On November 24, 2025, President Trump signed EO 14363, Launching the Genesis Mission to accelerate America’s race for global dominance in the application of AI to scientific discovery and scientific challenges.
Lynne Nalley, CPA
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 – ContractingRecent Posts
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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)
On December 5, 2025, the Department of Justice (DOJ) reported another settlement under the False Claims Act (FCA) related to cybersecurity. Swiss Automation agreed to pay $421,234 to the Government as a result of failing to provide adequate cybersecurity controls for drawings of parts supplied to Department of Defense (DoD) prime contractors. The qui tam suit under the False Claims Act (FCA) was brought forward by a whistleblower, not an Information Technology (IT) employee, but a Quality Control Manager of the company. The whistleblower received $65,291.
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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Item Determination
On November 26, 2025, the Office of Management and Budget (OMB) issued the 2025 Compliance Supplement. The Supplement outlines the compliance requirements to assist auditors in understanding the Federal program’s objectives, procedures and requirements when performing a Single audit for fiscal years beginning after June 30, 2024. The Compliance Supplement is normally issued in the spring of each year; however, OMB delayed its issuance to incorporate significant updates to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, in October 2024. In order to assist auditors with the different requirements, Part 3 Compliance Requirements of the Supplement was divided into two Parts for audit testing as follows:
- Part 3.1 for awards subject to 2 CFR 200 prior to October 2024 and
- Part 3.2 for awards after October 1, 2024
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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
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The Department of Defense (DoD) issued a final rule on September 10, 2025, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate the requirements of the Cybersecurity Maturity Model Certification (CMMC) for FAR-based contracts and subcontracts, effective November 10, 2025.
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Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Grants & Cooperative Agreements (2 CFR 200)
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Department of Defense (DoD) issued a final rule on September 10, 2025, amending Defense Federal Acquisition Regulation Supplement (DFARS), incorporating contractual requirements under the Cybersecurity Maturity Model Certification (CMMC) program as part of the National Defense Authorization Act for FY 2020 to enhance cybersecurity for the US defense industrial base. The final rule is effective November 10, 2025.
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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
If you have any grants or cooperative agreements (i.e., federal awards under 2 CFR 200), you must annually determine whether you must obtain an audit, as required by 2 CFR Subpart F. These are referred to as “Single Audits.” And yes, even if you get audited by the Defense Contract Audit Agency (DCAA) or one of its hired Independent Public Accountants (IPAs) for your FAR-based contract or subcontracts, if you have a grant, you will need a second audit.
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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
The President’s Executive Order – Restoring Common Sense to Federal Procurement involves a comprehensive overhaul of the Federal Acquisition Regulation (FAR) and subsequently the FAR Supplements. As the FAR is being updated it includes changes to contract provisions and clauses. The System for Award Management (SAM.gov), the official U.S. government website where entities register to do business with the federal government is also being streamlined.
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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)
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Contractors are required to use provisional billing rates when invoicing costs under cost reimbursable contracts or submitting an SF1443 Contractor’s Request for Progress Payment. FAR 42.704, Billing rates, requires the contracting officer or auditor (usually DCAA) to establish the billing rates. DCAA has undergone a reorganization, and the office assigned to your contractor site may have shut down or the staff may have been relocated.
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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
This is a myth. Let’s review the commercial definition:
FAR 2.101 Commercial Product definition Paragraph 1 states:
(1) A product, other than real property, that is of a type customarily used by the general public or by nongovernmental entities for purposes other than governmental purposes, and–
(i) Has been sold, leased, or licensed to the general public; or
(ii) Has been offered for sale, lease, or license to the general public;
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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
On May 1, 2025, the National Institute of Health (NIH) issued NOT-OD-25-104 updating its policy to reiterate the Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. This policy change will also prohibit foreign subawards in grants and cooperative agreements effective May 1, 2025, until NIH has developed a new foreign collaboration award structure policy. NIH is hoping to issue its new policy by September 30, 2025.
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Topics: Compliant Accounting Infrastructure, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)