Government Contractor Timekeeping Compliance

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Timekeeping compliance is a combination of several critical pieces, involving everyone within an organization. With specific requirements for government contracts, it is crucial to develop a structure and process for timekeeping and compensation in government contracts. Here are some considerations when reviewing your company’s timekeeping compliance:

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Topics: Government Compliance Training

Are you prepared for an Equal Employment Opportunity (EEO)/ Affirmative Action Evaluation?

Are you prepared for a compliance evaluation from the Office of Federal Contract Compliance Programs (OFCCP)? If you’re a government contractor or subcontractor employing at least 50 people and having a contract or subcontract of $50,000 or greater, you need to be. The OFCCP is under the umbrella of the Department of Labor and their goal is to “protect workers, promote diversity and enforce the law.” OFCCP administers the following laws, all of which are specific to government contractors:

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Topics: Contracts Administration, Government Compliance Training, Human Resources

Is My Accounting System Adequate, Acceptable or Approved...Does it Matter?

To the uninformed, there may be little or no distinction between the three adjectives which could apply to a contractor (or potential contractor) accounting system. To those dealing with the terminology in government solicitations, there may appear to be no significant distinction because the words seem to be used interchangeably. For example, an Air Force solicitation may have a prerequisite for an adequate accounting system, in contrast to Navy solicitation which substitutes the words acceptable accounting system. Then a third alternative could be a solicitation which gives competing bidders points for approved systems; i.e. 500 points for having an approved accounting system. In most cases, the solicitation links the accounting system status (adequate, acceptable or approved) to an action (written opinion or written determination) by a federal government agency or, less frequently, an opinion by an independent third party such as a CPA or consultant. There is a fourth alternative, an accounting system which has never been reviewed by any independent party (government or otherwise). In this case, a contractor (or a potential contractor) may have an accounting system awaiting its first test, so to speak.

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Topics: Compliant Accounting Infrastructure, Contracts Administration, Cost and Pricing and Budgeting, Government Compliance Training, Small Business Compliance

Immigration and Naturalization Homeland Security Management Alert

Although Redstone Government Consulting. Inc., makes every attempt to avoid blogs which are overtly political, we’ve taken note of a DHS OIG (Department of Homeland Security Office of Inspector General) “Management Alert” which coincidentally provides some indirect validation to the Executive Order which suspends US refugee intake for 120 days, and places a 90-day moratorium on citizens of seven countries (entering the United States).   As we all endure the divisive rhetoric directed at the Executive Order, it may or may not be coincidental that there has been no media mention of the DHS OIG Management Alert, dated January 19, 2017.

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Topics: Defense Contractors, Redstone GCI, Government Compliance Training

The First Annual Redstone Edge Conference

On September 22, 2016, approximately 150 professionals attended the first annual “Redstone Edge” conference.  The all-day event, held at the Jackson Center in Huntsville, Alabama, is planned to be an annual event, potentially expanding to two days in September 2017 (starting on September 21, 2017).  

The 2016 conference covered a broad range of topics with an impressive variety of presenters representing government agencies, government contractors, and related advisors, including attorneys and consultants/CPAs.

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Topics: Redstone GCI, Government Compliance Training

Do as I say, not as I do! DCAA’s Internal Control Failure.

DFARS 252.242-7006(c)(8) specifically requires management reviews or internal audits of the system to ensure compliance with the contractor’s established policies, procedures.

One of the first things a DCAA auditor looks at when auditing a contractor’s accounting system is its policies and procedures. Policies and procedures represent control activities that are essential for an adequate system of internal controls. Good policies and procedures help ensure consistent operations in accordance with management objectives. DCAA cites policy and procedure inadequacies or the failure to comply with policies and procedures in virtually every deficiency report it issues related to internal controls.

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Topics: Government Compliance Training, DCAA Audit Support

Yes, Small Businesses Do Need Written Policies and Procedures

A question we are frequently asked is “Do small contractors really need written policies and procedures in place to pass....”   This is finished with many types of audit - pre-award accounting system, post award accounting system, or even purchasing system?

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Compliance Training

Cyber-Security: The Continuing Saga & Side Affects

As a follow-up to our June 2015 blog on the now really infamous OPM computer hack of 2015 (which might actually date back to 2013 based upon the fact that OPM’s story continually changes) we now know that approximately 21 million personnel records have been compromised.  However, we can all sleep better at night knowing that the action was technically not a cyber-attack because there was purportedly no attempt to take over the systems; hence, “merely” infiltrating (hacking) the systems to gain access to sensitive data including that related to background investigation.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Compliance Training

Calling All Commercial Companies: “Become a Government Contractor and be Subject to Executive Orders Dictating Your Pay and Benefits Policies”

In an Executive Orders (EO) issued on Labor Day, President Obama continued to display his willingness to manage the personnel policies of government contractors. This latest EO, one of many directed solely at Government contractors, will require contractors to provide up to seven days paid sick leave (annually) for employees. The EO comes with the typical unsupported rhetoric that “we’ve seen that many companies, including small businesses, support these policies because they understand it’s helpful with recruitment and retention” and a separate assertion “that paid sick leave will improve contractor performance”. Perhaps unintended, but it is noteworthy that the White House did not state that many companies support the notion that paid sick leave will “improve contractor performance”; by implication, the White House could not find any companies which were sufficiently naive to buy-in to that highly speculative and wholly unsupported assertion.

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Topics: Contractor Employee Compensation, Government Compliance Training

PROPOSED CHANGES TO FLSA Would Significantly Impact Overtime Pay Requirements

The Fair Labor Standards Act of 1938 (FLSA), which is administered and enforced by the Wage and Hour Division (WHD) of the Department of Labor (DOL) imposes, among other things, minimum wage and overtime pay requirements. It is certainly nothing new and has been a hot topic amongst Human Resources professionals over the past months as President Obama directed the Secretary of Labor to update the regulations. With much speculation and rumblings of possible changes, all have been anxious for the impending proposed rule to be revealed.  

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Topics: Cost and Pricing and Budgeting, Government Compliance Training