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.
Lynne Nalley, CPA
Recent Posts
Topics: Compliant Accounting Infrastructure, Government Regulations, Cost Accounting Standards (CAS)
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.
Topics: DFARS Business Systems, Cybersecurity
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.
Topics: Government Regulations, Cost Accounting Standards (CAS), Grants & Cooperative Agreements (2 CFR 200)
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.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
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.
Topics: DFARS Business Systems
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