Redstone Government Consulting Blog (10)

My commercial company wants to increase business with the Federal Government – but not with all those requirements the Government follows when buying under FAR Part 15 rules (Contracting by Negotiation). Is that even possible? The answer is “absolutely”.

The FACT SHEET issued by the White House on November 8, 2023 professes the four underlying initiatives “will generate more than an additional 10 billion annually in savings and cost avoidance while improving the performance of Federal contracts.” Seeing as it also states, “[l]ast year alone, the Federal Government purchased $700 billion of goods and services,” – this 1.5% saving would be a good start. So, let’s take a look at these initiatives.

Contractors are required to keep their System of Award Management (SAM) registration up to date. FAR 52.204-7(b)(1) requires an offeror to be registered in the System of Award Management (SAM) when submitting an offer/quote, registered until the time of award, during performance, and through final payment. Sounds pretty easy. However, contractors are not always registering or updating their registration, resulting in ineligible awards, as noted in recent court cases (See our blog: SAM Registrations: Check Often and Never Let it Lapse!).

You have done the difficult work of developing a product that meets the technical specifications, quality, and reliability your Government customer requires. As you move from design to manufacturing, Redstone Government Consulting can help you plan and prepare for your Manufacturing Readiness Review (MRR) or Production Readiness Review (PRR). These phase gates may be required by your contract as part of the project bringing your product from design into manufacturing. Manufacturing Readiness Review (MRR) is the phase gate that typically follows the Critical Design Review (CDR), where the design is frozen. It is very common for this to be the point in the project that the manufacturing team becomes involved in preparing to produce the product.

My company only sells to the Government so my products/services can’t be commercial. Truth or Myth. This is a myth. If you are selling products/services under FAR 15 based contracts or subcontracts, submitting certified cost and pricing data and documenting other accounting and purchasing requirements that come along with it, when the products/services technically meet the definition of commercial under the FAR – it may be time to rethink your approach.

The Defense Contract Audit Agency (DCAA) issued a memorandum to its leadership – and ultimately its auditors in the field – addressing a revision to its audit guidance related to the audit of contractor cost impact calculations for unilateral cost accounting practice changes (23-PAC-009(R) Revised Audit Guidance on the Cost Impact Calculation for a Unilateral Cost Accounting Practice Change – dated October 3, 2023). Well, it is about time.

As we approach the end of the year, it is time to shift our focus on closing the fiscal year and preparing the upcoming fiscal year. Closing the fiscal year in Deltek Costpoint involves a series of steps to ensure accurate reporting, compliance, and a smooth transition into the new fiscal period. In this blog, we'll provide a guide on the steps for closing the fiscal year in Deltek Costpoint, focusing on both the General Ledger and Project aspects.

Most contractors that have contracts/subcontracts subject to full CAS coverage will eventually want to make a change to a cost accounting practice because there is a “better” allocation method or a change is required to remain in compliance with CAS.

If this were only a simple question. The most straightforward answer is that it is a good idea for any company to have policies and procedures. If that company is going to do business with the US Government those policies and procedures are going to have to be expanded as each contract may present additional requirements. To help you understand the complex level of requirements we will address the major business systems and other key areas.

Since the Department of Justice (DOJ) started promoting its initiative on Cyber Security reporting there have been several settlements related to cyber security noncompliance, four of which involve defense contractors.