IMPORTANT UPDATE: DoD Simplifies Government Property Clauses

Last year, we wrote about the Department of Defense (DoD) proposing a change to the Defense Federal Acquisition Regulation Supplement (DFARS) that would possibly simplify Government property clauses by consolidating four clauses into a single management clause. This became a reality in December 2023 when the DoD issued a final rule consolidating the four clauses into DFARS 252.245-7005, Management and Reporting of Government Property. The new clause had an effective date of January 22, 2024.

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Topics: DFARS Business Systems, DCAA Audit Support, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

New DFARS Rule Attempts to Limit Flowdowns to DoD Commercial Subcontracts

Department of Defense (DoD) issued a final rule effective November 17, 2023, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to limit DoD prime contractors from flowing down FAR and DFARS clauses to commercial subcontracts unless the flowdown is specified in the regulation.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Federal Acquisition Regulation (FAR)

Avoid a Hefty Tax Bill with State Sales and Use Tax Exemptions on Government Contracts

Contractors need to understand the laws for applying state sales and use taxes to purchased goods and services on government contracts. It can be a costly mistake that eats away at your profit.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

Supply Chain Requirements on Covered Articles in Effect Now

The FAR Council issued an interim rule, effective December 4, 2023, which implements the requirements of the Federal Acquisition Supply Chain Security Act (FASCSA). This included three new FAR clauses which prohibit the delivery or use of “covered articles” subject to a FASCSA order in the performance of a government contract.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting

What Policies and Procedures Should a Government Contractor Have?

If this were only a simple question. The most straightforward answer is that it is a good idea for any company to have policies and procedures. If that company is going to do business with the US Government those policies and procedures are going to have to be expanded as each contract may present additional requirements. To help you understand the complex level of requirements we will address the major business systems and other key areas.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR), Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR), Material Management and Accounting System (MMAS), Estimating System Compliance

Another Cyber Security Noncompliance Under False Claims Act

Since the Department of Justice (DOJ) started promoting its initiative on Cyber Security reporting there have been several settlements related to cyber security noncompliance, four of which involve defense contractors.

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Topics: DFARS Business Systems, Cybersecurity

Proposed FAR Changes Loaded with More Contractor Requirements for Cyber Security

The FAR Council submitted a proposed rule amending FAR subparts, provisions, and clauses on October 3, 2023, to implement an Executive order on cyber threats, incident reporting, and information sharing for Federal contracts. This revision is being made to strengthen and standardize contractual requirements for cybersecurity across Federal agencies. The proposed rule also implements OMB Memorandum M-21-07 Completing the Transition to internet Protocol Version 6 (IPv6), dated November 19, 2020.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity

What? The Government is Banning TikTok on My Personal Phone!

The FAR Council published an interim rule effective June 2, 2023, that bans TikTok on contractor and contractor employee electronic devices that are used in the performance of federal contracts.

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

Most Common Findings in an Estimating System Audit

If you have an upcoming Defense Federal Acquisition Regulation Supplement (DFARS) estimating system audit, you need to plan for it, and the sooner, the better. Don't wait until the Defense Contract Audit Agency (DCAA) begins sending you its requests for information. But how do you prepare? Perhaps a place to start is first understanding what this audit entails and knowing what DCAA may cite as common findings.

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Topics: DFARS Business Systems, DCAA Audit Support, Estimating System Compliance

Introduction to Government Property for Government Contractors

We have discussed recently how DoD has an increased interest in government property, especially the property that contractor’s control and maintain. RGCI has helped clients with government property issues more in the past four years than the previous ten years combined.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Property Management