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.
Lynne Nalley, CPA

Recent Posts
Topics: Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems
So, you have Federal Acquisition Regulation (FAR) based government contracts. Submitting a proposal for a grant should be similar, after all government regulations are government regulations – Right? Not really.
So, you have a Contractor Purchasing System Review (CPSR) in the pipeline. Whether your first CPSR review or Defense Contract Management Agency (DCMA) is returning to perform a comprehensive review, you should make sure your house is in order.
Effective for tax years after December 31, 2021, companies that have research and development expenditures will be required to amortize their R&D costs instead of deducting them in the current year. So, what is the impact – an increased tax bill beginning in 2022.
Topics: Compliant Accounting Infrastructure, DFARS Business Systems, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
Office of Management and Budget (OMB) issued a memorandum dated September 14, 2022, Subject Enhancing the Security of the Software Supply Chain through Secure Software Development Practices. This is a result of the President’s Executive Order on Improving the Nation’s Cybersecurity.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
If your company has an accounting system audit in the near future, now is the time to get prepared, before DCAA starts knocking at your door. So, what are the common deficiencies? We are going to address the typical post award accounting system audit and deficiencies that DCAA frequently identifies during an audit.
Topics: Compliant Accounting Infrastructure, Government Compliance Training, DCAA Audit Support
The Department of Justice (DOJ) settled one of the first lawsuits related to alleged cybersecurity fraud by Aerojet Rocketdyne, a defense contractor. So how did it begin. Aerojet Rocketdyne hired an employee as the Senior Director for Cyber Security, Compliance and Controls. The employee asserts that Aerojet misrepresented its compliance with the cyber requirements in DFARS 252.204-7012 when communicating with government officials to obtain DOD and NASA contracts between 2013 and 2015. The employee later refused to sign documents stating Aerojet was compliant with the cybersecurity requirements and reported it to the company’s ethics hotline and filed an internal company report. The employee was terminated and filed a qui tam suit alleging cybersecurity fraud under the False Claims Act.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
DoD issued a final rule on April 26, 2022, amending the FAR to support the Small Business Administration regulation of including overseas contracts in agency small business contracting goals. The final rule is effective May 26, 2022.
Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems
DoD issued a final rule under DFARS Case 2020-D033, effective April 28, 2022, that allows Contracting Officers to rely on a contract issued under FAR Part 12 procedures to serve as a prior commercial item determination on future buys. It only makes sense, that Contracting Officers rely on prior FAR 12 contracts instead of recreating the wheel each time a contractor submits a commercial product/service and making the contractor continually support a product/service already determined commercial.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination
CMMC was put on hold until recently – but is rolling forward again at a high speed. DOD held a CMMC Day Conference in May 2022 stating its goal of submitting a proposed rule in July 2022 ( no proposed rule to date) and issuing two interim final rules by March 2023. If DoD is able to stay on track (which does not appear to be the case) and issue the final interim rule by March 2023, contractors could start seeing CMMC requirements in solicitations soon after.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity