More to Report if you have DoD Service Contracts

On July 9th, 2021, the Department of Defense (DoD)issued a final rule in the Federal Register to implement 10 U.S.C. 2330a which requires the DoD to establish a data collection system to provide certain management information about an awarded contract or task order that is valued in excess of $3 million. This new rule is applicable for the following service acquisition portfolio groups:

  • logistics management services
  • equipment-related services
  • knowledge-based services
  • electronics and communications services

You may read the entire rule here.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration, Government Compliance Training, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, System Award Management (SAM), Government Regulations, DOD Contractors

Buy American – Don’t Get Caught With Your Documentation Down

What’s new in this long-standing area?

The FAR Council at long last issues final rule to implement the Trump Executive Order 13881, Maximizing Use of American-Made Goods, Products, and Materials. Only a few days later a Biden Executive Order 14005, Ensuring Future of America is Made in America by all of America’s Workers, hit the streets.

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Topics: Business Systems Review, Cost and Pricing and Budgeting, Incurred Cost Submission, Small Business Compliance, Contracts Administration, Defense Contractors, DFARS Business Systems, Incurred Cost Proposals, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, DOD Contractors, Federal Acquisition Regulation (FAR)

DOL Announces Final Rule on Independent Contractor Status Under FLSA

On January 6, 2021, the U.S. Department of Labor (DOL) announced its final rule to clarify whether a worker is an employee or an independent contractor under the Fair Labor Standards Act (FLSA). The final rule was published in the Federal Register on January 7, 2021 and the effective date is March 8, 2021. You may read the entire rule here.

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Topics: Small Business Compliance, Human Resources, Fair Labor Standards Act (FLSA), Independent Contractor

Incurred Cost Submission Audit: What to Expect?

Contractors with cost reimbursable contracts that include the Allowable cost and payment clause, FAR 52.216-7 or Payments under Time-and-Materials and Labor-Hour contracts clause, FAR 52.232-7, are required to submit an Incurred Cost Proposal for each fiscal year costs were incurred on any cost reimbursable contract. This incurred cost proposal is provided to your Administrative Contracting Officer (ACO) and Defense Contract Audit Agency (DCAA) with a deadline of six months after the Contractor’s fiscal year end. Once the Incurred Cost Proposal is received by DCAA, they review it for adequacy. DCAA provides a notification to the Contractor, typically via email, that the proposal is deemed adequate for audit or outlines changes DCAA believes are necessary. That is great to know it is adequate for audit but what does that mean? This means that DCAA has reviewed the incurred cost proposal and determined that the schedules are properly completed for them to begin the audit potentially.

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Topics: Incurred Cost Submission, Small Business Compliance, Defense Contractors, Incurred Cost Proposals, Cost-Type Contracts, DCAA Audit Support, Federal Acquisition Regulation (FAR)

Redstone Success Program – How We Help Government Contractors Succeed

How would you feel if you had unlimited access to all the resources Redstone Government Consulting had to offer?  Relief?  Security?  Control?  Protected?  Re-focused?

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Topics: Redstone GCI, Litigation Consulting Support, Small Business Compliance, Contracts Administration, Defense Contractors

Allowable vs Unallowable: Marketing, Advertising, and Public Relations

FAR Part 31.205 -1 – Public Relations and Advertising Costs

“Marketing is the activity, set of institutions, and processes for creating, communicating, delivering, and exchanging offerings that have value for customers, clients, partners, and society at large.” (American Marketing Association)

“Advertising is the action of calling something to the attention of the public especially by paid announcements.” (Merriam-Webster)

“Public relations (PR) is a strategic communication process that builds mutually beneficial relationships between organizations and their publics.” (Public Relations Society of America (PRSA))

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Topics: Compliant Accounting Infrastructure, Small Business Compliance

GovCon-Taxes: Accrual or Cash? Why Not Both?

It’s everyone’s least favorite time of year.  That’s right, tax season.  For those of us who no longer work in public accounting, this time of year is now a welcome reprieve; although for us, it also marks the start of incurred cost season.  If you’re not sure what an Incurred Cost Submission is or have questions about that topic, visit our website for a variety of resources.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration, Accounting & Billing System

Government “Forgive & Forget”—Not Likely Applicable to FAR 52.242-3 Penalties

A recent ASBCA decision (No 61583) confirms that Government benevolence does not extend to penalties associated with a contractor’s final indirect cost rate proposal (FICRP) which included expressly unallowable indirect costs. In one case, the issue was unallowable legal costs incurred as a result of the US Department of Justice (DOJ) investigation of the contractor, which was triggered by information suggesting that the contractor claimed indirect salaries for an individual whose services were as the housekeeper for the owners of the company and thus unallowable as costs allowable to Government contracts. 

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Topics: Small Business Compliance, Government Regulations

NLRB Alters Stance on Independent Contractor Standard

With its January 25th decision in SuperShuttle DFW Inc., the National Labor Relations Board (NLRB) altered its stance on the independent contractor standard. In a 3-1 vote, the NLRB amended its previous decision in FedEx Home Delivery (2014), asserting that a worker’s classification under the National Labor Relations Act (NLRA) should depend largely on the traditional common-law standard rather than economic factors.

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Topics: Small Business Compliance, Human Resources

2018 EEO-1 Reporting Deadline Extended to May 31, 2019

The 2018 EEO-1 reporting deadline, originally set for March 31, 2019, has been extended to May 31, 2019 due to the recent government shutdown. The EEOC, which planned to open the 2018 EEO-1 filing website during the second or third week of January 2019, closed its offices during the shutdown, and is now expected to launch in March. As employers wait for the filing website to launch, they may want to proactively gather employment data from the fourth quarter of 2018 so they will be prepared to file their EEO-1 report in a timely manner.

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Topics: Small Business Compliance, Human Resources