Redstone Government Consulting Blog (46)

Slowly is the word that always describes Government change, and acquisition process change is no exception.  Some of you will remember that the 2017 NDAA required DCAA to reduce the backlog of DoD incurred cost submissions and suspend work for other Departments.  But how many of you remember that it also created an Advisory Panel on Streamlining and Codifying Acquisition Regulations, better known as the Section 809 Panel? 

A recent DoD-IG (Department of Defense-Inspector General Report (DODIG-2019-070) has unfortunately reinforced DCAA’s audit interpretations of the reasonableness of contractor compensation (reference to FAR 31.205-6(b)). The IG (apparently with help from DCAA) reviewed ACO (Contracting Officer) actions to resolve/disposition DCAA (Defense Contract Audit Agency) advisory audit reports which included assertions that contractors had claimed unreasonable compensation (primarily for contractor executives). 

• RFP for 8(a) On Ramp can be found here: https://www.fbo.gov/index?s=opportunity&mode=form&id=31402bd0ff9188c41e8ec213e8375fc1&tab=core&_cview=1
• RFP for Small Business Pools 1, 3 and 4 can be found here: https://www.fbo.gov/index?s=opportunity&mode=form&tab=core&id=9f4b11d2c577b7ae6c5fc4ceae0320de

Key Dates (Subject to Change. Always check FBO/solicitation for latest info):

The budgeting process for any company can be a daunting process.  But, like most things, hard work pays off, and establishing a detailed budget is a critical element to ensure a healthy and profitable company.

Some of us have been tracking the long overdue Congressional mandate for the United States to achieve a ready-state for auditable financial statements.  Although it may come as a surprise, we’ve uncovered a somewhat reliable (thus somewhat unreliable) rumor that the next NDAA (National Defense Authorization Act) will include section 401(A.F.) which will require the Department of Defense (more specifically DCAA/Defense Contract Audit Agency) to provide technical assistance to all other agencies, inspector generals’, GAO (Government Accountability Office) and the hordes of independent private auditors who have thus-far failed in achieving that mystical milestone of fully auditable federal government financial statements.  

It’s everyone’s least favorite time of year.  That’s right, tax season.  For those of us who no longer work in public accounting, this time of year is now a welcome reprieve; although for us, it also marks the start of incurred cost season.  If you’re not sure what an Incurred Cost Submission is or have questions about that topic, visit our website for a variety of resources.

It’s that time of year again! The 2018 EEO-1 survey officially opened on March 18, 2019 and is due on May 31, 2019.

Unless you have undergone a DCAA Accounting System audit under the criteria in DFARS 252.242-7006 (a.k.a. DFARS Accounting System Audit), you do not know what a comprehensive audit is.  To start with there are eighteen criteria, some of which are as broad as “Accounting practices in accordance with standard promulgated by the Cost Accounting Standards Board, if applicable, otherwise, Generally Accepted Accounting Principles.”  This leaves the door open to pretty much endless questions.  But don’t worry, DCAA has narrowed it down to only 27 questions. 

A recent ASBCA decision (No 61583) confirms that Government benevolence does not extend to penalties associated with a contractor’s final indirect cost rate proposal (FICRP) which included expressly unallowable indirect costs. In one case, the issue was unallowable legal costs incurred as a result of the US Department of Justice (DOJ) investigation of the contractor, which was triggered by information suggesting that the contractor claimed indirect salaries for an individual whose services were as the housekeeper for the owners of the company and thus unallowable as costs allowable to Government contracts. 

Did you know that The International Traffic in Arms Regulations affects more than just exporters? You may need to register with the Directorate of Defense Trade Controls even if you do not export.