Worst Disclosure Statement Surprises

There are many presents one may enjoy receiving this holiday season. However, one present you do not want during the holiday season is a CAS Disclosure Statement (DS) surprise.  There are several surprises related to DS’s you can receive:

Read More

Topics: Contracts Administration, Defense Contractors

DoD-IG Report: Contractor Employees Failed to Meet Labor Qualifications on Task Order Contracts

In its report dated November 27, 2018 (DODIG-2019-029), the IG reviewed 12 of 540 task orders (issued between September 2014 to October 2017) to determine if contractor employees met the contract schedule labor qualifications.  The contract vehicle is the OASIS (One Acquisition Solution for Integrated Services), administered by the GSA, but used by multiple DoD (and other Government) agencies. The good news is that the IG reported 1,175 of 1,287 contractor employees met the labor category qualifications; the bad news is the remaining 112 employees did not meet the labor qualifications, and/or the DoD agency could not document that contractor employees met the labor qualifications. Thus, DoD agencies authorized $28 million of potentially improper payments (based on the IG’s statistical projection), authorized $574K of potential improper payments for employees who did not have qualification documentation, and did not consider the potential impact on contract performance and price before authorizing $6.8 million for employees without relevant education and work experience.

Read More

Topics: Incurred Cost Proposals, DCAA Audit Support, Contracts Administration

So, you want to do work with the U.S. Government? Part 1

For over a decade I’ve had the opportunity to work with many contractors pursuing their first government contract.  In my role as the VP of Special Projects at Redstone GCI many companies that I routinely assist are in the process of acquiring their first contract or in the very early stages of contract performance.  While I do work with small businesses going through the process of initial contract pursuit and mature government contractors, most companies that I work with are larger commercial or international companies.  I like to think of the role that our team provides as a voice of reason providing a measured approach to compliance to ensure the costs for barriers to entry (e.g. DFARS Business Systems) into the U.S. federal market are recoverable by the company. 

Read More

Topics: Defense Contractors, Contracts Administration, Small Business Compliance

Government Property Disposition: What is Abandonment?

The term abandonment seems to be a hot topic within government property (GP) circles for both contractors and government procurement professionals. Many more contractors are requesting abandonment as a method of disposition. But exactly what is abandonment? When can it be used? And is it a last resort for the government?

Read More

Topics: Contracts Administration, Defense Contractors

Government Furnished Property Gotchas

Government furnished property can be a headache, even for the most seasoned contractor. It can include thousands of tiny parts, multi-million-dollar pieces of equipment or both – often all on one contract in an old dark government building. We have identified some common, and not-so-common, areas we see missing in contractor government property management plans.

Read More

Topics: Contracts Administration, Defense Contractors

OFCCP Issues New Guidance to Address Pay Discrimination

A New Procedure: Directive 2018-05

On August 24, 2018, the Office of Federal Contract Compliance Programs (OFCCP) issued a standard procedure for OFCCP staff to follow when conducting an analysis of contractor compensation practices during a compliance evaluation.   This information is also intended to assist government contractors in performing annual internal reviews and proactively addressing any potential pay discrimination. Directive 2018-05 - Analysis of Contractor Compensation Practices During a Compliance Evaluation replaces Directive 2013-03 Procedures for Reviewing Contractor Compensation Systems and Practices which was issued in February 2013.

Read More

Topics: Human Resources, Contracts Administration

Organization Conflicts of Interest Decision Challenges

RCGI-Organizational Conflicts of Interest (OCI) Challenges

Organizational Conflicts of Interest (OCI) play a key role in a government contractor’s ability to compete for work.  In accordance with Federal Acquisition Regulation 9.504, contracting officers are responsible for evaluating OCI as early in the acquisition process as possible in an effort to avoid or mitigate conflicts that may otherwise be present in the acquisition. 

Read More

Topics: Contracts Administration, Defense Contractors

Government Contract Post-Award Debriefings 101

RCGI-Government Contract Post-Award Debriefings 101

Ever wonder how to get your questions answered at a post-award debriefing?  It can be frustrating to get the information you really want to know from the Government.  When I worked as an acquisition attorney with the Government, I spent many hours with my evaluation teams preparing for post-award debriefings.  I always set time aside to go through a mock debriefing and discuss what information to disclose and what type of questions to table. 

Read More

Topics: Contracts Administration, Defense Contractors

CPSR Guidebook and Threshold Changes: What Should Contractors Expect from DCMA?

RCGI-CPSR Guidebook and Threshold Changes 2018

As we noted in our last blog, DCMA has issued another updated CPSR Guidebook, dated May 29, 2018.  DCMA issued two updates in 2017 and have already issued 2 updates in 2018.  This leads us to question: Will there be more? And our intuition leads us to answer: More than likely! 

Read More

Topics: Contractor Purchasing System Review (CPSR), Contracts Administration

The “New and Improved” DCMA CPSR Guidebook: Really Improved?

RCGI-New DCMA CPSR Guidebook Released May 2018

A new DCMA CPSR Guidebook has been released effective May 29, 2018 and can be found here:  http://www.dcma.mil/Portals/31/Documents/CPSR/CPSR_Guidebook_052918.pdf The Redstone team will be conducting a more comprehensive review of the guidebook, but we want to share our initial thoughts with readers.

Read More

Topics: Contractor Purchasing System Review (CPSR), Contracts Administration, Defense Contractors