Redstone Government Consulting Blog | Redstone Team (10)

At Redstone GCI we are constantly seeking new tools to make our clients (and by extension us too) lives easier when it comes to maintaining compliance and completing deliverables for government customers.  One of the most challenging areas for contractors of all shapes and sizes in the proposal management process.  The government’s increasing use of multiple award IDIQ and other task order driven contracts often necessitates the formation of contractor teams.  In these situations, not only are you worried about your prime proposal, but you’re also managing data calls to your subcontractors to create the consolidated volumes for response to the government customer.  To say managing this process can be a challenge, is an understatement.

As a follow-up to our recent blog post, My CPA Audited My Financial Statements. Does That Mean My Accounting System is Adequate?  where we covered some differences between a financial statement audit and an adequate accounting system, we received several great questions from our readers.  We thought it might be beneficial to address them via a new blog post for the benefit of all our readers.  We welcome discussion on our blogs, though we do so in private via email.  In this case, though, these questions are ones we see frequently and impact all companies doing business with the U.S. Government.

Recently, there has been much discussion around comments made by Katie Arrington, the special assistant to the Assistant Secretary of Defense for Acquisition for Cyber in the Office of the Under Secretary of Acquisition and Sustainment in DoD.  She made the following statement before a roomful of vendors at the PSC meeting in Arlington, VA.

How would you feel if you had unlimited access to all the resources Redstone Government Consulting had to offer?  Relief?  Security?  Control?  Protected?  Re-focused?

The topic of accounting system adequacy seems to be a recurring issue for many in the government contracting community.  Earlier this month in the ongoing “process of elimination”, GAO weighed in again on what is NOT considered a determination of accounting system adequacy.  In Shivoy B-413104.36, GAO rightfully denied a protest for unequal treatment in eliminating a proposed offeror due to lack of verification of a proposed subcontractor’s accounting system as adequate.

On December 18, 2018 the Administrative Judge, in ASBCA No. 61583, denied the contractor’s appeal and granted the Government’s request for summary judgement related to the contractor’s claim that it was entitled to a penalty waiver because the contractor did not demonstrate that it “had adequate policies, training, controls, and review systems, and that it inadvertently incorporated the [unallowable cost]” in its incurred cost proposals. This decision serves as a reminder of the importance of maintaining adequate policies and procedures.

FAR Part 31.205 -1 – Public Relations and Advertising Costs

“Marketing is the activity, set of institutions, and processes for creating, communicating, delivering, and exchanging offerings that have value for customers, clients, partners, and society at large.” (American Marketing Association)

“Advertising is the action of calling something to the attention of the public especially by paid announcements.” (Merriam-Webster)

“Public relations (PR) is a strategic communication process that builds mutually beneficial relationships between organizations and their publics.” (Public Relations Society of America (PRSA))

Slowly is the word that always describes Government change, and acquisition process change is no exception.  Some of you will remember that the 2017 NDAA required DCAA to reduce the backlog of DoD incurred cost submissions and suspend work for other Departments.  But how many of you remember that it also created an Advisory Panel on Streamlining and Codifying Acquisition Regulations, better known as the Section 809 Panel? 

• RFP for 8(a) On Ramp can be found here: https://www.fbo.gov/index?s=opportunity&mode=form&id=31402bd0ff9188c41e8ec213e8375fc1&tab=core&_cview=1
• RFP for Small Business Pools 1, 3 and 4 can be found here: https://www.fbo.gov/index?s=opportunity&mode=form&tab=core&id=9f4b11d2c577b7ae6c5fc4ceae0320de

Key Dates (Subject to Change. Always check FBO/solicitation for latest info):

It’s everyone’s least favorite time of year.  That’s right, tax season.  For those of us who no longer work in public accounting, this time of year is now a welcome reprieve; although for us, it also marks the start of incurred cost season.  If you’re not sure what an Incurred Cost Submission is or have questions about that topic, visit our website for a variety of resources.