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

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: Small Business Compliance, Contracts Administration, Defense Contractors

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

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