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 Council Issues Proposed Rule to Increase Acquisition Thresholds

The FAR Council issued a proposed rule on November 29, 2024 to amend the FAR to increase acquisition related thresholds for inflation.

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance

Sole Source Justifications are Required for Purchases Over $10,000

The Government wants to pay a fair and reasonable price for products and services that they purchase and expects you to pay your suppliers a fair and reasonable price. FAR 52.244-5 Competition in Subcontracting includes the requirement to select subcontractors and suppliers on a competitive basis to the maximum extent possible. What happens when you receive only one bid or there is only one source that can perform the effort? Well, the purchase becomes sole source – and yes, the requirements have just increased significantly. If the purchase exceeds the micro-purchase threshold, yes $10,000, you must document the justification as sole source. While it sounds pretty simple, for example, when the customer directs a part to be purchased from a specific supplier, you just check the box “customer directed” and move on. Oh, if that were only the case. Even when a purchase is customer directed, more documentation is necessary. It is never as easy as checking a box. When you are directed to buy from a supplier, you must still document the price is fair and reasonable. If the price is not fair and reasonable, it is your job to inform the government.

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

Cost Accounting Standard (CAS) 411 – Accounting for Acquisition of Material Cost

CAS 411 provides criteria for accounting for the measurement and assignment of material costs to cost objectives and follows generally accepted accounting principles (GAAP).

What is the Purpose of CAS 411?

If you don’t have contracts subject to full CAS, then FAR 31.205-26 Material costs requires contractors to implement GAAP when accounting for material. Material costs can either be charged direct to a contract or assigned to contracts through inventory accounts. Material that is charged direct should be identified on the purchase order and material assigned through an inventory account should be consistently applied by category of material. While CAS 411 requires written policies for accounting for material, it is a best practice to establish written policies whether CAS 411 is applicable or not.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management and Accounting System (MMAS)

DoD Issues CMMC Proposed Rule - Submit Your Comments by October 15, 2024

DoD issued a proposed rule dated August 15, 2024 (DFARS Case 2019-D041) to amend DFARS to incorporate contractual requirements related to the Cybersecurity Maturity Module Certification (CMMC) Program. This implements a section of the National Defense Authorization Act for FY 2020 to enhance cybersecurity for the US defense industrial base. DoD is estimating that the final rule will be issued during Quarter 1 2025. Contractors should take heed and provide comments by the October 15, 2024, due date.

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Topics: Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity

Cost Accounting Standards (CAS 414 and 417) for Cost of Money as an Element of Cost

FAR 31.205-20 makes interest unallowable, however, cost of money is not interest based on the CAS Board and is allowable (see our article Interest is Unallowable – How is That Possible). Cost of money is an imputed cost that is provided to contractors to recover the time value of money invested in facilities and equipment that benefit government contracts. Contractors that do not have contracts subject to full CAS, follow FAR 31.205-10 Cost of money which incorporates CAS 414 (Cost of Money as an Element of the Cost of Facilities Capital) and CAS 417 (Cost of Money as an Element of the Cost of Capital Assets Under Construction) and allows cost of money as a cost as long as it is measured, assigned and allocated in accordance with the standard. Cost of money must be specifically identified and proposed in cost proposals to be claimed or billed. Let’s discuss the requirements of CAS 414 and 417.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Key Grant Regulations You Need to Know to Stay Compliant and Avoid Penalties

Grants are complex and the regulations in 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards aren’t exactly straight forward and easy to understand. When you receive a grant, you are expected to have internal controls in place such as policies and procedures, segregation of duties, timekeeping, documentation requirements, etc. If you do not have internal controls, you will need to implement them as soon as possible after award. While anyone can make mistakes, you don’t want continuous errors, overbillings, billing of unallowable costs to become significant noncompliance issues requiring corrective action or even the appearance of alleged fraud.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)

Indirect Rates for Grants and Cooperative Agreements

You are putting together a proposal in response to a Funding Opportunity Announcement (FOA) for a grant or cooperative agreement. It’s pretty simple. Just estimate direct labor, equipment, other direct costs, and my indirect rates. Correct? Well, maybe, but your indirect rates can be complex.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)

Subcontractors Can Request the Nontraditional Defense Contractor Exception

The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a Memorandum dated May 5, 2024, to Agencies on the Treatment of Nontraditional Defense Contractors.

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

When to Request a Consent to Subcontract If You Don't Qualify for a Purchasing Review

Probably now. Depending on the type and dollar amount of your subcontracts, FAR 52.244-2 Subcontracts clause requires a contractor that does not have an approved purchasing system (never been reviewed or is disapproved) to obtain written consent from the Contracting Officer before subcontract award.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

DFARS Final Rule on Commercial Products Procured Under Major Weapon Systems

DoD issued a final rule DFARS Case 2023-D010 on May 30, 2024, amending The Defense Federal Acquisition Regulation Supplement (DFARS) implementing Section 803 of the National Defense Authorization Act on data required in support of commerciality determinations and price reasonableness under procurements for major weapon systems. The purpose is to provide additional guidance related to the data required to support a request for a commercial determination and the price reasonableness process.

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