Tim Di Guiseppe

Recent Posts

When is Simple Negligence “Gross Negligence” And Why Should This Concern Your Company?

In a recent Federal Circuit ruling, KBR found out that “simple negligence” in its calculations of a reasonable price range for subcontractor’s price proposal resulted in a “Gross Negligence ruling” by the courts. Kellogg Brown & Root Services, Inc. (KBR) v. U.S., No. 203-5030, slip op. (Fed. Cir. Feb, 3, 2014).

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Topics: Compliant Accounting Infrastructure, Cost and Pricing and Budgeting, Incurred Cost Proposal Submission (ICP/ICE)

What Foreign Contractors Need to Know When Contracting with the U.S. Government

Non-U.S. contractors have many misconceptions as to what rules and regulations they must comply with under U.S. Government contracts. The two most common misunderstandings non-U.S. entities have are (1) their country laws trump U.S. laws and regulations, and (2) Federal Acquisition Regulations (FAR) rules on cost collection and allocations are less strenuous for non-U.S. contractors. These two misconceptions could not be further from the truth.

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Topics: Non-US Government Contractor, Compliant Accounting Infrastructure, Contracts Administration, DFARS Business Systems

DCMA Letter to NDIA: Key Points for Contractors

On September 5th, DCMA issued a letter to the National Defense Industrial Association (NDIA) addressing industry concerns raised at a meeting with DCMA on April 25, 2013.  We will highlight some key points in the letter that will help contractors deal with DCAA’s assertions which often times are not supported by regulations. The letter reinforces that it is DCMA that determines if a contractor’s business system is compliant or not and if a Corrective Action Request (CARs) is necessary.

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Topics: Contracts Administration, Defense Contractors, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR)

Highlights from the NDIA September Procurement Meeting in Washington, DC

The National Defense Industrial Association’s (NDIA) September Procurement Division Committee meeting provided insights and information that we believe is of  interest to our readers.  These comments are our own interpretations and opinions based upon our presence at the meeting.

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Topics: Compliant Accounting Infrastructure, Sequestration, Cost and Pricing and Budgeting, Contracts Administration, Defense Contractors

DCAA Audit: Knowledge, Planning and Preparation are the Keys

Dealing with DCAA audits can be tricky at best - especially in today’s environment, if you do not take the necessary steps to ensure that you understand, manage and respond appropriately to audits. In this brief article, we will look at what steps can be taken by contractors prior to, during and after a DCAA audit.
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Topics: Contracts Administration, Government Compliance Training, DCAA Audit Support