Subcontract Considerations, Basic Tip on Compliance for Prime Contractors

If your business pipeline is growing and you are issuing more subcontracts of higher values, Contractors should be aware that your organization has a duty under 48 CFR §22.805 to the Office of Federal Contract Compliance Programs (OFCCP).

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Topics: Contracts Administration, Defense Contractors, FAR, Contractor Purchasing System Review (CPSR), Government Regulations, DOD Contractors

PPP Loan Forgiveness – Impacted by Related Party Lease Cost

Apportioning the Costs of Buildings

The SBA and Treasury have made it clear that if you own or lease a building that you sublet to another company, the portion of the lease or mortgage expense that can be used as nonpayroll costs for PPP loan forgiveness is limited to the share of the expense applied to the business who’s PPP loan is being forgiven. The simple example is, you lease an office building for $10,000 per month and sublease part of the space to another company for $2,500 per month. Only $7,500 would be used toward your nonpayroll cost for loan forgiveness. This proration applies to utility and other shared costs of the tenants.

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Topics: Defense Contractors, DPAP, Accounting & Billing System, Government Regulations, DOD Contractors, COVID-19

Is Six Months Best for Incurred Cost Proposals, A New Game is Afoot

As we wrap up another hectic year of working with contractors to prepare, review and submit their Incurred Cost Proposals, it had us questioning…“Why do so many contractors wait until the last minute of their deadline to submit? Is there an advantage to submitting at the last minute or is submitting at the last minute actually a disadvantage?”

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Topics: Incurred Cost Submission, Contracts Administration, Defense Contractors, Incurred Cost Proposals, Cost-Type Contracts, FAR

CARES Act Section 3610, DPC DFARS Class Deviation and Guidance

On August 17, 2020; Acting Principal Director for Defense Pricing and Contracting issued two memos providing guidance in support of DFARS Class Deviation 2020-O0013 and 2020-O0021 – CARES Act Section 3610 Implementation. There is also a memo providing contracting officers with a template for a Memorandum for Record to document the file for the issuance of the Section 3610 related contract modification.

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Topics: Contracts Administration, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, DPAP, Accounting & Billing System, DOD Contractors, Cost Accounting Standards (CAS), COVID-19

DCAA COVID-19 Guidance – Still in a Wait and See, Holding Pattern

We Lifted the Vail

A few months back we submitted a request to DCAA under Freedom of Information Act. Based on the DPC guidance referencing both DCAA and DCMA as playing a key role in support of the rest of the DoD Acquisition Community, we expected DCAA would have a significant number of documents disclosing this key role. Turns out, not so much. All we got was a single document listing 13 frequently asked questions (FAQs) DCAA has been fielding from their auditors, dated July 31, 2020.

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Topics: Cost and Pricing and Budgeting, Contracts Administration, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, DPAP, DOD Contractors, Cost Accounting Standards (CAS), COVID-19

Deltek Costpoint 8 is Coming: 5 Things You Need to Know

5 Things You Need to Know Before Your Update

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Topics: Business Systems Review, Cost and Pricing and Budgeting, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, FAR, Accounting & Billing System, DOD Contractors, Cost Accounting Standards (CAS)

Why Bid and Proposal Cost is so Confusing to Government Contractors

Accounting for Bid and Proposal (B&P) Explained

Bid and Proposal is a topic that comes up with our contractor clients on a regular basis. Most questions surrounding this topic involve: whom at the contractor should be charging B&P, especially, contractor personnel that typically charge overhead or G&A. We understand why this is confusing. It is our opinion that the guidance per FAR (Federal Acquisition Regulations) and CAS (Cost Accounting Standards) regarding this topic is unclear and leaves contractors scratching their heads trying to be compliant.

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Topics: Defense Contractors, Incurred Cost Proposals, Accounting & Billing System, Cost Accounting Standards (CAS)

Service Contract Act: Cheers to 2020 and Getting it Right!

Lately, we seem to be constantly reminded of the necessity of accurately identifying contracts which are (or should be) covered by the Service Contract Act (SCA) (aka Service Labor Contract Standards (SCLS)) and the subsequent labor category mapping.  Unfortunately, these reminders tend to come at quite a cost, not only financially but also as an extreme burden on your staff.  With this in mind, we decided to share some common issues and suggestions, in hopes of encouraging you to kick off the New Year with a resolution to be proactive in your compliance efforts.

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Topics: Contracts Administration, Defense Contractors

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. 

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Topics: Defense Contractors, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity Maturity Model Certification (CMMC)

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.

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