Redstone Government Consulting Blog | Lynne Nalley and John Shire (3)

For-profit organizations that receive grants must establish a cost accounting system that complies with the Cost Principles in FAR part 31.2, read our article Which Cost Accounting Regulations Apply When You Have Grants and Federal Contracts. Additionally, a for-profit organization with a grant must also comply with the 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards and agency supplements for all other requirements under the grant, cooperative agreement, or subaward. While there are similarities between the FAR and 2 CFR 200 requirements – for example: written policies and procedures, accounting by project, and timekeeping practices, there are differences as well – the requirement for audit is one.

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

The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a guidance memorandum dated March 18, 2024 to Agencies based on the results of the Department of Defense (DoD) Inspector General (IG) Audit of DoD Compliance on Whistleblower Protection Requirements. While the DoD IG found in most cases, that Contracting Officers included the DFARS 252.203-7002 Requirement to Inform Employees of Whistleblower Rights clause in contracts, they did not verify whether contractors were complying with the clause.

Topics: Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

Cost Accounting Standard (CAS) 420 outlines accounting standards for Independent Research and Development (IR&D) and Bid & Proposal (B&P) costs incurred by government contractors, ensuring consistent and transparent reporting.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

In November of 2023, DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to partially implement a section of the 2017 National Defense Authorization Act (NDAA) addressing the Federal Acquisition Regulations (FAR) and DFARS contract clauses impacting prime or higher-tier contractors issuing commercial subcontracts for commercial products, including commercially available off-the-shelf items, and commercial services.

Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Service Contract Act, Commercial Item Determination

How does the Government define construction? We need to consider some of the definitions in FAR part 2:

Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Commercial Item Determination, Federal Construction Contracting

So, you have a contract with the clause FAR 52.230-2 Cost Accounting Standards, subject to full CAS coverage. If you receive allocations from a home office, the home office must comply with CAS 403, Allocation of home office expenses to segments. A home office has the responsibility for directing or managing two or more segments of an organization and includes intermediate home offices or a corporate office.

Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

The FAR Council issued an interim rule, effective December 4, 2023, which implements the requirements of the Federal Acquisition Supply Chain Security Act (FASCSA). This included three new FAR clauses which prohibit the delivery or use of “covered articles” subject to a FASCSA order in the performance of a government contract.

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

The National Defense Authorization Act (NDAA) for Fiscal Year 2022 and 2023 permanently authorized the Department of Defense (DoD) “to acquire innovative commercial products and commercial services through a competitive selection of proposals resulting from a general solicitation, known as a commercial solutions opening (CSO).” On August 17, 2023, the final rule was published in the Federal Register under DFARS Case 2022-D005 changing several parts of the DFARS – with most of the changes within DFARS part 212.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)