OMB Extends Deadline for Software Supply Chain Security to Submit Attestation Forms

On June 9, 2023, the Office of Management and Budget (OMB) issued M-23-16, Update to Memorandum M-22-18, providing an extension to the deadline for software developers to submit attestation forms to Federal agencies.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity

Cost Accounting Standard (CAS) 406 – Cost Accounting Period

Comparison to FAR

Like CAS 401, CAS 402, and CAS 405, CAS 406 is part of modified CAS coverage and is one of the first CAS standards a company encounters. It likely will not call for any changes to the company’s cost accounting system if you are compliant with FAR 31.203(g)(2) (Indirect costs). FAR states that for contracts not subject to CAS:

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

Recent ASBCA and Court of Appeals Decisions Impacting Undefinitized Contract Actions


April 25, 2023; the Court of Appeals agreed with the Armed Services Board of Contract Appeals (ASBCA) that a contractor cannot take a unilaterally established Undefinitized Contract Action (UCA) to the Board without first submitting a certified claim request for a final decision by the contracting officer.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Managing Multiple Companies in the Same Unanet System


There are many circumstances where a Unanet customer might manage multiple legal entities in the same Unanet system. There are many benefits as well:

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Topics: Compliant Accounting Infrastructure, Unanet

Best Practices Using QuickBooks Time for Government Contractors


The DCAA imposes strict requirements on government contractors when it comes to timekeeping. Make sure to utilize some of the key features in QuickBooks Time to help your business remain DCAA compliant.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Quickbooks

What to Do and Not to Do When DCAA Cites Findings Against Your Company


So, the Defense Contract Agency Audit (DCAA) auditor comes into your office, performs an audit, and…they have findings. What do you do? Wait…is there something that I should not do?

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Labor Qualifications under Time and Material Contracts

All Time and Material (T&M) contracts with the Federal Government, even commercial ones under Federal Acquisition Regulations (FAR) part 12, have one big thing in common. That big thing is that all of the labor hours delivered must be performed by individuals meeting the labor qualifications specified in the contract. The Federal Government uses very strong language in its contract requirement related to this, stating the hours “will not be paid to the extent the work is performed by individuals that do not meet the qualifications.”

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Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

DCAA Audit Programs Impacting Small Business


Starting back in 2021, DCAA issued updates to its audit programs supporting the audit of incurred cost. Here are a few interesting things we noted in the updates.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Risks and Consequences to Billing and Revenue Changes in Deltek Costpoint

While it may be tempting to change the Project Account Group (PAG) in Deltek Costpoint, revenue and billing formulas, revenue and billing formula levels, or a combination of both, you must consider the risks and consequences accompanying this decision.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Deltek Costpoint

Department of Defense Has a Problem with Audits (Their Own)

The Department of Defense has failed an audit - five in a row, to be exact. Federal law mandates audits for all federal agencies, and until 2017, the Department of Defense was never able to satisfy this requirement. It is a very tall task – auditing an agency that controls over half of the discretionary spending in the United States. But in 2017, DoD underwent a financial audit for the first time. They did not pass, but that was never expected. There have also been audits each year since, and while the Agency has not yet passed an audit, it has improved each time.

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Topics: DFARS Business Systems, Government Property Management