Redstone Government Consulting Blog | Redstone Team (13)

We have recently had to deal with issues related to DCAA applying DFARS business system rules in DFARS 252.242-7006 Accounting System Administration in its evaluation of small business client accounting systems. The DFARS business system rules were never intended to be applied to small businesses. Further, the limited resources of a small business make it very difficult for a small business to fully comply with all 18 of the specific criteria contained in the business system rules. DFARS 252.242-7005 regarding the applicability of the business system rules states:

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

A New Procedure: Directive 2018-05

On August 24, 2018, the Office of Federal Contract Compliance Programs (OFCCP) issued a standard procedure for OFCCP staff to follow when conducting an analysis of contractor compensation practices during a compliance evaluation.   This information is also intended to assist government contractors in performing annual internal reviews and proactively addressing any potential pay discrimination. Directive 2018-05 - Analysis of Contractor Compensation Practices During a Compliance Evaluation replaces Directive 2013-03 Procedures for Reviewing Contractor Compensation Systems and Practices which was issued in February 2013.

On August 14, 2018 the U.S. General Services Administration (GSA) released the Fiscal Year 2019 travel per diem rates, taking effect October 1, 2018. These represent the maximum reimbursable amounts allowed for expenses incurred by federal employees. Making adjustments based on the current economy is important, as well as taking into consideration local price variations  in what is termed “Non-Standard Areas.”

Organizational Conflicts of Interest (OCI) play a key role in a government contractor’s ability to compete for work.  In accordance with Federal Acquisition Regulation 9.504, contracting officers are responsible for evaluating OCI as early in the acquisition process as possible in an effort to avoid or mitigate conflicts that may otherwise be present in the acquisition. 

Ever wonder how to get your questions answered at a post-award debriefing?  It can be frustrating to get the information you really want to know from the Government.  When I worked as an acquisition attorney with the Government, I spent many hours with my evaluation teams preparing for post-award debriefings.  I always set time aside to go through a mock debriefing and discuss what information to disclose and what type of questions to table. 

As we noted in our last blog, DCMA has issued another updated CPSR Guidebook, dated May 29, 2018.  DCMA issued two updates in 2017 and have already issued 2 updates in 2018.  This leads us to question: Will there be more? And our intuition leads us to answer: More than likely! 

A new DCMA CPSR Guidebook has been released effective May 29, 2018 and can be found here:  http://www.dcma.mil/Portals/31/Documents/CPSR/CPSR_Guidebook_052918.pdf The Redstone team will be conducting a more comprehensive review of the guidebook, but we want to share our initial thoughts with readers.

The incurred cost submission is required for all federal contractors holding cost-type or time and materials (T&M) contracts and is a universal requirement regardless of agency customer. All contracts requiring the incurred cost submission will include the Federal Acquisition Regulations "Allowable Cost & Payment Clause" (FAR 52.216-7) and/or the "T&M Payment Clause" (FAR 52.232-7). Following are answers to frequently asked questions and pointers to resources to help you.

FOR IMMEDIATE RELEASE

We’ve previously released a few blogs on the topic to make our clients and friends aware of the emerging requirement for registration at SAM.gov.  While the Government has not been entirely forthcoming on why this requirement has emerged, there has been a lot of speculation from a data breach to fictitious registrations stemming from a few unscrupulous “consultants” that charge to register entities in SAM.  

With summer just around the corner, now is the perfect time for your company to advertise internship opportunities. Internships are often a “win-win” opportunity, providing valuable education and training for students while improving workflow for employers.