This is the first blog on a three-part series on progress payments and discusses progress payments and the applicable rates.
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, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)
DCAA has caught up on their incurred cost backlog and is concentrating effort on Truth in Negotiations Audits (i.e., Defective Pricing). The objective of the Truth in Negotiations audit is to determine whether a negotiated contract price was increased by a significant amount because a contractor did not submit or disclose current, accurate or complete cost or pricing data.
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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)
DoD Inspector General Audit on Whistleblower
We issued a blog in May 2021 addressing the Department of Justice, Inspector General. The IG found that DOJ contracts did not comply with the whistleblower requirements to include whistleblower clauses in the contract, disseminate the rights and protections in writing to employees, and include required information in confidentiality agreements/statements to employees. We indicated we would not be surprised to see the DoD IG pick up on this area and review DoD Contractors.
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Topics: DOD IG, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR)
This video and article discuss the importance of provisional billing rates for government contractors. If you have cost-reimbursable vouchers or progress payments based on costs, you want to make sure you have established provisional billing rates.
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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Vlog
The focus of fraud used to be primarily on defense contractors, health care providers and health care suppliers. However, other companies are now being exposed to the Federal Claims Act (FCA) including software companies, private equity financiers, insurance companies, and educational institutions. Additionally, fraud is not just related to companies receiving the funds.
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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DOD IG, Government Compliance Training, Paycheck Protection Program (PPP) Loans
What is SAM.gov?
SAM.gov is the System for Award Management (SAM) in which businesses must register to contract with the US Government and for non-profits to receive grants. The registration is valid for one year and must be renewed annually. It is recommended to renew 45-60 days prior to expiration.
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Topics: System Award Management (SAM)
A commercial item determination should define the item or service, document market research, identify the FAR 2.101 Commercial Item definition, and include a “determination” that the item is commercial. Sounds easy right!
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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination
Safeguarding Controlled Unclassified Information – Procedures to Consider and Your Chance to Comment
What is CUI, CDI and CTI?
CUI is Controlled Unclassified Information and encompasses all Covered Defense Information (CDI) and Controlled Technical Information (CTI). CUI requires the safeguarding or dissemination of controls pursuant to applicable laws, regulations, and government-wide policies.
- Covered Defense Information (CDI) is unclassified controlled technical information or other information described in the Controlled Unclassified Information (CUI) Registry found here.
- Controlled Technical Information (CTI) is technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination. It does not include information that is lawfully publicly available without restrictions.
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Whistleblower claims are on the rise with alleged violations of health and safety laws as well as fraud and abuse under the CARES Act due to the pandemic. Employers need to ensure they are familiar with the whistleblower laws and their responsibilities under government contracts.
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Topics: DOD IG, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR)