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

Hold On, My Company Can Submit a Commercial Quote on a Government or Prime Solicitation?

My commercial company wants to increase business with the Federal Government – but not with all those requirements the Government follows when buying under FAR Part 15 rules (Contracting by Negotiation). Is that even possible? The answer is “absolutely”.

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

Department of Energy Issues Class Deviation on System of Award Management (SAM)

Contractors are required to keep their System of Award Management (SAM) registration up to date. FAR 52.204-7(b)(1) requires an offeror to be registered in the System of Award Management (SAM) when submitting an offer/quote, registered until the time of award, during performance, and through final payment. Sounds pretty easy. However, contractors are not always registering or updating their registration, resulting in ineligible awards, as noted in recent court cases (See our blog: SAM Registrations: Check Often and Never Let it Lapse!).

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Topics: Contracts & Subcontracts Administration, System Award Management (SAM), Government Regulations

Why Identifying Commercial Items at Your Organization is Key

My company only sells to the Government so my products/services can’t be commercial. Truth or Myth. This is a myth. If you are selling products/services under FAR 15 based contracts or subcontracts, submitting certified cost and pricing data and documenting other accounting and purchasing requirements that come along with it, when the products/services technically meet the definition of commercial under the FAR – it may be time to rethink your approach.

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Topics: Proposal Cost Volume Development & Pricing, Commercial Item Determination

What are the Different Types of CAS Accounting Practice Changes?

Most contractors that have contracts/subcontracts subject to full CAS coverage will eventually want to make a change to a cost accounting practice because there is a “better” allocation method or a change is required to remain in compliance with CAS.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Cost Accounting Standards (CAS)

Another Cyber Security Noncompliance Under False Claims Act

Since the Department of Justice (DOJ) started promoting its initiative on Cyber Security reporting there have been several settlements related to cyber security noncompliance, four of which involve defense contractors.

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Topics: DFARS Business Systems, Cybersecurity

Grant Regulations are Going to be Updated Soon – Get Your Comments Ready

Suppose your company is working on a grant or cooperative agreement or planning to submit a proposal in response to a funding opportunity announcement. In that case, the regulations that apply will be Code of Federal Regulations (CFR) Title 2 Grants and Agreements. The problem is, when you receive a grant, generally, the award agreement says to comply with 2 CFR. There are no specific clauses or wording; basically, you are responsible for reading the entire regulation to see what applies to your award. 2 CFR includes inconsistent language and terms.

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

Proposed FAR Changes Loaded with More Contractor Requirements for Cyber Security

The FAR Council submitted a proposed rule amending FAR subparts, provisions, and clauses on October 3, 2023, to implement an Executive order on cyber threats, incident reporting, and information sharing for Federal contracts. This revision is being made to strengthen and standardize contractual requirements for cybersecurity across Federal agencies. The proposed rule also implements OMB Memorandum M-21-07 Completing the Transition to internet Protocol Version 6 (IPv6), dated November 19, 2020.

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

What? The Government is Banning TikTok on My Personal Phone!

The FAR Council published an interim rule effective June 2, 2023, that bans TikTok on contractor and contractor employee electronic devices that are used in the performance of federal contracts.

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

Subrecipient Risk Assessment under 2 Code of Federal Regulations (CFR) 200

In our article, Understanding your Lower-Tier Relationships with Subrecipient and Contractor Determinations under 2 CFR 200, we addressed the required determination as to whether the lower-tier organization supporting your Awards or Subawards are classified as subrecipients or contractors. Now that the determination is made and documented is that all that needs to be done? Well no.

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

OMB Extends Deadline for Software Supply Chain Security to Submit Attestation Forms

On June 9, 2023, the Office of Management and Budget (OMB) issued M-23-16, Update to Memorandum M-22-18, providing an extension to the deadline for software developers to submit attestation forms to Federal agencies.

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