Lynne Nalley, CPA

Lynne Nalley, CPALynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, 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. Professional Experience 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. Lynne 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. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting

Recent Posts

FAR Final Rule: Small Business Opportunities Overseas – Don't Pack Your Bags Yet


DoD issued a final rule on April 26, 2022, amending the FAR to support the Small Business Administration regulation of including overseas contracts in agency small business contracting goals. The final rule is effective May 26, 2022.

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Topics: Small Business Compliance, Contracts Administration, DFARS Business Systems, Proposals

Finally – Prior FAR 12 Contract = Commercial Item Determination, for the Most Part


 

DoD issued a final rule under DFARS Case 2020-D033, effective April 28, 2022, that allows Contracting Officers to rely on a contract issued under FAR Part 12 procedures to serve as a prior commercial item determination on future buys. It only makes sense, that Contracting Officers rely on prior FAR 12 contracts instead of recreating the wheel each time a contractor submits a commercial product/service and making the contractor continually support a product/service already determined commercial.

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

One More Required Company Executive Certification Under CMMC 2.0


CMMC was put on hold until recently – but is rolling forward again at a high speed. DOD held a CMMC Day Conference in May 2022 stating its goal of submitting a proposed rule in July 2022 ( no proposed rule to date) and issuing two interim final rules by March 2023. If DoD is able to stay on track (which does not appear to be the case) and issue the final interim rule by March 2023, contractors could start seeing CMMC requirements in solicitations soon after.

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

Contractors Beware: Don’t get caught with a Material Breach of Contract Terms


Contractor compliance with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 is back in the news. The Principal Director, Defense Pricing and Contracting (DPC), issued a memorandum dated June 16, 2022, to the Department of Defense Departments, Subject: Contractual Remedies to Ensure Contractor Compliance with Defense Federal Acquisition Regulation Supplement Clause 252.204-7012, for contracts and orders not subject to Clause 252.204-7020; and Additional Considerations Regarding National Institute of Standards and Technology Special Publication 800-171 Department of Defense Assessments.

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

Department of Justice Initiative on Cyber Security Incident Reporting


The Department of Justice (DOJ) announced in October 2021 that they are following through on the launch of the DOJ’s Civil Cyber-Fraud Initiative. This initiative is being used to pursue cybersecurity related fraud when Government contractors and subcontractors knowingly fail to comply with cybersecurity requirements, through the use of the False Claims Act (FCA). The DOJ is asking individuals (yes that means your employees) to focus their attention on potential cyber security noncompliance under the False Claims Act. It only takes one upset employee to report that you are not complying with your reported cybersecurity practices or have an unreported cyber-attack affecting covered defense information. Contractor employees who file a qui tam suit can receive a government payment incentive of 15 to 30 percent of the recovery. There has already been one reported contractor settlement resolving a qui tam suit for a company failing to meet federal cybersecurity standards.

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

Bye-Bye Foreign, Buy American


The FAR Council published a final rule on March 7, 2022, implementing revisions to the Buy American Act. The final rule strengthens the impact of Federal procurement preferences for products and construction materials domestically manufactured from substantially all domestic content and is effective October 25, 2022.

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

It is Time for a CPSR Review – Is Your Universe Up-To-Date?


What is a CPSR Review?

A CPSR Review is a Contractor Purchasing System Review. This review is performed by the Government on a contractor, in order to:

  • assess the overall health of the purchasing organization,
  • evaluate the efficiency and effectiveness of the contractor’s practices in expending Government funds,
  • perform an independent review of the contractor’s system to optimize its effectiveness in compliance with Government policy, and
  • identify risk to provide the Administrative Contracting Officer (ACO) a basis for approving or disapproving the purchasing system.
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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)

Limitation on Pass-Through Charges in Government Contracts


Does the Total of All Proposed Subcontract Costs Exceed 70% of the Total Contract Costs?

Is your company submitting a proposal to the government/prime contractor that includes a total of all subcontract costs exceeding 70 percent of the total costs proposed? If so, you must identify “added value” in your proposal so the government/auditor does not classify the indirect cost applied to the total subcontract cost as “excessive pass-through charges.”  The government considers indirect costs and profit/fee that a contractor applies to subcontract costs that exceed 70 percent of the contract to be “pass through costs.” This applies to lower tier subcontract costs also. If there is no negligible value added by the contractor, the government or auditor will question the indirect costs and profit/fee applied to the subcontract costs as unallowable excessive pass through under FAR 31.203(i).

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Topics: Compliant Accounting Infrastructure, Cost and Pricing and Budgeting, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations

Cyber Incident Reporting For GovCon


Due to the recent Russian invasion in Ukraine, there has been a significant increase in cyber-attacks reported across the world. While the U.S. Government has concerns related to attacks on U.S. companies including banks, power companies, fuel suppliers, they are also concerned with defense contractors. President Biden has issued multiple warnings to companies including defense contractors about looming cyber-attacks.

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

DCMA Commercial Item Group - Year in Review


What is the Commercial Item Group (CIG)?

So, what is the DCMA CIG? They are the “cadre of experts” established under DCMA as a result of Section 831 of the FY 2013 National Defense Authorization Act (NDAA). The purpose of the CIG is to assist DoD contracting officers in making commercial item determinations. There are several DCMA ACO’s that have warrants specific to making commercial item determinations on contractor assertions or higher-tier contractor determinations of its supplier’s assertions at the request of a buying command. DCMA CIG has price analysts and engineers that perform market research, evaluate the commercial submission, determine whether pricing is fair and reasonable as well as provide negotiation support.

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Topics: Cost and Pricing and Budgeting, Proposals, Commercial Item