OMB Directs Agencies to Buy Commercial or Justify Non-Commercial Acquisitions

OMB’s new guidance directs agencies to expand commercial acquisitions and justify non-commercial awards. Government contractors may see closer review of commerciality, pricing, option periods, and cost-reimbursement contracts, making support for market research and contract decisions more important.

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Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting

Here We Go Again, DCAA Reorganization Phase 3

On April 20, 2026, the Defense Contract Audit Agency (DCAA) announced yet another reorganization: a transition to 23 “hub” organizations while maintaining office locations at key defense contractor sites. This reduction reduces the 180 office (branch and suboffices) locations to 23 hubs covering only 19 of the 50 states in the continental U.S.

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Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting

Businesses Can Now Claim IEEPA Tariff Refunds Through the New Portal

The launch of the CAPE (Consolidated Administration and Processing of Entries) system by U.S. Customs and Border Protection marks a significant opportunity for importers to recover duties previously paid under IEEPA tariffs that were later ruled invalid by the U.S. Supreme Court. By enabling consolidated refund claims and streamlining the process through the ACE portal, this program reduces administrative burden and accelerates reimbursement. For importers, especially small businesses that directly paid these tariffs, this development is highly relevant because it provides a time-sensitive pathway to reclaim costs, improve cash flow, and correct past overpayments in a changing tariff environment.

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Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting

DCAA Updates ICE Model Ahead of Incurred Cost Submission Deadlines

DCAA recently released Version 1.04 of the ICE Model that utilizes Microsoft Power Query to prepare incurred cost proposals. For government contractors preparing annual incurred cost submissions with Microsoft Power Query, this update should be used in replacement of the previous version released. Both the April 2026 Power Query version and the May 2019 Visual Basic version remain available, but each version carries different considerations for preparation, review, and submission through the Contractor Submission Portal.

The updated Power Query version is intended to improve compatibility with contract information such as contract ceiling issues on Schedule I. The instructions have been revised to provide better clarification of information required to properly run the power query version. The original Visual Basic version remains available, but contractors using this version need to be aware of a specific restriction in the Contractor Submission Portal. Files prepared in the Visual Basic version must be saved as .xls or .xlsx before uploading to the Contractor Submission Portal. The Contractor Submission Portal will not accept .xlsm macro files.

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Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)

CLIENT ALERT: EO 14398 Executive Order Addresses DEI Discrimination by Federal Contractors

On March 26, 2026, President Donald J. Trump signed an executive order (EO) titled, "Addressing DEI Discrimination by Federal Contractors." The order establishes new mandatory contract clause requirements for federal contractors and subcontractors at all tiers, creates reporting and monitoring obligations, and designates noncompliance as material under the False Claims Act (FCA). Federal agencies are required to incorporate the new clause into contracts and contract-like instruments by April 25, 2026. The EO applies to federal contracts, subcontracts, and contract-like instruments subject to the Federal Property and Administrative Services Act (40 U.S.C. § 101 et seq.).

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Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting

Why QuickBooks Chart of Accounts Decisions Matter More Than Government Contractors Realize

The chart of accounts is one of the earliest decisions made when setting up an accounting system, and for government contractors, it is one of the most consequential. What looks like a basic bookkeeping choice at implementation often shapes reporting quality, cost visibility, and compliance capacity long after the business has grown.

Most QuickBooks setups look perfectly functional at first glance. Transactions flow in, reports are generated, and the books balance. For a small commercial business, that may be all that is needed. But government contractors often find out the hard way that a system that appears to be working is not actually built for the work they do.

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Topics: Accounting System Compliance, Small Business Compliance, Quickbooks

Why Ongoing Support Matters after Unanet Implementation

Unanet implementation does not end at go live. The transition into live processing often reveals workflow issues, training gaps, and process risks that can affect billing, reporting, and overall system adoption. Ongoing support during this period helps organizations stabilize operations, reduce rework, and strengthen long term system results.

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Topics: Accounting System Compliance, Small Business Compliance, Unanet, Organizational Change Management Consulting

ASBCA Scrutinizes Honeywell’s Interpretation of ‘Total’ in Total Cost Input

In June 2023, the Armed Services Board of Contract Appeals (ASBCA) denied Honeywell's motion to dismiss a $151 million claim alleging improper G&A allocation treatment under CAS 410. The Board affirmed that interdivisional cost transfers must be included in a total cost input base, contradicting Honeywell's position. Government contractors should review whether their G&A allocation bases are consistent with this ruling.

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Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

An Update on the Cost Accounting Standards (CAS) Board’s Shift Toward GAAP

The Cost Accounting Standards (CAS) Board has been working to eliminate several cost accounting standards and replace them with reliance on GAAP. As of April 2026, five standards are under proposed elimination, including a new March 2026 NPRM for CAS 407. Contractors should be aware that removing these standards does not eliminate cost accounting or consistency obligations.

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Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

How the March 2026 CAS Threshold and Related Changes Affect Government Contractors

On March 20, 2026, the CAS Board issued a Notice of Proposed Rulemaking proposing significant increases to the CAS thresholds and changes to exemption determinations for indefinite-delivery contracts. Most changes reflect requirements in Section 1806 of the 2026 NDAA and are broadly favorable to contractors, though key concerns remain about the treatment of single-award indefinite-delivery contracts.

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Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)