Six months after the Defense Contract Audit Agency (DCAA) made its major reorganization, it made another one: the elimination of its Field Detachment (FD) as a separate entity within DCAA. The Field Detachment was a separate entity within DCAA that handled DCAA’s classified audit work. It was a separate and distinct DCAA entity from the current Land, Air, and Sea Directorates of DCAA.
Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations
We knew this was coming based on the June 30, 2025, PF 2025-38 (FAL 2025-05) Implementation of Indirect and Fringe Benefits Cost Reimbursement Limits on Financial Assistance Awards guidance to Granting officers. However, we believed the May 15, 2025, preliminary injunction issued by the U.S. District Court for the District of Massachusetts in the case of Association of American Universities et al. v. U.S. Department of Energy would slow down DOE‘s implementation of the cap on indirect cost recovery for more than just Institutions of Higher Education (IHEs). Sadly, that is not the case.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
The President’s Executive Order – Restoring Common Sense to Federal Procurement involves a comprehensive overhaul of the Federal Acquisition Regulation (FAR) and subsequently the FAR Supplements. As the FAR is being updated it includes changes to contract provisions and clauses. The System for Award Management (SAM.gov), the official U.S. government website where entities register to do business with the federal government is also being streamlined.
Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)
Recently, we conducted research related to some incurred cost audit findings for a client and came across an Armed Services Board of Contract Appeals (ASBCA) case that highlighted key information every contractor, especially small businesses, should know. The Technology Systems, Inc. ASBCA No. 59577 reads like a soap opera. It starts with some ups and downs. There were audit findings in Fiscal Year (FY) 2001, which the contractor and the Administrative Contracting Officer (ACO) negotiated. For FY 2002 to 2006, the contractor’s indirect rates were accepted as proposed. This was followed by relationship issues during the FY 2007 audit between the Defense Contract Audit Agency (DCAA) auditor and the contractor (No surprise to most of us). Then, a period of separation occurred, from FY 2009 to 2013, when DCAA decided that proposal pricing supporting new contract awards was the priority. During this time, the contractor’s FY 2007 incurred cost audit was shelved, along with significant potential questioned costs. Then, in an act of desperation, the ACO issued a Contracting Officer’s Final Decision (COFD) based on a DCAA memorandum for the FY 2007, which questioned costs to avoid the statute of limitations running out. Ok, enough of the soap opera, let’s go through the things you need to know.
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
A well-configured HR system can feel like the backbone of a thriving organization by streamlining processes, enhancing employee experience, and offering powerful data insights. However, even the most advanced HR technology can quickly become a liability if one critical element is overlooked - compliance. Government contractors risk turning their greatest HR asset into a hidden source of vulnerability if they fail to consider compliance in their implementation strategy.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act, Organizational Change Management Consulting, UKG Ready HR Software Consulting
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Contractors are required to use provisional billing rates when invoicing costs under cost reimbursable contracts or submitting an SF1443 Contractor’s Request for Progress Payment. FAR 42.704, Billing rates, requires the contracting officer or auditor (usually DCAA) to establish the billing rates. DCAA has undergone a reorganization, and the office assigned to your contractor site may have shut down or the staff may have been relocated.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
A little background – On April 15, 2025, Executive Order 14275, Restoring Common Sense to Federal Procurement, was issued. The intent of this order was to make revolutionary changes to the Federal Acquisition Regulations (FAR) to make the federal acquisition process more efficient and cost-effective. Section 2 states, “It is the policy of the United States to create the most agile, effective, and efficient procurement system possible. Removing undue barriers, such as unnecessary regulations, while simultaneously allowing for the expansion of the national and defense industrial bases is paramount. Accordingly, the FAR should contain only provisions required by statute or essential to sound procurement, and any FAR provisions that do not advance these objectives should be removed.”
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
If you’ve ever found yourself scratching your head over why the Project Status Report (PSR) doesn’t match the Revenue Worksheet (Rev WS), you are not alone. These two reports serve different purposes and speak two distinct languages. But to truly understand the differences, you must start with what is happening behind the scenes in the Costpoint Project Ledger.
Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Deltek Costpoint
The de minimis rate is an indirect rate that can be elected by Non-federal entities (State, local government, Indian Tribe, Institution of Higher Education or non-profit) that do not have a current negotiated indirect cost rate agreement (NICRA). The de minimis rate is addressed in 2 Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, specifically 200.414(f).
Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)
Revenue recognition is a very critical and highly scrutinized aspect of accounting for government contractors. Whether you're working on cost-plus contracts, time and materials, or firm fixed price agreements, how and when you recognize revenue can significantly impact your financial reporting and compliance with government regulations.
Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)