The Top 4 Halloween Costumes At the Annual Government Halloween BallAlthough we once again failed to receive an invitation to attend the Federal Government’s Annual Halloween Ball, we have it from a reliable source that the following were the top four costumes for Government Officials and/or Agencies.  In addition, we’ve identified the most likely reasons for the popularity of the top four costumes.

1. Ghost.  

This is all-too-obvious based upon the ubiquitous use of the word “transparency” in virtually every statement by every government official or in every policy announcement.   Virtually every proposed rule is ostensibly to make the government more transparent as if the federal government really wants to be that transparent (as evidenced by continuing efforts to block visibility into IRS behavior concerning conservative not-for profit entities).  Apparently ,no one in the government has actually read the definitions for transparent because they aren’t exactly favorable if applied to the government; in particular, easily seen through or detected as in “his transparent excuses”. This seems to fit like a glove in application to a 2014 series of Executive Orders specifically targeting government contractors, including a statement that “requiring contractors to report salary and wage data by gender and race will increase voluntary reporting”; since when is required reporting voluntary?

2. Magician. 

This may not be the most common costume, but it was apparently the costume chosen by the President based upon his continued assertions that if we just raise the minimum wage (to $10.10/hour) it will i) increase productivity; ii) reduce employer-employee friction; and iii) increase the pool of qualified employees leading to a more efficient and effective government.   There is absolutely no empirical evidence or study supporting his assertions; hence, we can only assume that increased productivity, less friction and an increase in the labor pool will magically happen if the minimum wage is increased.  With respect to better employer-employee relations, shortly after the Executive Order was issued in February 2014, public agency employees in the District of Columbia immediately staged a walk-out demanding an even higher minimum wage.  Apparently some magicians are better than others.

3. Pinocchio. 

This costume was in high demand for officials representing various agencies, apparently not realizing that a functioning Pinocchio costume would be hazardous with so many government officials in close proximity to each other.  Certainly, an appropriate costume which would actually achieve transparency if worn in public.  Perhaps most fitting for the Department of Justice which routinely issues press releases announcing settlements with government contractors which typically contain several paragraphs discussing the misdeeds of the government contractor, the amount of the settlement, and the fact that the Department is aggressively holding contractors accountable.  Almost as an after-thought, at the very end of the very negative representations regarding the egregious behavior of the contractor, the DOJ press release inserts the statement that “the claims resolved by the settlement are allegations only and there has been no determination of liability”.

There is one other very specific situation for which the Pinocchio costume is applicable, that of DCAA (Defense Contract Audit Agency) and its policy for evaluating contractor compensation.  In 2012, two ASBCA decisions (JF Taylor and Metron) resulted in very unflattering decisions concerning DCAA’s methods to benchmark a contractor’s compensation to third party compensation surveys.  In particular, that for numerous reasons, DCAA’s benchmarking was statistically flawed and that DCAA’s questionable/flawed methods were obviously biased to yield lower amounts.  In spite of these decisions, DCAA’s Director and one or more of DCAA’s Regional Directors have publicly stated that “we believed that we have always used appropriate methodology”.  As the nose grows, so grows government transparency if only we had more Pinocchio costumes.

4. Dumb and Dumber To. 

Perhaps most applicable to the Secretary of Labor in terms of statements made in his press releases.  Very recent examples include a trip to London to “learn how apprenticeships create a talent pipeline” and “remarkably, employers in the London Living Wage program are also responsible for ensuring that their employees earn a living wage”.  Who suspected that learning how apprenticeships create a talent pipeline would require a trip to London?  With respect to the second statement, one can only assume that the Secretary of Labor (and the current Administration) believes that only the government can do anything for anyone and without government “encouragement”, employers would never do anything for their employees.  Remarkable!

Written by Michael Steen

Michael Steen Mike Steen is a Senior Advisor with Redstone Government Consulting, Inc. and a specialist in complex compliance issues to include major contractor cost accounting & business system regulations, financial compliance, resolution of DCAA audit issues, Cost Accounting Standards application, litigation support, and claims preparation. Prior to joining Redstone Government Consulting, Mike served in a number of capacities with DCAA for over thirty years, and upon his retirement, he was one of the top seven senior executives with DCAA. Mike Served as a Regional Director for two DCAA regions, and during that time was responsible for audits of approximately $25B and 800 employees. In October 2001, he was selected for the Senior Executive Service and in 2006 he received the Presidential Rank Award. During Mike’s tenure with DCAA, he was involved in conducting or managing a variety of compliance audits, to include cost proposals, billing systems, Cost Accounting Standards, claims, defective pricing, and then-evolving programs such as restructuring, financial capability and agreed-upon procedures. He directly supported the government litigation team on significant contract disputes and has prepared and presented various lectures and seminars to DCAA staff and business community leaders. Since joining Redstone Government Consulting in June 2007, Mike has developed and presented training and seminars on Government Contracts Compliance to NCMA, Federal Publications Seminars and various clients. Mike also is a prolific contributor of written articles to government contracting publications, as well as to our own Government Insights Newsletter. Mike also serves as the director of our training service offerings, with responsibilities for preparing and developing course content as well as instructing our seminars to clients and general audiences throughout the U.S. Mike also serves as a faculty instructor for the Federal Publications Seminars organization. Education Mike has a BS Degree in Business Administration from Wichita State University. He is also a graduate of the DCAA Director’s Fellowship Program in Management, and has a Masters Degree in Administration from Central Michigan University. Mr. Steen also completed a number of OPM’s management and executive development courses.

About Redstone GCI

Redstone Government Consultants are a team of the most senior industry veterans and the brightest new talent in the industry. Many have held senior government positions including leadership roles in the DCAA. Our new talents bring significant accounting and software experience along with fresh perspectives, inspiration and energy to our team. Through our leadership and combined experience, we provide a unique perspective, bringing both government and contractor proficiencies to bear and ensuring rock-solid government compliance for our clients.

Topics: Business Systems Review, Contractor Employee Compensation, Small Business Compliance, DFARS Business Systems