Lynne Nalley, CPA

Lynne Nalley, CPALynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting

Recent Posts

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)

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

Avoid a Hefty Tax Bill with State Sales and Use Tax Exemptions on Government Contracts

Contractors need to understand the laws for applying state sales and use taxes to purchased goods and services on government contracts. It can be a costly mistake that eats away at your profit.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

Hold On, My Company Can Submit a Commercial Quote on a Government or Prime Solicitation?

My commercial company wants to increase business with the Federal Government – but not with all those requirements the Government follows when buying under FAR Part 15 rules (Contracting by Negotiation). Is that even possible? The answer is “absolutely”.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Department of Energy Issues Class Deviation on System of Award Management (SAM)

Contractors are required to keep their System of Award Management (SAM) registration up to date. FAR 52.204-7(b)(1) requires an offeror to be registered in the System of Award Management (SAM) when submitting an offer/quote, registered until the time of award, during performance, and through final payment. Sounds pretty easy. However, contractors are not always registering or updating their registration, resulting in ineligible awards, as noted in recent court cases (See our blog: SAM Registrations: Check Often and Never Let it Lapse!).

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Topics: Contracts & Subcontracts Administration, System Award Management (SAM), Government Regulations

Why Identifying Commercial Items at Your Organization is Key

My company only sells to the Government so my products/services can’t be commercial. Truth or Myth. This is a myth. If you are selling products/services under FAR 15 based contracts or subcontracts, submitting certified cost and pricing data and documenting other accounting and purchasing requirements that come along with it, when the products/services technically meet the definition of commercial under the FAR – it may be time to rethink your approach.

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Topics: Proposal Cost Volume Development & Pricing, Commercial Item Determination

What are the Different Types of CAS Accounting Practice Changes?

Most contractors that have contracts/subcontracts subject to full CAS coverage will eventually want to make a change to a cost accounting practice because there is a “better” allocation method or a change is required to remain in compliance with CAS.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Cost Accounting Standards (CAS)

Another Cyber Security Noncompliance Under False Claims Act

Since the Department of Justice (DOJ) started promoting its initiative on Cyber Security reporting there have been several settlements related to cyber security noncompliance, four of which involve defense contractors.

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Topics: DFARS Business Systems, Cybersecurity

Grant Regulations are Going to be Updated Soon – Get Your Comments Ready

Suppose your company is working on a grant or cooperative agreement or planning to submit a proposal in response to a funding opportunity announcement. In that case, the regulations that apply will be Code of Federal Regulations (CFR) Title 2 Grants and Agreements. The problem is, when you receive a grant, generally, the award agreement says to comply with 2 CFR. There are no specific clauses or wording; basically, you are responsible for reading the entire regulation to see what applies to your award. 2 CFR includes inconsistent language and terms.

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Topics: Government Regulations, Cost Accounting Standards (CAS), Grants & Cooperative Agreements (2 CFR 200)

Proposed FAR Changes Loaded with More Contractor Requirements for Cyber Security

The FAR Council submitted a proposed rule amending FAR subparts, provisions, and clauses on October 3, 2023, to implement an Executive order on cyber threats, incident reporting, and information sharing for Federal contracts. This revision is being made to strengthen and standardize contractual requirements for cybersecurity across Federal agencies. The proposed rule also implements OMB Memorandum M-21-07 Completing the Transition to internet Protocol Version 6 (IPv6), dated November 19, 2020.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity