--- title: Proposed Rule to Shorten KTR CPAPs Review-Response Time description: Get the scoop on FAR 52.216-7 and FAR 33.206 and how it affects government contractor response time. image: https://info.redstonegci.com/hs-fs/file-282590778-jpg/images/106457993.jpg --- [ PAY INVOICE](https://redstonegci.com/invoice-payment/) [Call Us Today 256-704-9800](tel:2567049800) [info@redstonegci.com](Mailto:info@redstonegci.com) [![Redstone_Logo](https://info.redstonegci.com/hubfs/redstone%20logo%20version%201%20-%20rgb-1.png)](https://www.redstonegci.com/) # Proposed Rule to Shorten KTR CPAPs Review-Response Time [Posted by Michael Steen on Wed, Aug 28, 2013 @ 16:08 PM](https://info.redstonegci.com/blog/author/michael-steen) - [Tweet](https://twitter.com/share) ![CPAR-review-response-time](https://info.redstonegci.com/hs-fs/file-282590778-jpg/images/106457993.jpg?width=523&name=106457993.jpg) On August 13, 2013, the Federal Register included a proposed rule to reduce the contractor response time (for comments on past performance ratings) from 30 to 14 days. The change is a required reform (i.e. Congressional expectation) to improve contractor past performance databases; per the rule writers, it will “improve communication with contractors, access to performance information within the government and procedures selecting high performing contractors” and “having this data available within 14 days will be to the advantage of most contractors”. Not that it matters, but this strikes us as a meaningless and inconsequential change (to placate Congress) which will do nothing to improve the timeliness of the acquisition process. Moreover, just one more example where contractual due dates are imposed on contractors (who are then held to these due dates) when few if any due dates are contractually imposed on government auditors or contracting officers. Notably when FAR 52.216-7 was revised in May 2011, public comments suggested that with respect to the annual indirect cost rate proposal (contractor due date for submission is six months after the end of the contractor fiscal year) it also include due dates for incurred cost audits to facilitate contract closeout—in their infinite (and biased) wisdom, the rule makers stated that government due dates would be inappropriate because such due dates might impact the quality of the contract audits. Which begs the question, how does one measure audit quality when DCAA completes so few incurred cost audits? Perhaps the real reason why the government rule writers freely impose due dates on contractors but refrain from government due dates, the government does poorly when due dates equally apply to contractors and the government as evidenced by government (DCAA/DCMA) failure to recognize that the FAR 33.206 six year statute of limitations applies equally (reference to case law over the past 18 months wherein the government has lost significant cost recoveries because of the government failure to recognize the applicability of the six year statute of limitations). No one should expect any new regulation imposing mandatory and enforceable due dates on government actions—“mandatory due dates” and “federal government/federal agencies” do not belong in the same sentence.  [![Learn More About Our Incurred Cost Proposal Submission Services](https://no-cache.hubspot.com/cta/default/203971/interactive-168719282754.png) ](https://info.redstonegci.com/hs/cta/wi/redirect?encryptedPayload=AVxigLJW4%2BPH22lOBYH3ruiPhbH5fLgFhh67Igq0xHOTWvdvf51NdyZzckgEv%2Fevb9WkJ9V79XQprYDH4d1Sg5Sd56Xm7br809prR1V21ySQ3jUXrcV36SN7WOrmu1V%2BIetur79IbbaujLVlfpdSPEo6U%2F2XwvCXQa0rYUZ%2BvySoAX8GT9SdiwtD2RKeBrnxI0q%2FMze4ROMGpcxFW2kQz9iYn0q%2FprXFtgaDqerVTvRk%2BIRMrqO4RQ%3D%3D&webInteractiveContentId=168719282754&portalId=203971) ### Written by [Michael Steen](https://info.redstonegci.com/blog/author/michael-steen) ![Michael Steen](https://info.redstonegci.com/hubfs/images/Staff_/Michael-Steen-Redstone-Government-Consulting.png) Mike Steen is a Emeritus Advisor with Redstone Government Consulting, Inc. and a specialist in complex compliance issues to include major contractor cost accounting & business system regulations, financial compliance, resolution of DCAA audit issues, Cost Accounting Standards application, litigation support, and claims preparation. Prior to joining Redstone Government Consulting, Mike served in a number of capacities with DCAA for over thirty years, and upon his retirement, he was one of the top seven senior executives with DCAA. Mike Served as a Regional Director for two DCAA regions, and during that time was responsible for audits of approximately $25B and 800 employees. In October 2001, he was selected for the Senior Executive Service and in 2006 he received the Presidential Rank Award. During Mike’s tenure with DCAA, he was involved in conducting or managing a variety of compliance audits, to include cost proposals, billing systems, Cost Accounting Standards, claims, defective pricing, and then-evolving programs such as restructuring, financial capability and agreed-upon procedures. He directly supported the government litigation team on significant contract disputes and has prepared and presented various lectures and seminars to DCAA staff and business community leaders. Since joining Redstone Government Consulting in June 2007, Mike has developed and presented training and seminars on Government Contracts Compliance to NCMA, Federal Publications Seminars and various clients. Mike also is a prolific contributor of written articles to government contracting publications, as well as to our own Government Insights Newsletter. Mike also serves as the director of our training service offerings, with responsibilities for preparing and developing course content as well as instructing our seminars to clients and general audiences throughout the U.S. Mike also serves as a faculty instructor for the Federal Publications Seminars organization. Education Mike has a BS Degree in Business Administration from Wichita State University. He is also a graduate of the DCAA Director’s Fellowship Program in Management, and has a Masters Degree in Administration from Central Michigan University. Mr. Steen also completed a number of OPM’s management and executive development courses. ## About Redstone GCI Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals. Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs. One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle. 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