What Should I Do if My Contract or Grant is Affected by Executive Orders?

Executive Order Impacting Funding on Contract or Grant Work

The President issued an Executive Order (EO) on January 20, 2025, to immediately pause the disbursement of funds appropriated through the Inflation Reduction Act of 2022 (Public Law 117-169) or the Infrastructure Investment and Jobs Act (Public Law 117058). This relates to programs for issuing grants, loans, contracts, or any other financial disbursements of such appropriated funds. The Office of Management and Budget issued a guidance memo on January 28 and rescinded the memorandum on January 29.

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200), REAs, Claims & Terminations

Why Do Contractors Have to Do Market Research?

Why do contractors have to do market research? Simply put, you signed a contract with the US Government or a subcontract with a prime contractor that expects it – yes, it is contractually required. Plus, it is one of the most often reported contractor purchasing system review (CPSR) findings.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Proposed Rule Amending the FAR to Include Controlled Unclassified Information (CUI) Requirements

The FAR Council issued a proposed rule on January 15, 2025, to expand the CUI requirements into FAR under Executive Order 13556 Controlled Unclassified Information. Controlled Unclassified Information is information that the government creates or possesses, or that an entity creates or possesses for or on behalf of the government, that a law, regulation, or governmentwide policy requires or permits an agency to handle using safeguarding or dissemination controls. CUI may not be released to the public.

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

When and Why Commercial Determinations Are Required

Let’s start with the basics. When is a commercial determination required in the Federal Acquisition Regulations (FAR)? The common belief is that only when the award of a subcontract exceeds the cost or pricing data threshold. This common belief is what we refer to as a too-often believed myth. The truth is that FAR 52.244-6, Subcontracts for Commercial Products and Commercial Services, specifically requires that “to the maximum extent practicable, the Contractor shall incorporate, and require its subcontractors at all tiers to incorporate, commercial products, commercial services, or non-developmental items as components of items to be supplied” to the Government. To comply with this requirement, as many as possible of your purchase orders issued under your U.S. Government contracts and subcontracts should have commercial determination regardless of the dollar value.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Do You Completely Understand FAR 31.205-36 Rental Costs?

While the cost principle is titled “Rental Costs,” it addresses the cost of renting and leasing real and personal property utilized in the performance of US Government procurement contracts and subcontracts. The way I read the cost principle, FAR 31.205-36(b) provides that rental and leasing costs are allowable with the following limitations:

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Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

ASBCA Makes it Clear How the Waiver of Penalties Works

On November 7, 2024, the Armed Services Board of Contract Appeals (ASBCA) issued a decision that every small business needs to read. ASBCA Case 62458 Left Hand Design Corporation Decision explains exactly how the Federal Acquisition Regulation (FAR) implements the statutorily required penalties through FAR 42.709-6, Waiver of the penalty, and provides a cautionary tale for small businesses or large businesses that are new to government contracting.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Dare We Say – The Government May Shutdown in December 2024

As Kevin so aptly put it in Home Alone 2 – “Another Christmas in the trenches.”

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Topics: Government Shutdown, Contracts & Subcontracts Administration

FAR Council Issues Proposed Rule to Increase Acquisition Thresholds

The FAR Council issued a proposed rule on November 29, 2024 to amend the FAR to increase acquisition related thresholds for inflation.

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance

DCAA Publishes the 2025 Compensation Cap

Again, this year our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2025 compensation cap amount is $671,000. Below we have provided the compensation caps going back to 2019.

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Topics: Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Why You and Your Team Need Quality Training in Deltek Costpoint

Mastering efficiency, ensuring compliance, and driving growth is a constant challenge for government contractors. Amidst these challenges, enterprise resource planning (ERP) systems like Deltek Costpoint emerge as indispensable tools for streamlining operations, managing finances, and facilitating decision-making. However, the true power of Costpoint lies not just in its software capabilities but in the hands of well-trained users who can leverage its functionalities to their fullest extent. Comprehensive training is a vital step toward maximizing the system’s value and driving organizational success.

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Topics: Compliant Accounting Infrastructure, Government Compliance Training, Deltek Costpoint