Redstone Government Consulting Blog

What is a Department of Defense (DoD) class deviation? It is a deviation from the Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation (DFARS) that affects more than one contract. They are issued by an authorized official and are used to deviate from the FAR or DFARS and offer flexibility in the acquisition process. Class deviations are supposed to be temporary. If the class deviation will become permanent, the Government is supposed to issue a proposed revision to the FAR or DFARS.

Topics: Contracts & Subcontracts Administration, System Award Management (SAM), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Cybersecurity

The Federal Funding and Accountability Transparency Act (FFATA) requires prime contractors to report their first-tier subcontracts and grant recipients to report their first-tier subawards using the Federal Funding and Accountability Transparency Act Subaward Reporting System website.

Topics: Employee & Contractor Compensation, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)

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 The Office of Management and Budget issued a guidance memo on January 28 and rescinded the memorandum on January 29.

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

FAR 1.604 allows a contracting officer (CO) to designate a representative to assist the CO in the technical monitoring and administration of a contract. The CO authorizes the contracting officer’s representative (COR) to perform many important tasks to assist the CO in administrating the contract during performance. However, FAR 1.602-2(d)(5) specifically prohibits the CO from authorizing the COR “to make any commitments or changes that affect price, quality, quantity, delivery, or other terms and conditions of the contract nor in any way direct the contractor or its subcontractors to operate in conflict with the contract terms and conditions.”

Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations

Does the Government find most of the cost incurred by a contractor to be reasonable? I must say it does appear that way. Defense Contract Audit Agency (DCAA) FY 2023 Report to Congress shows that of the $186B incurred cost audited, there was only $1.1B in audit exceptions (.6%). So, the world is good, and we can move on. If that were only the case. Remember that while this percentage is low, this is money you have already spent that the Government will not pay you for, which directly impacts your bottom line.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

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.

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

President Trump took aim at more than just DEI programs in Executive Order 14173 signed on January 21, 2025, "Ending Illegal Discrimination and Restoring Merit-Based Opportunity," in which he ordered the revocation of several executive actions, including EO 11246.

Topics: Human Resources, Government Regulations, Office of Federal Contract Compliance Programs

Costpoint’s automated overtime calculation streamlines your payroll process, ensuring compliance and reducing administrative burden. By leveraging Deltek’s Time & Expense module, you can configure custom overtime rules that automatically align with your company’s policies and state or federal labor laws. After updating the Overtime Hours Rules tab to reflect your companies’ business rules and to abide by state and/or federal labor laws and verifying the Pay Types Links subtask is correctly configured, which both can be found on the Timesheet Classes screen, along with changes within a few control screens in Time & Expense, you can ensure that your employees are documenting their time in accordance with your company’s policies and in compliance with any agreements you may have.

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Regulations, Deltek Costpoint

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.

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

We have had several clients tell us they have purchase orders under the Truthful Cost or Pricing Data (TINA) threshold for what they believe to be commercial purchases. They run a quick search on the purchase order (PO) and find there are no Federal Acquisition (FAR) or Defense FAR Supplement (DFARS) clauses in the agreement even though the prime contract is to the U.S. Government.

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