John is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to the DFARS business systems, CAS Disclosure Statements, and DCAA/DCMA compliance preparation, advisory, and defense. Prior to joining Redstone Government Consulting, John served in a number of capacities with DCAA/DCMA for more than 30 years. Upon his retirement, he was based in Texas as an SES-level Corporate Audit Director for DCAA, managing a staff of 300 auditors at one of the largest DOD programs. Professional Experience John began his career in the late 80s working in the Clearwater, FL audit office and over the next three decades he progressed through a number of positions within both DCAA and DCMA with career highlights as DCAA Program Manager at Ft. Belvoir, Chief of Technical Programs Division, Deputy Assistant Director-Policy, Director of the DCMA Cost and Pricing Center, the SES-level Lockheed Martin Corporate Audit Director, and Director of Integrity and Quality Assurance. John’s three decades of experience in performing and leading DCAA auditors and DCMA reviewers provides a wealth of expertise to our clients. John’s role, not only in the performance of audits, but also in the development of audit policy affords him unique insights into the defense of audit findings and the linkage of audit program steps to the underlying regulatory framework. He is an expert in FAR, DFARS, and other agency acquisition regulation, as well as a subject matter expert in the Cost Accounting Standards having reviewed and provided audit feedback on many of the largest and most complex cost accounting practices during his tenure with the DCAA. John’s tenure with DCAA and DCMA came at a critical time during each agency’s history where a number of changes were occurring such as the response to the ICS backlog, development of audit approaches to the DFARS Business Systems and implementation of new audit initiatives as a result of Congressional oversight through the NDAA process. John’s leadership at the DCMA Cost & Pricing center saw oversight of all major DOD pricing actions, leadership of should cost review teams, the Commercial Pricing group and many other areas of strategic value to our clients. His involvement in these and other Agency initiatives is of great value to our clients due to his in depth understanding of DCAA and DCMA’s internal policy directives. Education John holds a Master of Business Administration and a B.A. in Accounting from the University of South Florida. Certifications Certified Information Systems Auditor State of Alabama Certified Public Accountant
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:
Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
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.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
FAR Part 36 - Construction and Architect-Engineer Contracts provides the direction to contracting officer on the expected processes and requirements around contracting for construction and Architectural and Engineering (A&E) services. Part 36 addresses construction and A&E separately and we have included some of the key areas below.
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Commercial Item Determination, Federal Construction Contracting
Normally, I make numerous references to the Federal Acquisition Regulations (FAR) when writing. However, there is only one FAR reference for this topic, and then we must turn to the Accounting Standards Codification (ASC). In this case, that single FAR reference is FAR 31.201-2(a)(3).
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)
I wrote an article in 2022, “The Future Does Not Look Good For COVID-Related REAs.” Well, it looks like things may have changed. On October 2, 2024, the Armed Services Board of Contract Appeals (ASBCA) issued its decision in the Appeals of Chugach Federal Solutions, Inc. ASBCA Nos. 62712, 62713, and 62877. In this case, the Board “rule[d] the government … failed to carry its burden to establish the sovereign acts defense.”
Topics: Contracts & Subcontracts Administration, Government Regulations, COVID-19, Federal Acquisition Regulation (FAR)
Every small business that receives a Federal Government cost reimbursable contract is expected, by the Defense Contract Audit Agency (DCAA), to have a “sound internal control environment, accounting framework, and organizational structure.”
Topics: Compliant Accounting Infrastructure, Small Business Compliance, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
Yet another interesting case to consider from United States Court of Appeals for the Federal Circuit – ACLR, LLC v. United States Court of Appeals 2013-1190.
Topics: Litigation Consulting Support, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
Lessons Learned from a recent Armed Services Board of Contract Appeals (ASBCA) case – Platinum Services, Inc. ASBCA Nos. 62199, 62200.
The contractor (Platinum Services, Inc. – PSI), the Army, and even the Board all agree the services were rendered, however, since an official certified claim was not filed within six years from the date of the initial invoicing, the Government does not have to pay.
Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
The Court of Appeals decision came out on June 26, 2024, and I have been trying work it through my head how they got to their decision. I for sure do not have an answer but I have come up with some ideas and concerns. International Development Solutions, LLC v. Secretary of State, U.S. Court of Appeals, Federal Circuit, 68 CCF ¶82,658, (Jun. 26, 2024)
Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)
CAS 416 provides criteria for the measurement of insurance costs, the assignment of such costs to cost accounting periods, and the allocation to final cost.
Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)