Redstone Government Consulting Blog (56)

Congressman Mac Thornberry recently introduced the “Defense Acquisition Streamlining and Transparency Act” to improve the acquisition system and workforce, and improve transparency in the acquisition system. Click here to download the 80-page bill.

As a business owner or executive, it is highly likely that you are not preparing and submitting your business tax return. After all, tax rules are complicated and submission requirements can be a little unnerving. So, for those reasons and for peace of mind knowing that your tax return is prepared correctly, a savvy business owner or executive will outsource their tax preparation to a trusted firm that specializes in taxes.

It has been years since the contract period of performance has ended, DCAA has finally concluded their audit or review of your incurred cost proposal, and you have received the final indirect rate letter from DCAA. Now what? By design, the contract closeout process begins in earnest.   Typically, the Administrative Contracting Officer (ACO) is responsible for initiating administrative closeout of the contract after receiving evidence of its physical completion.

Is your purchasing system ready for a DCMA Contractor Purchasing System Review?  Time to dust off those policies and procedures, and make sure your employees are trained on FAR and DFARS requirements.

DCMA has been hard at work reviewing contractor purchasing systems, making several updates in 2016 to the CPSR Guidebook, the most recent being January 18, 2016.  In addition, in October 2016, the Director of DCMA issued a Class Deviation from FAR 44.302(a), increasing the CPSR threshold from $25 million to $50 million.  Questions remain on how this will impact contractors whose contracts include FAR 44.3 and who are on DCMA’s review schedule.  The threshold can be lowered if the ACO determines a contractor’s risk level warrants a review.  We have already seen the lower threshold enforced in the early part of 2017 for a couple of our clients.

What is a Program Control analyst and do I need one? These questions are often asked by small business who might not understand the role of a Program Controller. Program (or Project) Controllers are most frequently financial managers who oversee project revenues and expenditures to ensure programs are on schedule and within budget. Program Control Analysts bridge the gap between the program manager and the accounting department and support the needs of both organizations. Program Managers typically manage the technical aspects of a program, while the accounting department manages payroll, accounts payable, accounts receivable, and compliance with generally accepted accounting principles. Program Control Analysts provide a link between the technical elements of program management and the compliance elements of cost accounting. Program control personnel generally have a business background in accounting, finance, business administration or economics which allows them to assist the program manager with decisions which are compliant with business policy and are in accordance with contract terms.

For most small businesses - and especially for those in the early stages of their life cycle - Quickbooks is an excellent option and an almost fundamental starting point when considering an accounting software from which to grow your company. It is cost effective, easy to use, and given its popularity and presence in the market, training resources are readily available. But is it a viable option for Government Contractors?

Accounting for independent research and development costs and bid and proposal costs are found in Far 31.205-18 and Cost Accounting Standards 420. Because FAR 31.205-18 incorporates CAS 420, it does not matter if your company has revenue of $50 million or under $5 million; if you have IR&D and B&P costs, this Cost Accounting Standard (CAS) provides the criteria for accumulation and allocation of those costs.

We often hear the following statement and question: “My proposal (the government solicitation) calls for a compliant accounting system (SF 1408) and I’ve never been audited.  What do I do?”.

Virtually all government contractors and anyone else hoping for regulatory relief from the new administration is aware of the Executive Order (EO) requiring a 2 for 1 reduction in agency regulations for each new regulation. In an effort to show that DCAA is politically savvy and much more positive and proactive than most agencies (who are less than enthusiastic about this EO), DCAA has begun to vet some “similar to” audit strategies. The following are some of the highlights of a DCAA Press Conference to announce a broad range of “2 for 1 reductions”.

With a Presidential Memorandum halting all proposed federal regulations that have not yet taken effect and pausing the Department of Labor’s (DOL) appeal of the nationwide injunction on the overtime rule which would double the minimum salary for exempt status, we are curious how the new administration will impact employer responsibilities, particularly those of federal contractors. While we certainly hope for some respite, we won’t speculate on what might happen, and we continue to encourage employers to be diligent in compliance with those regulations which have recently taken effect as well as those that employers have been slow to tackle.