John C. Shire, CPA

John C. Shire, CPAJohn 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

Recent Posts

FAR Part 31 Provides Special Treatment for Construction and A&E Contracts

FAR 31.105, Construction and architect-engineer contracts, provides somewhat unique cost accounting expectations (i.e., cost principles and procedures) the Federal Government has when awarding contracts for construction management or construction, alteration or repair of buildings, bridges, roads, or other kinds of real property. It also addresses architect-engineer (A&E) contracts related to construction projects. This applies to all cost-reimbursable contracts and the pricing of contracts based on cost analysis as required by FAR 15.404-1(a)(3).

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Topics: Government Regulations, Federal Acquisition Regulation (FAR), Federal Construction Contracting

The Hidden Competitor in Federal Construction and A&E Contracting

FAR 36.203, Government estimate of construction costs, and FAR 36.605, Government cost estimate for architect-engineer work, require the development of an independent Government estimate of the cost of construction costs and architect-engineer services when the value is expected to exceed the simplified acquisition threshold ($250,000). The estimate shall be prepared in as much detail as though the Government were competing for award or on the basis of a detailed analysis of the required work as though the Government were submitting a proposal. Access to the Government estimate is limited to Government personnel unless during negotiations the contracting officer identifies a specialized task and discloser is deemed necessary to arrive at a fair and reasonable price.

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Topics: Government Regulations, Federal Acquisition Regulation (FAR), Federal Construction Contracting

Internal Controls Required for Federal Grants and Cooperative Agreements


Organizations receiving Federal awards (i.e., grants or cooperative agreements) are required by 2 CFR 200.303(a) to “[e]stablish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” This section goes on to provide that the internal controls should comply with the guidance in:

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Topics: Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

Which Cost Accounting Regulations Apply When You Have Grants and Federal Contracts?

Organizations that have federal awards, whether that be grants, cooperative agreements or contracts, must comply with specific cost accounting regulations. Unfortunately, depending on the type of federal award, the regulations may not be the same. Both, both Grants or Cooperative Agreements awarded under 2 Code of Federal Regulations (CFR) 200 and Contracts awarded under 48 CFR Federal Acquisition Regulations (FAR) provide requirements for cost allowability, allocability, and reasonableness as well as the required cost accounting treatment for all cost:

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Topics: Compliant Accounting Infrastructure, Government Regulations, Cost Accounting Standards (CAS), Grants & Cooperative Agreements (2 CFR 200)

Should Payroll Protection Program (PPP) Loan and Forgiveness Have Been Treated as a Credit?

We understand this revelation (so to speak) is likely too late for many contractors that have already established final indirect rates for the year of PPP forgiveness; however, any direct costs adjusted for loan forgiveness still remain open until closeout of the contract.

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Topics: COVID-19, Paycheck Protection Program (PPP) Loans

The Court of Appeals Reverses The Armed Services Board in The Raytheon Case

Apparently, nothing the Board found was to the liking of the judges at the United States Court of Appeals for the Federal Circuit in Case Number 21-2304, Secretary of Defense v. Raytheon Company, Raytheon Missile Systems, decided January 3, 2023. This was the appeal from the Armed Services Board of Contract Appeals in Nos. 59435, 59436, 59437, 59438, 60056, 60057, 60058, 60059, 60060, and 60061.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Government Regulations, Federal Acquisition Regulation (FAR)

The Theory of Laches Does Not Apply Under Contracts Disputes Act

In the Lockheed Martin ASCBA Case 62209 Lockheed Martin Aeronautics Company April 13, 2022 Decision, the Board found that when there is a Congressionally established statute of limitation the “theory of laches” does not apply.

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Topics: Government Regulations, Federal Acquisition Regulation (FAR)

ASBCA Case Helps Nail Down Record Retention Requirements

In the ASCBA Case 61691 Doubleshot, Inc. July 19, 2022 Decision, the Board supported what we believe is the correct reading of the records retention requirement under the FAR related to Cost-Reimbursable contracts. FAR 52.215-2, Audit and Records, requires contractors to make available until 3 years after final payment or any shorter period specified in Subpart 4.7.[1] FAR 4.705-2(b) limits the required retention period to 2 years from the end of fiscal year for pay related records (e.g., timesheet or cards).[2] So provided you submit your Incurred Cost Submission (required by FAR 52.216-7, Allowable Cost and Payment Clause) on time, you only need to maintain any of the records listed in FAR Subpart 4.7 for the time period set forth in that section of the FAR.

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

The Future Does Not Look Good For COVID Related REAs

Recent Armed Services Board of Contract Appeals (ASBCA) cases have rejected contractor requests for equitable adjustments (REAs) related to the impact of COVID-19 on contract performance under firm fixed price (FFP) contracts. In both cases, discussed below, the ASBCA turned to the Connor Bros. Federal Circuit decision (550 F.3d 1368 (2008)). In that decision the Federal Circuit found the act of the Sovereign Government does not result in an act of the Government as a contracting party. Therefore, under the “Changes” clause (FAR 52.243-1, Changes-Fixed-Price) that was in Connor’s contract this did not give rise to an equitable adjustment in the contract price. The basis of the Connor Bros. decision and the two recent cases is the “Sovereign Acts Doctrine.”

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Topics: Government Regulations, COVID-19, Federal Acquisition Regulation (FAR)

Does Micro-Purchase Threshold Apply to Government Contractors?

Government Contractor Purchases below the Micro-Purchase Threshold Require NO Documentation

This is a common misconception within the GOVCON community. While the expectations are clearly less documentation and effort are required than that of a larger dollar value purchase, there is not a magic threshold at which NO documentation of the fair and reasonable price is allowed.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

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