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.
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.
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.
A new DCMA CPSR Guidebook has been released effective May 29, 2018 and can be found here: http://www.dcma.mil/Portals/31/Documents/CPSR/CPSR_Guidebook_052918.pdf The Redstone team will be conducting a more comprehensive review of the guidebook, but we want to share our initial thoughts with readers.
In late 2013, the BBA (Bipartisan Budget Act) significantly changed the FAR 31.205-6(p) regulatory cap for allowable contractor employee compensation. In a highly politicized action, the Obama Administration convinced Congress to reduce allowable compensation to $487,000 for any contractor employee effective for contracts on or after June 24, 2014. Additionally, Section 702 of the BBA prescribed the method for annual increases to the statutory cap (based upon the change in the Employment Cost Index for all workers as calculated by the BLS (Bureau of Labor Statistics).
How does one ensure the financial success of one’s government contracts? If we were to poll twenty-five different government contractors, we would likely get 25 different responses, and most wouldn’t be wrong. Some would say it takes a great program manager, while some would say it takes executive management committed to providing the necessary resources. Others might say it depends on the type of contract being worked or the type of fee being earned. All of these would be correct.
As we near the end of calendar year 2017, many will be thinking of some resolutions for the upcoming “Year of the Dog” (the 2018 animal per the Chinese Calendar). In fact, we’ve discovered that Government agencies sometimes consider similar resolutions, and in the case of DCAA (Defense Contract Audit Agency), we’ve accidentally been copied on one of the unofficial versions of its 2018 New Year’s resolutions (which are three months late, given the government fiscal year started October 1, 2017).
Congressman Mac Thornberry recently introduced the “Defense Acquisition Streamlining and Transparency Act” to improve the acquisition system and workforce, and improve transparency in the acquisition system. Click here to download the 80-page bill.
What is a Program Control analyst and do I need one? These questions are often asked by small business who might not understand the role of a Program Controller. Program (or Project) Controllers are most frequently financial managers who oversee project revenues and expenditures to ensure programs are on schedule and within budget. Program Control Analysts bridge the gap between the program manager and the accounting department and support the needs of both organizations. Program Managers typically manage the technical aspects of a program, while the accounting department manages payroll, accounts payable, accounts receivable, and compliance with generally accepted accounting principles. Program Control Analysts provide a link between the technical elements of program management and the compliance elements of cost accounting. Program control personnel generally have a business background in accounting, finance, business administration or economics which allows them to assist the program manager with decisions which are compliant with business policy and are in accordance with contract terms.
With a Presidential Memorandum halting all proposed federal regulations that have not yet taken effect and pausing the Department of Labor’s (DOL) appeal of the nationwide injunction on the overtime rule which would double the minimum salary for exempt status, we are curious how the new administration will impact employer responsibilities, particularly those of federal contractors. While we certainly hope for some respite, we won’t speculate on what might happen, and we continue to encourage employers to be diligent in compliance with those regulations which have recently taken effect as well as those that employers have been slow to tackle.