Lynne Nalley

Lynne NalleyLynne Nalley is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Items, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. She was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Lynne currently specializes in assisting companies with Business System Reviews and complex DCAA audit issues related to business systems and CAS. She also assists with prime contractor commercial item determinations and related support. Education Lynne earned a Bachelor of Science Degree in Accounting from University of Central Florida.

Recent Posts

What Information Should I Include in a Commercial Item Determination?

A commercial item determination should define the item or service, document market research, identify the FAR 2.101 Commercial Item definition, and include a “determination” that the item is commercial. Sounds easy right!

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Topics: Business Systems Review, Cost and Pricing and Budgeting, DFARS Business Systems, Contractor Purchasing System Review (CPSR)

Safeguarding Controlled Unclassified Information – Procedures to Consider and Your Chance to Comment

What is CUI, CDI and CTI?

CUI is Controlled Unclassified Information and encompasses all Covered Defense Information (CDI) and Controlled Technical Information (CTI). CUI requires the safeguarding or dissemination of controls pursuant to applicable laws, regulations, and government-wide policies.

  • Covered Defense Information (CDI) is unclassified controlled technical information or other information described in the Controlled Unclassified Information (CUI) Registry found here.
  • Controlled Technical Information (CTI) is technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination. It does not include information that is lawfully publicly available without restrictions.
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Topics: Compliant Accounting Infrastructure, Cybersecurity Maturity Model Certification (CMMC), Cybersecurity

Is Your Company Familiar with the Whistleblower Laws?

Whistleblower claims are on the rise with alleged violations of health and safety laws as well as fraud and abuse under the CARES Act due to the pandemic. Employers need to ensure they are familiar with the whistleblower laws and their responsibilities under government contracts.

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Topics: Business Systems Review, DOD IG, Human Resources, Contractor Purchasing System Review (CPSR)

Subcontractor has to Report Executive Compensation – Say What?

What is FAR 52.204-10 – Reporting Executive Compensation and First-Tier Subcontract Awards?

FAR 52.204-10 requires the contractor to report executive compensation of first-tier subcontracts with a value of $30,000 unless an exemption applies. Contracting Officers are required to include the FAR clause 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, in all solicitations and contracts of $30,000 or more. A first-tier subcontract is a subcontract awarded directly by the contractor for the purpose of acquiring supplies or services for performance of a prime contract. This does not include long term arrangements between the prime and first-tier subcontractors for material or supplies that benefit multiple contracts.

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Topics: Business Systems Review, Contractor Purchasing System Review (CPSR)

New DCAA Portal for Contractor Incurred Cost Proposal Submissions

DCAA created a new portal called Contractor Submission Portal (CSP) which is addressed in DCAA’s Memorandum for Regional Directors (MRD) 20-OTS-005(R) dated September 29, 2020. The portal allows contractors a means to submit their Incurred Cost proposals electronically. There are three options available to contractors when uploading the incurred cost proposal:

  • Submit a new proposal
  • Update an existing proposal
  • Withdraw a proposal
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Topics: Incurred Cost Submission, Incurred Cost Proposals

You’re Not Rejecting My Voucher

DCAA’s Authority for Interim Vouchers

DCAA is given the authority under DFARS 242.803(b) to approve interim vouchers for DoD. DFARS 242.803(b) states DCAA will approve interim vouchers using sampling methodology for provisional payment after a prepayment review. This also includes reviewing completion/final vouchers and issuing a DCAA Form 1, Notice of Contracts Costs Suspended and/or Disapproved when DCAA questions the allowability of costs.

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Topics: Business Systems Review, Cost-Type Contracts, Accounting & Billing System

Does Your Company Qualify as a “Major Contractor” for IR&D Reporting?

The calendar year ended December 31st and you are closing your books and gathering information for your incurred cost submission that is due June 30th. There is one more requirement you should consider that may have been overlooked. Does your company meet the requirement to input IR&D costs into the Defense Technical Information Center (DTIC)?

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Topics: Incurred Cost Submission, Incurred Cost Proposals, Cost Accounting Standards (CAS), Accounting

Contracting with Responsible Subcontractors

Prime contractors must award contracts to responsible subcontractors. One of the required flowdowns from a prime to a subcontract is FAR 52.209-6, Protecting the Government's Interest When Subcontracting with Contractors Debarred, Suspended, or Proposed for Debarment. This flowdown is required when the solicitation or contract exceeds $35,000 but is not required when purchasing commercially available off the shelf (COTS) items. The purpose of the clause is to protect the government. A contractor that is debarred or suspended is referred to as an excluded contractor.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)

DFARS Class Deviation 2020-O0021 and 2020-O0013 Revision

DFARS Class Deviation 2020-O0021 Revision

On January 15, 2021, the Principal Director at Defense Pricing and Contracting (DPC) issued a memorandum on the CARES Act Section 3610 Reimbursement Requests, DFARS Class Deviation 2020-O0021, Revision 2. This memorandum revises and supersedes the DFARS Class Deviation 2020-O0021 Revision 1 issued on October 14, 2020. The only revision is to extend the period for which paid leave must be taken from March 27, 2020 through December 11, 2020 to March 27, 2020 through March 31, 2021. The remainder of the memorandum remains unchanged and details are included in Redstone GCI’s blog.

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Topics: Incurred Cost Proposals, Accounting & Billing System, COVID-19

Are Contract Briefs Necessary?

What is a Contract Brief?

A contract brief is a document which identifies information about the contract, contract administration representatives and significant contract terms and conditions.

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Topics: Incurred Cost Submission, Incurred Cost Proposals, Cost-Type Contracts, Accounting & Billing System