Redstone Government Consulting Blog (50)

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.

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.

On February 22^nd, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced that it will now post its Corporate Scheduling Announcement List (CSAL) in its Freedom of Information Act (FOIA) library instead of sending advanced notifications to individual establishments. The next CSAL is expected to be released in early to mid-March.

With its January 25^th decision in SuperShuttle DFW Inc., the National Labor Relations Board (NLRB) altered its stance on the independent contractor standard. In a 3-1 vote, the NLRB amended its previous decision in FedEx Home Delivery (2014), asserting that a worker’s classification under the National Labor Relations Act (NLRA) should depend largely on the traditional common-law standard rather than economic factors.

Unanet offers a streamlined platform which works for many small contractors and offers a host of benefits you should consider, including smooth integration and a single platform for most of your financial processes. For all of our current Unanet users and potential Unanet users; the Unanet Practice Group would like to give you a quick view of additional products available within Unanet:

You now understand a little bit more about provisional billing rates from our first of this two-part series. In this second part of our coverage of provisional billing rates, we delve a little deeper into the purpose behind provisional billing rates as well as how to prepare them and the differences between provisional billing rates and proposal bid rates. Knowing these details will enable you to prepare an accurate DCAA submission.

For our 12/31 year-end contractors, this is a busy time of year.  Year-end books are ending and 2019 budgets are being formed.  This is also the time of year for submitting provisional billing rates or PBRs for contractors that have cost reimbursable type contracts such as cost-type and time and material contracts. 

Looking forward to closing 2018? It can be a daunting task, even when you have a trained team and an armload of checklists. To ensure you are fully prepared to tackle each of the processes you encounter at the end of the year and to start the new year right, we at Redstone GCI wanted to provide a check-list and some links to the Unanet Knowledge Center to help you through the Year-End Process:

The competition for that big contract you have been dying to win is underway.  This is a great business opportunity for you.  So, you begin the process of putting together the perfect proposal.  As you go through that process, there are several pitfalls that could prevent you from having the best proposal.  As a government attorney, I saw many of those pitfalls in every source selection I worked.  So as one gift as you enter this new year, I want to go over some of the main pitfalls I have seen from the government’s perspective.