How would you feel if you had unlimited access to all the resources Redstone Government Consulting had to offer? Relief? Security? Control? Protected? Re-focused?
On December 18, 2018 the Administrative Judge, in ASBCA No. 61583, denied the contractor’s appeal and granted the Government’s request for summary judgement related to the contractor’s claim that it was entitled to a penalty waiver because the contractor did not demonstrate that it “had adequate policies, training, controls, and review systems, and that it inadvertently incorporated the [unallowable cost]” in its incurred cost proposals. This decision serves as a reminder of the importance of maintaining adequate policies and procedures.
Slowly is the word that always describes Government change, and acquisition process change is no exception. Some of you will remember that the 2017 NDAA required DCAA to reduce the backlog of DoD incurred cost submissions and suspend work for other Departments. But how many of you remember that it also created an Advisory Panel on Streamlining and Codifying Acquisition Regulations, better known as the Section 809 Panel?
It’s everyone’s least favorite time of year. That’s right, tax season. For those of us who no longer work in public accounting, this time of year is now a welcome reprieve; although for us, it also marks the start of incurred cost season. If you’re not sure what an Incurred Cost Submission is or have questions about that topic, visit our website for a variety of resources.
In the last article, I talked about some of the early considerations for beginning the path toward your first government contract. I would encourage you to take a look here before diving in on the next major question to answer when pursuing your first government contract. That question is:
The December 21, 2018 deadline for a partial government shutdown is quickly approaching. That is an unwanted Christmas present for Government workers in the affected agencies, but what about for contractors? What should they do if the shutdown occurs?
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:
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.
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.