We have had several clients tell us they have purchase orders under the Truthful Cost or Pricing Data (TINA) threshold for what they believe to be commercial purchases. They run a quick search on the purchase order (PO) and find there are no Federal Acquisition (FAR) or Defense FAR Supplement (DFARS) clauses in the agreement even though the prime contract is to the U.S. Government.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Federal Acquisition Regulation (FAR)
Let’s start with the basics. When is a commercial determination required in the Federal Acquisition Regulations (FAR)? The common belief is that only when the award of a subcontract exceeds the cost or pricing data threshold. This common belief is what we refer to as a too-often believed myth. The truth is that FAR 52.244-6, Subcontracts for Commercial Products and Commercial Services, specifically requires that “to the maximum extent practicable, the Contractor shall incorporate, and require its subcontractors at all tiers to incorporate, commercial products, commercial services, or non-developmental items as components of items to be supplied” to the Government. To comply with this requirement, as many as possible of your purchase orders issued under your U.S. Government contracts and subcontracts should have commercial determination regardless of the dollar value.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
While the cost principle is titled “Rental Costs,” it addresses the cost of renting and leasing real and personal property utilized in the performance of US Government procurement contracts and subcontracts. The way I read the cost principle, FAR 31.205-36(b) provides that rental and leasing costs are allowable with the following limitations:
Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
On November 7, 2024, the Armed Services Board of Contract Appeals (ASBCA) issued a decision that every small business needs to read. ASBCA Case 62458 Left Hand Design Corporation Decision explains exactly how the Federal Acquisition Regulation (FAR) implements the statutorily required penalties through FAR 42.709-6, Waiver of the penalty, and provides a cautionary tale for small businesses or large businesses that are new to government contracting.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
As Kevin so aptly put it in Home Alone 2 – “Another Christmas in the trenches.”
With yet another potential Government shutdown looming, we want to draw your attention to some of our previous articles on this ever-tiring topic. Below are a few articles we’ve published on the government shutdown topic in the past:
Topics: Government Shutdown, Contracts & Subcontracts Administration
The FAR Council issued a proposed rule on November 29, 2024 to amend the FAR to increase acquisition related thresholds for inflation.
Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
Again, this year our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2025 compensation cap amount is $671,000. Below we have provided the compensation caps going back to 2019.
Topics: Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Mastering efficiency, ensuring compliance, and driving growth is a constant challenge for government contractors. Amidst these challenges, enterprise resource planning (ERP) systems like Deltek Costpoint emerge as indispensable tools for streamlining operations, managing finances, and facilitating decision-making. However, the true power of Costpoint lies not just in its software capabilities but in the hands of well-trained users who can leverage its functionalities to their fullest extent. Comprehensive training is a vital step toward maximizing the system’s value and driving organizational success.
Topics: Compliant Accounting Infrastructure, Government Compliance Training, Deltek Costpoint
FAR Part 36 - Construction and Architect-Engineer Contracts provides the direction to contracting officer on the expected processes and requirements around contracting for construction and Architectural and Engineering (A&E) services. Part 36 addresses construction and A&E separately and we have included some of the key areas below.
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Commercial Item Determination, Federal Construction Contracting
Deltek Costpoint’s Billing Module is designed to facilitate the invoicing process while adhering to complex government regulations. Whether you’re billing fixed-price contracts, time and materials (T&M), or cost-plus contracts, mastering its capabilities can significantly enhance efficiency and accuracy in your financial workflows. In this article we delve into some fundamental tips and tricks to help you harness the full power of Deltek Costpoint for billing purposes.
Topics: DCAA Audit Support, Deltek Costpoint