IMPORTANT UPDATE: DoD Simplifies Government Property Clauses

Last year, we wrote about the Department of Defense (DoD) proposing a change to the Defense Federal Acquisition Regulation Supplement (DFARS) that would possibly simplify Government property clauses by consolidating four clauses into a single management clause. This became a reality in December 2023 when the DoD issued a final rule consolidating the four clauses into DFARS 252.245-7005, Management and Reporting of Government Property. The new clause had an effective date of January 22, 2024.

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Topics: DFARS Business Systems, DCAA Audit Support, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

The Department of Labor Issues New Rules on Employee Classifications

On January 10, 2024, the U.S. Department of Labor (DOL) published its highly anticipated “final rule” on independent contractor classifications.[1] As expected, they adopted the “totality of the circumstances” test which means that many more workers will be found to be w-2 employees as opposed to 1099 independent contractors. This rule takes effect on March 11, 2024, and is anticipated to have a significant impact across many industries that rely on contract workers, including government contractors. Under the new rule, many independent contractors will likely be reclassified as employees, which will financially impact employers by way of potential entitlement to company benefits, additional tax implications, and possible exposure to employment-based lawsuits, etc. Furthermore, if a worker is misclassified as an independent contractor but is later determined to be your employee, there is an additional risk of back wages that could be assessed for unpaid overtime, particularly in light of the changes DOL has in store regarding the salary basis for exempt employees. Those proposed changes will be discussed at the end of this article.

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Topics: Small Business Compliance, Human Resources, Government Regulations

New DFARS Rule Attempts to Limit Flowdowns to DoD Commercial Subcontracts

Department of Defense (DoD) issued a final rule effective November 17, 2023, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to limit DoD prime contractors from flowing down FAR and DFARS clauses to commercial subcontracts unless the flowdown is specified in the regulation.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Federal Acquisition Regulation (FAR)

Understanding Health and Welfare Under the Service Contract Act (SCA)

The McNamara-O’Hara Service Contract Act (SCA), aka Service Contract Labor Standards (SCLS), requires contractors and subcontractors on covered contracts to provide specified wages and fringe benefits to covered employees (i.e., “service employees”). While that may sound fairly straightforward, there are many nuances and complexities that can cause great concern and angst when working toward compliance with the SCA. At the top of the list of these administrative burdens is the appropriate distribution of Health and Welfare (H&W).

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Topics: Employee & Contractor Compensation, Small Business Compliance, Human Resources, HR Huddle, Service Contract Act

FAR Parts and Why They Matter to Government Contractors

If you have Government contracts, you probably heard of the Federal Acquisition Regulation, or FAR, but how much do you know of its parts? Why is it important to know? How could it possibly impact me?

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Is Construction for the Federal Government Commercial?

How does the Government define construction? We need to consider some of the definitions in FAR part 2:

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Commercial Item Determination, Federal Construction Contracting

January 1st Unanet Implementation: Where Are You Now?

January 1st is a popular Go Live date for any software implementation, and we certainly see that with our Unanet clients. The benefits of starting a new accounting system at the beginning of the year include several things such as:

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Topics: Compliant Accounting Infrastructure, Unanet

Why You Don't Want to Miss Redstone GCI's Day with Deltek 2024

Redstone GCI's Deltek Costpoint group is hosting Redstone GCI's Day with Deltek on April 11th. This FREE event will include sessions with Deltek and Redstone Government Consulting experts, networking opportunities, and 4 CPE credits. This year's event includes sessions on CMMC, system audit preparation, and even a live report writing training session. We will also have a special lunch and learn session with a DCAA representative.

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Topics: Deltek Costpoint

Cost Accounting Standard (CAS) 403 - Allocation of Home Office Expenses to Segments

So, you have a contract with the clause FAR 52.230-2 Cost Accounting Standards, subject to full CAS coverage. If you receive allocations from a home office, the home office must comply with CAS 403, Allocation of home office expenses to segments. A home office has the responsibility for directing or managing two or more segments of an organization and includes intermediate home offices or a corporate office.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

The Critical Importance of Understanding Legally Binding Contracts Before Signing

Contract Management needs to ensure they set aside enough time and read the contract before they sign it. We understand there are deadlines to meet, but you don’t want to get caught up skimming the contract because it is too lengthy, thinking you know all the clauses by heart, or ignoring legal jargon because you don’t understand it.

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Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, Organizational Change Management Consulting