Redstone Government Consulting Blog (26)

Organizations that have federal awards, whether that be grants, cooperative agreements or contracts, must comply with specific cost accounting regulations. Unfortunately, depending on the type of federal award, the regulations may not be the same. Both, both Grants or Cooperative Agreements awarded under 2 Code of Federal Regulations (CFR) 200 and Contracts awarded under 48 CFR Federal Acquisition Regulations (FAR) provide requirements for cost allowability, allocability, and reasonableness as well as the required cost accounting treatment for all cost:

Oftentimes when supporting the production of cost volumes and pricing exercises for clients, we’re given a basis of estimate (BOE) that has been written by someone on the technical team. Even being a group of accounting and compliance professionals who know little in areas such as cyber, engineering, or other technical areas of the scope of work, we’re left scratching our heads. This usually leads to several back-and-forth discussions centered around gleaning enough information from the technical team to pass the proverbial government “sniff test”.

The Office of Management and Budget (OMB) issued a proposed rule to add a new Part 184 in 2 CFR Chapter I and revisions to 2 CFR 200.322 Domestic preferences for procurements on Build America/Buy America Act for Grants and Agreements. The revision will address the Buy American Preference for awards with infrastructure expenditures. Comments to the proposed rule are due March 13, 2023.

What is the Incurred Cost Submission? What is Schedule O? What are the Supplemental A Schedules? This VLOG will briefly explain the Incurred Cost Submission, how to complete Schedules O and the Supplemental A Schedules, and the importance of those schedules.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

The Office of Federal Contractor Compliance Programs (OFCCP) issued the FY 2023 Corporate Scheduling Announcement List, commonly referred to as a CSAL on January 20, 2023. This list includes 500 supply & service contractors selected for an Establishment Review, Corporate Management Compliance Evaluation (CMCE), or Functional Affirmative Action Program (FAAP) review. These reviews help determine whether a covered contractor maintains records consistent with their obligations under OFCCP’s laws, has correctly certified in the GSA’s System for Award Management database and has established Affirmative Action Programs (AAP) at each establishment.

DoD issued a DFARS Final Rule on Treatment of Incurred Independent Research and Development Costs (DFARS Case 2017-D019). The rule is effective January 31, 2023.

On January 5, 2023, the Federal Trade Commission (FTC) voted 3-1 on proposed regulations that, if upheld, would ban employers from imposing non-competition agreements on their employees. Relying on Section 5 of the FTC Act, the FTC concluded that “non-compete clauses reduce competition in labor markets, suppressing earnings and opportunity even for workers who are not directly subject to a non-compete.” Commissioner Wilson dissented, stating that the FTC lacks the authority to engage in rulemaking, particularly with consequences of this significance. 

As inflation continues to rise, you are likely wondering what the General Services Administration (GSA) guidance to contractors will impact you. The issue of inflation has many companies looking for answers, and although GSA has taken steps to address inflation, there is still a lot to be discussed. In this article, we will look at what types of relief and guidance GSA is providing.

We understand this revelation (so to speak) is likely too late for many contractors that have already established final indirect rates for the year of PPP forgiveness; however, any direct costs adjusted for loan forgiveness still remain open until closeout of the contract.

So, you have Federal Acquisition Regulation (FAR) based government contracts. Submitting a proposal for a grant should be similar, after all government regulations are government regulations – Right? Not really.