Lynne 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
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.
Topics: Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
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.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
On April 27, 2023, The Cybersecurity and Infrastructure Security Agency (CISA) of The Department of Homeland Security (DHS) published a draft Secure Software Development Attestation Form. Software producers that sell to the government will be required to complete the self-attestation form to attest that the software they produce was developed in conformity with specified secure development practices.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
The National Defense Authorization Act (NDAA) 2023, Section 803 amended the data that contractors are required to supply for commercial products at the subsystem, component and spare-part levels for major weapons system. While a DFARS proposed rule is being drafted, we expect Contracting Officers and DCMA Commercial Item Group (CIG) to begin requiring this information for proposed commercial products in advance of the DFARS proposed rule.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination
DoD Issued a Final Rule amending the Defense Acquisition Regulation Supplement (DFARS) to require contracting officers to consider Supplier Performance Risk System (SPRS) risk assessments when evaluating a suppliers quote or offer. The final rule is effective March 22, 2023. The Supplier Performance Risk System (SPRS) is the authoritative source to retrieve supplier product and performance information assessments for the DoD acquisition community to use in identifying, assessing, and monitoring unclassified performance.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Cybersecurity
DoD issued a Final Rule (DFARS Case 2021-D001) amending the DFARS to expand Contracts Eligible for Quick Closeout. The final rule is effective March 1, 2023. We believe there will be an increase in the number of DCMA requests to apply the quick closeout procedures to contracts with less than $2 million of unsettled direct and indirect cost, or if it is in the best interest of the government regardless of the dollar amount of the contract or unsettled costs. Seeing as DCAA questions less than 1% of the incurred cost it does get around to auditing. It would be in DoD’s best interest to close all completed contracts. One can only hope.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations
The Small Business Administration issued a final rule effective August 22, 2022 (Federal Register: Past Performance Ratings for Small Business Joint Venture Members and Small Business First-Tier Subcontractors), which provides two new methods for small business government contractors to obtain/receive credit for past performance ratings. Prior to this rule, small businesses did not always receive credit for past performance for much of their efforts supporting the Federal Government. A small business can now get credit for past performance under a joint venture or use a past performance rating for work performed as a first-tier subcontractor to compete for their own prime contracts. See Redstone’s blog “Small Businesses Have More Opportunities to Obtain Past Performance Ratings under SBA Final Rule”. It is unclear whether the FAR 52.219-9 Small Business Subcontracting Plan clause will be updated.
Topics: Small Business Compliance, Contractor Purchasing System Review (CPSR)
The Small Business Administration issued a final rule effective August 22, 2022 (Federal Register: Past Performance Ratings for Small Business Joint Venture Members and Small Business First-Tier Subcontractors), which provides two new methods for small business government contractors to obtain/receive credit for past performance ratings. Prior to this rule, small businesses did not always receive credit for past performance for much of their efforts supporting the Federal Government. A small business can now get credit for past performance under a joint venture or use a past performance ratings for work performed as a first-tier subcontractor to compete for their own prime contracts. It is unclear whether the FAR 52.219-9 Small Business Subcontracting Plan clause will be updated.
Topics: Small Business Compliance, Contractor Purchasing System Review (CPSR)
The Office of Management and Budget (OMB) issued a proposed rule to add a new Part 184 in 2 CFR Chapter I and revisions to 2 CFR 200.322 Domestic preferences for procurements on Build America/Buy America Act for Grants and Agreements. The revision will address the Buy American Preference for awards with infrastructure expenditures. Comments to the proposed rule are due March 13, 2023.
Topics: Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
DoD issued a DFARS Final Rule on Treatment of Incurred Independent Research and Development Costs (DFARS Case 2017-D019). The rule is effective January 31, 2023.
Topics: Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems
