FAR 31.205-6(p) Compensation “Cap”—OMB’s Unpublicized Increases for 2016 to 2018

RCGI-FAR 31.205-6p Compensation “Cap”—OMB’s Unpublicized Increases for 2016 to 2018

In late 2013, the BBA (Bipartisan Budget Act) significantly changed the FAR 31.205-6(p) regulatory cap for allowable contractor employee compensation.   In a highly politicized action, the Obama Administration convinced Congress to reduce allowable compensation to $487,000 for any contractor employee effective for contracts on or after June 24, 2014.  Additionally, Section 702 of the BBA prescribed the method for annual increases to the statutory cap (based upon the change in the Employment Cost Index for all workers as calculated by the BLS (Bureau of Labor Statistics).

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Topics: Contractor Employee Compensation, Contracts Administration, Defense Contractors

Internships: To Pay or Not to Pay?

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With summer just around the corner, now is the perfect time for your company to advertise internship opportunities. Internships are often a “win-win” opportunity, providing valuable education and training for students while improving workflow for employers.

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Topics: Contracts Administration, Human Resources

Incurred Cost Submission: Everything You Need to Know

Incurred Cost Submission

This blog was first published on the Deltek Government Contracting Blog as a guest post by Asa J. Gilliland of Redstone Government Consulting. 

The incurred cost submission is required for all federal contractors holding cost-type or time and materials (T&M) contracts and is a universal requirement regardless of agency customer.  All contracts requiring the incurred cost submission will include the Federal Acquisition Regulations “Allowable Cost & Payment Clause” (FAR 52.216-7) and/or the “T&M Payment Clause” (FAR 52.232-7). Following are answers to frequently asked questions and pointers to resources to help you.

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Topics: Incurred Cost Submission

Alleged Fraudulent Activity in GSA’s System for Award Management (SAM)

Redstone GCI-Alleged Fraudulent Activity in GSAs SAM

The GSA Office of Inspector General (OIG) is actively investigating alleged fraudulent third-party activity in GSA’s System for Award Management (SAM). At this time, a limited number of entities registered in SAM are suspected of being impacted by this illegal activity. GSA has taken proactive steps to address this issue and has notified the affected entities.

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Topics: Contracts Administration, DCAA

Payroll Audit Independent Determination Program - What Employers Need to Know

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The Department of Labor’s Wage & Hour Division has announced a new pilot program expected to launch next month. This initiative, referred to as the Payroll Audit Independent Determination (PAID) program, will allow employers the opportunity to voluntarily correct employee pay and accounting errors which violate the requirements of the Fair Labor Standards Act (FLSA).  Though an official launch date has not been announced, the program is set to run for an initial 6 months and is open to all FLSA-covered employers who have not already been sued and/or who are not currently being audited by the Department of Labor (DOL). Eligible employers may enroll online shortly after the launch date (see “How to Enroll” below) and participate in the PAID program through the end of the pilot.

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Topics: Contracts Administration, Human Resources, Accounting & Billing System

Government Contractor Timekeeping Compliance

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Timekeeping compliance is a combination of several critical pieces, involving everyone within an organization. With specific requirements for government contracts, it is crucial to develop a structure and process for timekeeping and compensation in government contracts. Here are some considerations when reviewing your company’s timekeeping compliance:

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Topics: Government Compliance Training

Government Contract Project Management and Control—A Team Sport

Redstone GCI-Government Contract Project Management and Control—A Team Sport.jpg

How does one ensure the financial success of one’s government contracts? If we were to poll twenty-five different government contractors, we would likely get 25 different responses, and most wouldn’t be wrong. Some would say it takes a great program manager, while some would say it takes executive management committed to providing the necessary resources. Others might say it depends on the type of contract being worked or the type of fee being earned. All of these would be correct.

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Topics: Contracts Administration, Defense Contractors, Human Resources

Are Work Authorizations Required by DCAA for an Adequate Accounting System?

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As incurred cost audits are becoming more prevalent and voucher audits are taking off like wildfire, there is emphasis placed on the use of work authorizations by government contractors.  There is no specific regulatory authority that can be cited which requires work authorizations as a part of a contractor’s Labor/Timekeeping System.  This argument, although accurate, is not the rationale which will be used by a DCAA auditor when “disclosing” deficiencies in a contractor’s labor system and ultimately rendering an inadequate opinion with respect to the accounting system, when the work authorization process is absent. 

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Topics: DCAA Audit Support

DCAA’s 2018 New Year Resolutions

As we near the end of calendar year 2017, many will be thinking of some resolutions for the upcoming “Year of the Dog” (the 2018 animal per the Chinese Calendar). In fact, we’ve discovered that Government agencies sometimes consider similar resolutions, and in the case of DCAA (Defense Contract Audit Agency), we’ve accidentally been copied on one of the unofficial versions of its 2018 New Year’s resolutions (which are three months late, given the government fiscal year started October 1, 2017).

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Topics: Defense Contractors, DCAA Audit Support

Wishing You a Joyous Holiday Season

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Topics: Redstone GCI