Redstone Government Consulting Blog (37)

DCMA updated the Contractor Purchasing System Review (CPSR) Handbook on September 10, 2021.

Recently, our office has become aware of a few instances of auditors misunderstanding the DCAA Headquarters’ guidance pertaining to the treatment of credits associated with PPP Loan Forgiveness.

In our last newsletter, we focused on some of the unnecessary obstacles small businesses face in the regulatory environment and areas where, in our opinion, Government auditors, particularly DCAA, misinterpret regulatory guidance in their efforts to question costs.

This is the second of a two-part blog series where we tackle small business joint ventures and the SBA Mentor-Protégé Program. In this blog, we will discuss small business joint ventures and how a government contractor can get involved in one.

Every month our team’s charity committee comes up with clever ideas centered around a truly important part of our organization: giving back to the community. In this month’s installment, they took it to the next level with the so called, "One Chip Challenge."

Overview

• The Office of Management and Budget (OMB) has approved the OFCCP Affirmative Action Plan (AAP) Verification Program.
• The EEOC will soon require contractors to use new EEO tabulation data from 2014-2018 in their AAPs.
• The OFCCP is rescinding its previously issued notice stating that it would not request, accept, or use EEO-1 Component 2 data. 
• The Department of Homeland Security has extended the Form I-9 verification flexibility.
• As part of President Biden’s COVID-19 Plan, an Executive Order (#14043) on COVID Safety Protocols for Federal Workers and Contractors was signed on September 9, 2021. 
• As a reminder, September 30^th is the deadline to file the VETS-4212 report.
• You are invited to join a national online dialogue on “Advancing Worker Equity at the U.S. Department of Labor.”

This is the first of a two-part blog series where we will tackle small business joint ventures and the SBA Mentor-Protégé Program. In this blog, we will discuss the SBA Mentor-Protégé Program.

As we approach the third quarter of the year, now is a good time to review your payroll setup and wages for accuracy. I often find that whether the client is a seasoned payroll processor, or new to Costpoint and payroll in general, there can be errors in wages that are not obvious in day-to-day processing. There are numerous actions you can take to prepare for a smooth year end. For example, start by ordering forms early in the last quarter of the year. Many sources for W2s, 1099s, ACA forms, etc. will sell out in January. Also, be sure to register for access to the Social Security Administration for W2 upload since this process can be time consuming waiting on the access codes to be snail mailed.

DoD Inspector General Audit on Whistleblower

We issued a blog in May 2021 addressing the Department of Justice, Inspector General. The IG found that DOJ contracts did not comply with the whistleblower requirements to include whistleblower clauses in the contract, disseminate the rights and protections in writing to employees, and include required information in confidentiality agreements/statements to employees. We indicated we would not be surprised to see the DoD IG pick up on this area and review DoD Contractors.

In 2020 Congress directed through the National Defense Authorization Act (NDAA) that contracting officers be prohibited from determining that the price of a contract or subcontract is fair and reasonable based solely on historical prices paid by the Government. Congress goes on to provide that if the contractor fails to provide data supporting the proposed price, the contractor is ineligible for award, unless the head of the contracting activity (HCA) determines that it is in the best interest of the Government to make the award. Let’s face it they are saying contracting officer should be asking for “cost data.”