Are You and Your Subcontractors Ready for Cybersecurity Maturity Model Certification?

Per DFARS 252.204-7012, Contractors were to implement NIST SP 800-171 by 12/31/2017 “Safeguarding Cover Defense Information and Incident Reporting”. However, Contractors self-certification has not gone as well as the Department of Defense (DoD) had hoped.  They have even included it as part of 2019 Contractor Purchasing System Reviews (CPSR) for the Defense Contract Management Agency (DCMA) to evaluate Contractors monitoring of subcontractor’s self-certification.  In the meantime, DoD has shifted gears and is developing the Cybersecurity Maturity Model Certification (CMMC) to help strengthen the DoD supply chain's cybersecurity at all levels of the supply chain, from the prime Contractor on down to the lowest subcontractor. 

Read More

Topics: Defense Contractors, DFARS Business Systems, Contractor Purchasing System Review (CPSR)

Non-Tariff Supply-Chain Restrictions on IT/Telecom Products and Services (Part 3 of 3)

Future Supply-Chain Rules to Be Implemented Under Executive Order 13873, and Under Sections 889(a)(1)(B) and 889(b) of the 2019 NDAA

There have been several recent developments in U.S. law, relating to non-tariff restrictions on foreign-origin information technology and telecommunications equipment, with a focus on Chinese-origin products. This is the third installment of a three-part series on this topic.

Read More

Topics: Defense Contractors, DFARS Business Systems, Government Regulations, Export and Import

Non-Tariff Supply-Chain Restrictions on IT/Telecom Products and Services (Part 2 of 3)

Supply-Chain Rules from Section 889(a)(1)(A) of the NDAA for 2019 (Implemented by FAR Subpart 4.21)

There have been several recent developments in U.S. law, relating to non-tariff restrictions on foreign-origin information technology and telecommunications equipment, with a focus on Chinese-origin products. This is the second installment of a three-part series on this topic.

Read More

Topics: Defense Contractors, DFARS Business Systems, Government Regulations, Export and Import

Non-Tariff Supply-Chain Restrictions on IT/Telecom Products and Services (Part 1 of 3)

Supply-Chain Rules Under DFARS Subpart 239.73

In the ongoing trade war between the U.S. and China, the U.S. Government’s Section 301 tariffs on Chinese-origin goods has received most of the attention, and rightfully so. Effective September 1, 2019, these tariffs generally impact all Chinese-origin goods imported into the United States, including all information technology and telecommunications equipment (“Equipment”). However, there have also been several recent developments in U.S. law, relating to non-tariff restrictions on foreign-origin Equipment, with specific focus on Chinese-origin products.

Read More

Topics: Defense Contractors, DFARS Business Systems, Government Regulations, Export and Import

Redstone Success Program – How We Help Government Contractors Succeed

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?

Read More

Topics: Redstone GCI, Litigation Consulting Support, Small Business Compliance, Contracts Administration, Defense Contractors

Section 809 Panel—The Government Moves Slowly

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? 

Read More

Topics: Contracts Administration, Defense Contractors

DoD-IG Report Reinforces DCAA’s Interpretations of Contractor Compensation Reasonableness

A recent DoD-IG (Department of Defense-Inspector General Report (DODIG-2019-070) has unfortunately reinforced DCAA’s audit interpretations of the reasonableness of contractor compensation (reference to FAR 31.205-6(b)). The IG (apparently with help from DCAA) reviewed ACO (Contracting Officer) actions to resolve/disposition DCAA (Defense Contract Audit Agency) advisory audit reports which included assertions that contractors had claimed unreasonable compensation (primarily for contractor executives). 

Read More

Topics: Contractor Employee Compensation, Defense Contractors, DOD IG

So, You Want to Work with the U.S. Government? Part 2: Where Do I Stand?

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: 

Read More

Topics: Small Business Compliance, Contracts Administration, Defense Contractors

Government Closures & Shutdowns for Government Contractors

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?

Read More

Topics: Government Shutdown, Contracts Administration, Defense Contractors

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