e.g., producer-supplier. See, Sterling Printing, Inc., supra, Sl. op. at 8 and 35, fns. 13 and 47 (report on quality of paper from contractor's paper supplier). Accord, Atlantic Electric Company, GSBCA No. 6016, 83-1 BCA ¶ 16,484. In the absence of such proof, Colortek's price quotation is entitled to little evidentiary weight beyond that of argument. Board Rules, Rule 13(c). See, RD Printing Associates, Inc., GPO BCA 02-92 (December 16, 1992), Sl. op. 10 and 13, fns. 11 and 15 (memorandum from customer-agency employee supporting contractor's interpretation of the contract, and revised pricing specification from the succeeding contract). See also, Merchant's Service Company, No GPOCAB Docket Number [GPO Contract Nos. 373 and 374] (February 11, 1980), Sl. op. at 18-20. Accord, Hildebrand and Day, AGBCA No. 82-183-1, 82-188-1, 83-1 BCA ¶ 16,321 (affidavit attached to brief). The second document, a preliminary estimate prepared by the Appellant on March 29, 1990, for bid purposes on another GPO contract-Program C598-S-covering the production of a saddle- stitched pamphlet with a page count of between 24 to 48 pages, is also of no help to the Contractor in proving its claim. See, Appellant's Letter of April 3, 1990, Exhibit B. The Contractor contends that its estimate for Program C598-S, which does not include film work, will demonstrate the unreasonableness of the Contracting Officer's decision to calculate the revised contract price by prorating the original bid estimates. Apart from the "bootstrap" nature of this argument, the Board has already indicated that its narrow jurisdictional mandate prevents it from considering matters pertaining to other contracts unrelated to the one involved in this case. See, note 3 supra (and cases cited therein). Consequently, except for default termination cases where a reprocurement contract is under review because the contractor is contesting the assessment of excess reprocurement costs, see, e.g., Sterling Printing, Inc., supra, Sl. op. at 55-63, the Board has consistently refused to consider matters outside the scope of the disputed contract. See, Shepard Printing (1993), supra, Sl. op. at 7, fn. 11; B. P. Printing and Office Supplies, supra, Sl. op. at 14-15. Accordingly, the Board will not consider the Appellant's estimates for Program C598-S in the context of this case. 28 The record on which the Board's decision is based consists of: (a) the Appellant's Complaint; (b) the R4 File, Tabs A-M; (c) the Report of Prehearing Telephone Conference; (d) the Respondent's Informal Brief; and (e) the Appellant's Post Conference Memorandum. 29 The extent of the Contractor's palpable frustration can be seen in its letter of October 2, 1989, when it told the DRPPO: ". . . [B]oy are we going to be happy to see this job come to an end." See, R4 File, Tab F, p. 3. 30 See, note 3 supra. 31 The appeal was submitted to the Board for resolution on the record. Board Rules, Rule 11. See, RPTC, p. 2; Appellant's Letter of April 3, 1990. It is well-settled that even though an appellant selects a Rule 11 proceeding for its appeal, it is still responsible for providing adequate evidence to allow a contract appeals board to make a finding in its favor. Shumate Constructors, Inc., VABCA No. 2772, 90-3 BCA ¶ 22,946, at 115,192 (citing, Jan-Beck Associates, VABCA Nos. 2107 et al., 87-2 BCA ¶ 19,831; Shoenfeld Associates, VABCA Nos. 2104, 2510-2517, 87-2 BCA ¶ 19,648). Although there is enough undisputed evidence here to decide the issues, the record contains certain evidentiary conflicts which perhaps could have resolved if the parties had agreed to a stipulation of facts, on the one hand, or a method for auditing the Appellant's claim, on the other, as requested by the Board. See, note 3 supra. However, the Board cannot avoid its responsibility, and we make our decision on the record as we find it. Shumate Constructors, Inc., supra, 90-3 BCA ¶ 22,946, at 115,192. 32 Under GPO Contract Terms, where, as here, the pricing of any contract modification is in dispute, the Contracting Officer has the right to audit the contractor's books, records, documents and other data related to negotiating, pricing or performing the modification. See, GPO Contract Terms, Contract Clauses, Art. 40 (Audit-Sealed Bidding). The same right is accorded to GPO's Office of the Inspector General (OIG). Id. However, by its terms, this clause only applies when the contract amount exceeds $100,000.00. Consequently, the Board's policy, announced in this decision, merely extends the Government's auditing rights to sealed bid contracts of lesser value. The comparable contract clause for other types of contracts (e.g., cost-reimbursement, incentive, time-and-materials, labor-hour, or price redeterminable contracts, etc.) is GPO Contract Terms, Contract Clauses, Art. 42 (Audit-Negotiation). 33 Indeed, the observations made by the authors of the book "Getting It Printed: How to Work with Printers and Graphic Arts Services to Assure Quality, Stay on Schedule, and Control Costs", seem particularly apropos. In that regard, they say, in pertinent part: "Final costs almost always exceed quotes because of changes from the original specifications. . . . Most alterations take place during film preparation, not press or bindery work. Printers usually base estimates and quotes on specifications, not final copy. . . . Alterations also occur when customers change their minds between writing specifications and producing camera ready copy. . . . The cost of alterations varies from almost free to very expensive, depending on the nature of the changes and at what stage they occur. We use the rule of thumb that a change that costs $5 at the pasteup stage will cost $50 at the negative stage and $500 on press [in other words, at multiples of 1, 10 and 100]. . . . After negatives are stripped, any change in format such as a revised page count, a new trim size, or a different number of colors means major alteration costs. New formats require at least partial restripping and may require refiguring the entire job." Mark Beach, Steve Shepro, and Ken Russon, Getting It Printed: How to Work with Printers and Graphic Arts Services to Assure Quality, Stay on Schedule, and Control Costs, (Coast to Coast Books, Portland, Oregon, 1986), pp. 90-91 (hereinafter Beach, Shepro, and Russon). [Emphasis added.] 34 The regulations and case law make it clear that adjustments to the contract price on account of Government- ordered changes are on a cost basis. GPO Contract Terms, Contract Clauses, Art. 4.(b). See, Bruce Construction Corporation v. United States [9 CCF ¶ 72,325], 163 Ct.Cl. 97, 324 F.2d 516 (1963); ACS Construction Company, Inc. of Mississippi, ASBCA No. 33550, 87-1 BCA ¶ 19,660. 35 The unpaid cost of film work ($6,427.97), which was submitted to the Contracting Office on February 8, 1990, represents 39 percent of the claim. 36 The Board cannot tell whether the Contractor's adjusted running rate for 10,050 copies of the Citizen Soldier is also derived from some arbitrary formula. (Although there was a 58 percent reduction in the number of pages in the pamphlet- from 48 to 28-the downward revision in the running rate was only 49 percent-from $188.75 to $92.75.) Indeed, the Board has no idea how the Appellant computed the new figure since it has not supplied any supporting documentation. However, it is unnecessary for the Board to answer that question. Suffice it to say, that when the Board compares the Contracting Officer's calculation for running the pamphlet ($11,426.85) with the Appellant's approximately 18 percent lower figure ($9,321.38) for the same work, it wonders if the parties are even dealing with the same contract. 37 In that regard, a basic custom of the printing trade is to charge for author's alterations, which represents work performed in addition to the original specifications, at current rates and support the charges with documentation upon request. Beach, Shepro, and Russon, p. 176. However, for author's alterations performed under GPO contracts such documentation is required. GPO Contract Terms, Supplemental Specifications, Art. 17.(c) (Author's Alterations-Proof of charge). 38 See, note 27 supra. 39 The reason for this approach was stated in Bruce Construction Corporation: "Since the purpose underlying such adjustments is to safeguard the contractor against increased costs engendered by the modification, it appears patent that the measure of damages cannot be the value received by the Government, but must be more closely related to and contingent upon the altered position in which the contractor finds himself by reason of the modification." Bruce Construction Corporation v. United States, supra, 163 Ct.Cl. at 100, 324 F.2d at 518. 40 The reason for this bias was clearly stated by the Federal Circuit in Dawco Construction, Inc. v. United States, when it said: ". . . the `actual cost method' is preferred because it provides the court, or contracting officer, with documented underlying expenses, ensuring that the final amount of the equitable adjustment will be just that- equitable-and not a windfall for either the [G]overnment or the contractor." Dawco Construction, Inc. v. United States, 930 F.2d 872, 882 (Fed. Cir. 1991), rev'g, 18 Cl.Ct. 682 (1990). 41 While the contractor's original or bid estimate can be used to determine the cost of the work, later evidence, such as purchase order prices or vendor quotations, are normally better evidence of the costs that the contractor would have incurred. See, e.g., Atlantic Electric Company, supra, 83-1 BCA ¶ 16,484. If there is no such evidence, the bid estimate may be considered the best available proof of this amount. Select Contractors, Inc., ENGBCA No. 3919, 82-2 BCA ¶ 15,869; Dawson Construction Company, Inc., GSBCA No. 5672(5308)-Rein, 81-2 BCA ¶ 15,387, aff'd on reconsid., 82-2 BCA ¶ 15,914; Onetta Boat Works, Inc., supra, 81-2 BCA ¶ 15,279; Pruitt, Inc., ASBCA No. 18344, 73-2 BCA ¶ 10,213. But see, Ordnance Materials, Inc., supra, 88-3 BCA ¶ 29,910. However, the use of estimates does not change the burden of proof. Cf., Lagarelli Brothers Construction Company, Inc., ASBCA No. 34793, 88-1 BCA ¶ 20,363; Clary Corporation, ASBCA No. 19274, 74-2 BCA ¶ 10,927. 42 In Condor Reliability Services, Inc., the ASBCA stated: "The rule applicable to the price is . . . `the difference between the reasonable cost of performing without the change or deletion and the reasonable cost of performing with the change or deletion.' [Citation omitted.] The result should not change the contractor's loss or profit position before the change occurred. In other words, there should be no repricing of the contract as a whole." Condor Reliability Services, Inc., supra, 90-3 BCA ¶ 23,254, at 116,675-76. [Emphasis added.] 43 As explained by the Claims Court: "The search for `reasonability,' . . . , is not limited to inquiry of such factors as `fair market value' or `historical cost.' . . . The reasonable cost concept includes both `objective' and `subjective' elements . . . The objective focus is on the costs that would have been incurred by a prudent businessman placed in a similar overall competitive situation . . . However, unless it also takes into account the subjective situation of the contractor, a test of `reasonable cost' is incomplete. . . .". Nager Electric Company, supra, 194 Ct.Cl. at 851-53, 442 F.2d at 945-46. 44 Generally, the Government's credit for deleted work is measured by the net cost savings to the contractor. S.N. Nielsen Company v. United States, 141 Ct.Cl. 793 (1958); Jackson Engineering Company, Inc., ASBCA No. 27104, 85-3 BCA ¶ 18,418; Unicom Systems, Inc., ASBCA No. 29468, 84-3 BCA ¶ 17,675; N.G. Adair, Inc., ASBCA No. 25961, 83-2 BCA ¶ 16,887; Fordel Films West, ASBCA No. 23071, 79-2 BCA ¶ 13,913; Celesco Industries, supra, 79-1 BCA ¶ 13,604. See also, Cibinic and Nash, pp. 483, 496. As explained by the ASBCA: "When a change deletes work, the Government is entitled to an amount equal to what it would have reasonably cost the contractor to have performed the work. In other words, the price reduction for the deletion should leave the contractor in the same financial condition as it would have been if the change order had not been issued. [Citation omitted.] While the proper measure of the price reduction is what it would have cost [the contractor] to perform the deleted work, the ascertainment of this figure is not always easy since by definition the `actual costs' of deleted work are not available." ACS Construction Company, Inc. of Mississippi, supra, 87-1 BCA ¶ 19,660, at 99,550. See also, Condor Reliability Services, Inc., supra, 90-3 BCA ¶ 23,254, at 116,675-76. Obviously, if the contractor realized no savings from a change, the Government will not be awarded a price reduction. See, e.g., L.G. Lefler, Inc. v. United States, 6 Ct.Cl. 514 (1984). 45 Sustaining this evidentiary burden may not be an easy task for the Government because deleted work is not actually performed. ACS Construction Company, Inc. of Mississippi, supra, 87-1 BCA ¶ 19,660, at 99,550. Consequently, a board may have to find the requisite proof in the "comparative reasonableness" of the estimates presented by the respective parties. Jackson Engineering Company, Inc., supra., 85-3 BCA ¶ 18,418, at 92,492. Indeed, it has been noted that estimates are used almost exclusively to establish the cost of deleted work. Cibinic and Nash, p. 510. See, Arctic Corner, ASBCA No. 29545, 86-3 ¶ 19,304. 46 This is not to say that the Government's changes had no affect on the Contractor's performance under the contact whatsoever. That there was some reduction in the contract here is beyond cavil. However, what the record demonstrates is a reduction in the number of pages per copy, not the number of copies which had to be produced under each contract. See, Banta Company, supra, Sl. op. at 53-54, fn. 66. Thus, while the Appellant had to print 201,000 less pages (20 pages x 10,050 copies), it nonetheless still had to produce 10,050 copies of the Citizen Soldier. The Respondent assumes that because the Government required less pages, ergo, less effort was required by the Contractor. To the contrary, in the Board's view, the reduction in the amount of paper and ink required to perform the contract is offset by the increased activity on the part of the Contractor which was necessary to make all of the author's alterations and produce a pamphlet which was satisfactory to the Army. Id. Accord, Celesco Industries, supra, 79-1 BCA ¶ 13,604. See also, Beach, Shepro, and Russon, note 34 supra. 47 Even so, a contractor is still entitled to recover reasonable and necessary expenses incurred exclusively for the deleted item prior to its deletion. Groesbeck-Durbin, Inc., supra, 72-1 BCA ¶ 9,251, at 42,899. 48 Unlike this appeal, Banta Company involved the application of the "loss bid" rule, which forbids the use of an equitable adjustment to either reduce or increase a contractor's profit or loss, or convert a loss to a profit or vice versa. See, Pacific Architects & Engineers, Inc. v. United States, supra, 203 Ct.Cl. at 508, 491 F.2d at 739; Nager Electric Company, supra, 194 Ct.Cl. at 853, 442 F.2d at 946. Contrary to the position asserted by the contractor, who had bid the contracts in question at a loss and argued that the doctrine should only apply to the original work but not the additional work caused by the author's alterations, the Board held that the "loss bid" rule applied to the entire contract; i.e., both the changed and unchanged work. Banta Company, supra, Sl. op. at 28-30. Accord, BH Services, Inc., ASBCA No. 39460, 93-3 BCA ¶ 26,086. 49 The reason the "jury verdict" technique is usually viewed as an evidentiary tool, rather than as a method of proof of the amount itself, is simple enough. As explained by the ASBCA: "There is neither a single nor a precise method of arriving at the dollar amount of an equitable adjustment. In general we seek to reach a figure as an equitable adjustment which represents the cost to a reasonably efficient contract[or] of performing the changed work under his contract. Evidence of this amount may be found in the actual costs of the particular contract, to the extent that those costs are not shown to be other than reasonable, and in engineering estimates of reasonable cost made by experts who bring into play their experience and knowledge to attempt to visualize the price at which that reasonably efficient contractor could perform. Neither estimating nor accounting are such exact arts that either can produce figures which will be agreed to by all parties without legitimate argument. We recognize that often, despite protestations to the contrary, extreme positions on monetary entitlement are taken during litigation. . . . [We must determine] . . . a figure as the amount of an equitable adjustment . . . [which] . . . ordinarily is . . . some place between the amount contended for by each party to the litigation. . . . This is a figure which in the view of the trier of the facts is fair in light of all the facts of the case, or, put another way, is supported by consideration of the entire record." Johnson, Drake & Piper, Inc., supra, 65-2 BCA ¶ 4,868, at 23,073. Similarly, the Department of Agriculture Board of Contract Appeals has observed that: "It is not essential that the amount be ascertainable with absolute exactness or mathematical precision. [Citations omitted.] It is enough if the testimony and evidence adduced is sufficient to enable the court or board (acting as the jury) to make a fair and reasonable approximation of the amount recoverable. [Citations omitted.]" Lawrence D. Krause, supra, 82-2 BCA ¶ 16,129, at 80,073. See also, Greenwood Construction Corporation, Inc., AGBCA No. 75-127, 78-1 BCA ¶ 12,893. See generally, Cibinic and Nash, pp. 519-22. 50 In essence, notwithstanding the requirement for proof of costs, the cases disclose a hesitancy to completely deny recovery in cases where it is reasonably certain that an injury did, in fact, occur. See, e.g., Meva Corp. v. United States, 206 Ct.Cl. 203, 220-21, 511 F.2d 548 (1975) (where the court allowed a "jury verdict" recovery because it was "equally clear" that the contractor suffered substantial monetary damage in direct consequence of the Government's breach of contract). See also, e.g., Harold Benson, AGBCA No. 384, 77-1 BCA ¶ 12,490 (where the evidence did not support the amount claimed by the contractor but did indicate that the amount allowed by the contracting officer was too low); Custom Roofing Company, ASBCA No. 19164, 74-2 BCA ¶ 10,925 (where the board granted a "jury verdict" recovery based on "rough estimates"); and Rocky Mountain Construction Company, IBCA No. 1091-12-75, 77-2 BCA ¶ 12,692 (where the board applied the "jury verdict" method to an item whose cost was "totally unclear"). Indeed, under the "jury verdict" technique, a board may even go so far as to make its own calculations of an equitable adjustment if it is not satisfied with the computations of either the contractor or the Government. See, e.g., Steve P. Rados, Inc., AGBCA No. 77-130-4, 82-1 BCA ¶ 15.624; Varo, Inc., ASBCA No. 15000, 72-2 BCA ¶ 9,717. In short, the teaching of these cases is that it is error for a trier of fact to totally deny a contractor's claim when entitlement is clear and there is some evidence upon which to base a "jury verdict" recovery. See, e.g., Assurance Company v. United States, supra, 813 F.2d at 1205; S.W. Electronics & Manufacturing Corporation v. United States, supra, 228 Ct.Cl. 333, 655 F.2d at 1088; Electronic & Missile Facilities, Inc. v. United States, supra, 189 Ct.Cl. 237, 416 F.2d at 1358; Eagle Paving, AGBCA No. 75-156, 78-1 BCA ¶ 13,107. Thus, the "jury verdict" method works in harmony with two purposes of the equitable adjustment procedure in general, namely to recognize and give appropriate consideration to the special circumstances of each case, and to avoid blind computations of additional costs or cost savings. G.M. Company Manufacturing Inc., ASBCA No. 2883, 57-2 BCA ¶ 1,505, at 5,234. 51 Even when proof of causation is not fully demonstrated, a board may use the "jury verdict" approach to reduce the amount claimed. See, e.g., Steve P. Rados, Inc., supra, 82-1 BCA ¶ 15,624, where the contractor had provided detailed evidence of the events that had occurred and of the costs which had been incurred, the board made its own computations of the amount of claimed costs that were attributable to Government action. Compare, Joseph Pickard's Sons Company v. United States, 209 Ct.Cl. 643, 532 F.2d 739, 742 (1976) (where the Claims Court refused to use the "jury verdict" method to prove causation). 52 It is well-settled that a board of contract appeals has the authority to recalculate the amount of a deduction taken by the Government. Banta Company, Inc., supra, Sl. op. at 58 (citing, Mit-Con, Inc., ASBCA No. 43021, 92-1 BCA ¶ 24,632; Arctic Corner, supra, 86-3 ¶ 19,304; R & E Electronics, Inc., supra, 85-3 BCA ¶ 18,316; Steve P. Rados, Inc. supra, 82-1 BCA ¶ 15,624; Varo, Inc., supra, 72-2 BCA ¶ 9,717). 53 The total amount of the contractor's claims in Banta Company exceeded $100,000.00, and an audit was authorized under GPO Contract Terms, Contract Clauses, Art. 40 (Audit- Sealed Bidding). See, note 32 supra. 54 As indicated previously, although the original claim was for $45,135.00, the unpaid portion which is still in dispute amounts to only $16,620.89. See, note 23 supra. In addition, the Appellant also asks the Board to award it interest and/or the cost of funds in the amount of $5,796.00. App. Mem., pp. 7-8. Apart from the fact that the Appellant's claim for interest would have to be presented to the Contracting Officer for a decision before the Board could consider it, see, e.g., Shepard Printing, GPO BCA 37-92 (January 24, 1994), Sl. op. at 31-32; P.X. Engineering Company, supra, 89-2 BCA ¶ 21,859, at 109,952, the simple fact is that the Board has no authority to award interest. It is well- settled that a contractor cannot recover interest on a claim against the United States unless there is an express provision in the contract or a relevant statute permitting such payment. See, Maitland Brothers Company, ASBCA No. 40388, 93-3 BCA ¶ 26,007 (citing, Fidelity Construction Company v. United States [30 CCF ¶ 70,827], 700 F.2d 1379 (Fed. Cir. 1983)), motion for reconsid. denied, 94-1 BCA ¶ 26,285; Reese Industries, ASBCA No. 36077, 89-1 BCA ¶ 21,255. The contract in dispute here is subject to the contract cost principles set forth in GPO Procurement Directive 306.2, Contract Cost Principles and Procedures, dated April 1, 1988 (CCPP). See, GPO Contract Terms, Contract Clauses, Art. 45 (Contract Cost Principles and Procedures). Those cost principles expressly disallow interest on borrowings (however represented) and directly associated costs. CCPP, ¶ 28. Since the Board takes its authority from the contract itself, see, note 3 supra, it cannot award a contractor compensation which is specifically prohibited by its terms. Furthermore, the Board has already ruled that GPO is not subject to the interest requirements of the Prompt Payment Act of 1982, as amended (PPA), 31 U.S.C. § 3901 et seq., because the PPA uses the APA definition of "agency" to define its coverage in terms of the Executive branch, and GPO is a Legislative branch agency. See, Chavis and Chavis Printing, supra, Sl. op. at 7, fn. 7. Similarly, GPO is not an "executive agency" within the meaning of the CDA. See, Tatelbaum v. United States, supra, 749 F.2d at 730. As a consequence, GPO is not subject to the interest and prompt payment provisions of the CDA either. See, 41 U.S.C. §§ 611, 612(a),(b). Accordingly, the Appellant's request for payment of interest in the amount of $5,796.00 is hereby DENIED.