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 – Contracting
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.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DOD IG, Government Compliance Training, Paycheck Protection Program (PPP) Loans
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.
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!
Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination
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.
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.
Topics: DOD IG, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR)
FAR 52.204-10 requires the contractor to report executive compensation of first-tier subcontracts with a value of $30,000 unless an exemption applies. Contracting Officers are required to include the FAR clause 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, in all solicitations and contracts of $30,000 or more. A first-tier subcontract is a subcontract awarded directly by the contractor for the purpose of acquiring supplies or services for performance of a prime contract. This does not include long term arrangements between the prime and first-tier subcontractors for material or supplies that benefit multiple contracts.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)
DCAA created a new portal called Contractor Submission Portal (CSP) which is addressed in DCAA’s Memorandum for Regional Directors (MRD) 20-OTS-005(R) dated September 29, 2020. The portal allows contractors a means to submit their Incurred Cost proposals electronically. There are three options available to contractors when uploading the incurred cost proposal:
DCAA is given the authority under DFARS 242.803(b) to approve interim vouchers for DoD. DFARS 242.803(b) states DCAA will approve interim vouchers using sampling methodology for provisional payment after a prepayment review. This also includes reviewing completion/final vouchers and issuing a DCAA Form 1, Notice of Contracts Costs Suspended and/or Disapproved when DCAA questions the allowability of costs.
Topics: Compliant Accounting Infrastructure, DFARS Business Systems
The calendar year ended December 31st and you are closing your books and gathering information for your incurred cost submission that is due June 30th. There is one more requirement you should consider that may have been overlooked. Does your company meet the requirement to input independent research and development (IR&D) costs into the Defense Technical Information Center (DTIC)?
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Cost Accounting Standards (CAS)
Prime contractors must award contracts to responsible subcontractors. One of the required flowdowns from a prime to a subcontract is FAR 52.209-6, Protecting the Government's Interest When Subcontracting with Contractors Debarred, Suspended, or Proposed for Debarment. This flowdown is required when the solicitation or contract exceeds $35,000 but is not required when purchasing commercially available off the shelf (COTS) items. The purpose of the clause is to protect the government. A contractor that is debarred or suspended is referred to as an excluded contractor.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)