Redstone Government Consulting Blog (57)

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.

We’re almost through October and 2019 will be here before we know it. This is a great time to review your company’s year-end and new year checklists for compliance. Want to be sure those frightful DOL ghosts and OFCCP goblins don’t come after you? Keep these checklist items in mind:

If your unbilled receivables account has you searching for a solution as simple as waving a Harry Potter wand and reciting “Evanesco!” you are not alone. The everyday life of an accountant is chock-full of number-crunching, and then you suddenly realize the “deathly hollows” of year-end is quickly approaching. Whether you are new to the tracking of unbilled receivables or the account has been covered in cobwebs, understanding the creation process to this “chamber of secrets” is where your journey out of the “dark forest” can begin.

We have recently had to deal with issues related to DCAA applying DFARS business system rules in DFARS 252.242-7006 Accounting System Administration in its evaluation of small business client accounting systems. The DFARS business system rules were never intended to be applied to small businesses. Further, the limited resources of a small business make it very difficult for a small business to fully comply with all 18 of the specific criteria contained in the business system rules. DFARS 252.242-7005 regarding the applicability of the business system rules states:

Government furnished property can be a headache, even for the most seasoned contractor. It can include thousands of tiny parts, multi-million-dollar pieces of equipment or both – often all on one contract in an old dark government building. We have identified some common, and not-so-common, areas we see missing in contractor government property management plans.

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.

A New Procedure: Directive 2018-05

On August 24, 2018, the Office of Federal Contract Compliance Programs (OFCCP) issued a standard procedure for OFCCP staff to follow when conducting an analysis of contractor compensation practices during a compliance evaluation.   This information is also intended to assist government contractors in performing annual internal reviews and proactively addressing any potential pay discrimination. Directive 2018-05 - Analysis of Contractor Compensation Practices During a Compliance Evaluation replaces Directive 2013-03 Procedures for Reviewing Contractor Compensation Systems and Practices which was issued in February 2013.

On August 14, 2018 the U.S. General Services Administration (GSA) released the Fiscal Year 2019 travel per diem rates, taking effect October 1, 2018. These represent the maximum reimbursable amounts allowed for expenses incurred by federal employees. Making adjustments based on the current economy is important, as well as taking into consideration local price variations  in what is termed “Non-Standard Areas.”

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.

It’s that time again!  This is a reminder of the Federal contractor obligations for record-keeping and reporting under the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA). 

Organizational Conflicts of Interest (OCI) play a key role in a government contractor’s ability to compete for work.  In accordance with Federal Acquisition Regulation 9.504, contracting officers are responsible for evaluating OCI as early in the acquisition process as possible in an effort to avoid or mitigate conflicts that may otherwise be present in the acquisition. 

Ever wonder how to get your questions answered at a post-award debriefing?  It can be frustrating to get the information you really want to know from the Government.  When I worked as an acquisition attorney with the Government, I spent many hours with my evaluation teams preparing for post-award debriefings.  I always set time aside to go through a mock debriefing and discuss what information to disclose and what type of questions to table. 

As we noted in our last blog, DCMA has issued another updated CPSR Guidebook, dated May 29, 2018.  DCMA issued two updates in 2017 and have already issued 2 updates in 2018.  This leads us to question: Will there be more? And our intuition leads us to answer: More than likely!