Redstone Government Consulting Blog (24)

In the Lockheed Martin ASCBA Case 62209 Lockheed Martin Aeronautics Company April 13, 2022 Decision, the Board found that when there is a Congressionally established statute of limitation the “theory of laches” does not apply.

It’s Government year-end, meaning government contractors are working overtime to process contract awards and modifications. Taking the necessary steps to set up Unanet correctly will save your business time later and ensure the program managers can track their projects properly.

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As a small business you know all too well the challenges of managing your back-office accounting activities with limited resources. The headache that comes with reconciling data from an entry-level third-party accounting tool and trying to maintain governmental compliance standards, while being prepared for a contract audit at any time, can be overwhelming for a small finance team.

DoD issued a final rule on April 26, 2022, amending the FAR to support the Small Business Administration regulation of including overseas contracts in agency small business contracting goals. The final rule is effective May 26, 2022.

In the ASCBA Case 61691 Doubleshot, Inc. July 19, 2022 Decision, the Board supported what we believe is the correct reading of the records retention requirement under the FAR related to Cost-Reimbursable contracts. FAR 52.215-2, Audit and Records, requires contractors to make available until 3 years after final payment or any shorter period specified in Subpart 4.7.[1] FAR 4.705-2(b) limits the required retention period to 2 years from the end of fiscal year for pay related records (e.g., timesheet or cards).[2] So provided you submit your Incurred Cost Submission (required by FAR 52.216-7, Allowable Cost and Payment Clause) on time, you only need to maintain any of the records listed in FAR Subpart 4.7 for the time period set forth in that section of the FAR.

Intuit is constantly developing and improving QuickBooks, particularly the online version. And while it’s still not nearly as robust as some of the more complex accounting software solutions that are geared specifically toward government contractors (nor should we expect it to be with the price point difference), it will still get the job done, particularly for small to mid-size contractors that don’t have a bunch of overly complex contracts.

Did You Know that Over 60,000 Charges of Workplace Discrimination Were Filed in the Fiscal Year 2021?

When an employer receives an EEOC Charge of Discrimination, they need to take it very seriously and thoughtfully consider how to prepare a response, which is referred to as a Position Statement. Businesses of all sizes need to understand the ramifications of an EEOC Charge, and to establish policies and procedures to respond to charges and to reduce the likelihood of being charged with discrimination, harassment or retaliation. There are a variety of laws enforced by the EEOC, including:

Schedule I is the most important part of the Incurred Cost Submission and is the single area of great interest for the Government and its auditors. This VLOG will briefly explain the Incurred Cost Submission, the importance of Schedule I, and how to resolve potential issues.

DoD issued a final rule under DFARS Case 2020-D033, effective April 28, 2022, that allows Contracting Officers to rely on a contract issued under FAR Part 12 procedures to serve as a prior commercial item determination on future buys. It only makes sense, that Contracting Officers rely on prior FAR 12 contracts instead of recreating the wheel each time a contractor submits a commercial product/service and making the contractor continually support a product/service already determined commercial.

CMMC was put on hold until recently – but is rolling forward again at a high speed. DOD held a CMMC Day Conference in May 2022 stating its goal of submitting a proposed rule in July 2022 ( no proposed rule to date) and issuing two interim final rules by March 2023. If DoD is able to stay on track (which does not appear to be the case) and issue the final interim rule by March 2023, contractors could start seeing CMMC requirements in solicitations soon after.