Redstone Government Consulting Blog | Redstone Team (10)

All too often, contractors have a dilemma as to which changing dollar threshold should be inserted into company policy.  You may recall that there has been considerable debate around changing dollar thresholds around TINA, CAS, and even the executive comp ceiling from a few years back.  There is now a proposed rule before the FAR Council is seeking to eliminate this confusion.  This rule will also reduce the administrative workload in processing changing dollar thresholds throughout the FAR.  

The Federal Acquisition Regulation (FAR) implemented Section 822 of the Fiscal Year 2017 National Defense Authorization Act (NDAA) which requires contactors to submit additional certified cost or pricing data when only one offer is received in response to a competitive solicitation.  Certified cost and pricing data is required when the following three criteria are met:

GSA establishes the per diem rates for the lower 48 Continental United States (CONUS), which are the maximum allowances that federal employees are reimbursed for expenses incurred while on official travel.

It is with a heavy heart and eyes filled with tears that we write this message.  Scott Butler, our beloved friend, mentor, and the founder of Redstone Government Consulting has passed away after a strong, faithful and diligent battle with cancer.  If you knew Scott, you instantly loved and admired Scott.  He was a friend to everyone he met, and he deeply and truly cared for those around him.  Scott had an incredible faith and love of Jesus Christ and it showed in every interaction he had, whether good or bad.  Our lives will be forever changed, because we had the fortune to work with Scott daily.  In a picture hanging in Scott’s office was a quote, 

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.