In reference to the now outdated terminology “Multiple Personality Disorders” (now “DID” or Dissociative Identity Disorder), my focus is on two Government actions, the 2026 NDAA (National Defense Authorization Act) and the very recent EO (Executive Order), “Prioritizing the Warfighter in Defense Contracting.” Before getting into the substance of this blog, just to note that one can only hope that the proposed/legislated changes to improve the efficiencies and effectiveness of the procurement process (for the Department of War and more broadly the US Government) will actually succeed and not be just one more set of idealized and unfulfilled political promises.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
On November 24, 2025, President Trump signed EO 14363, Launching the Genesis Mission to accelerate America’s race for global dominance in the application of AI to scientific discovery and scientific challenges.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)
On December 5, 2025, the Department of Justice (DOJ) reported another settlement under the False Claims Act (FCA) related to cybersecurity. Swiss Automation agreed to pay $421,234 to the Government as a result of failing to provide adequate cybersecurity controls for drawings of parts supplied to Department of Defense (DoD) prime contractors. The qui tam suit under the False Claims Act (FCA) was brought forward by a whistleblower, not an Information Technology (IT) employee, but a Quality Control Manager of the company. The whistleblower received $65,291.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Item Determination
On November 26, 2025, the Office of Management and Budget (OMB) issued the 2025 Compliance Supplement. The Supplement outlines the compliance requirements to assist auditors in understanding the Federal program’s objectives, procedures and requirements when performing a Single audit for fiscal years beginning after June 30, 2024. The Compliance Supplement is normally issued in the spring of each year; however, OMB delayed its issuance to incorporate significant updates to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, in October 2024. In order to assist auditors with the different requirements, Part 3 Compliance Requirements of the Supplement was divided into two Parts for audit testing as follows:
- Part 3.1 for awards subject to 2 CFR 200 prior to October 2024 and
- Part 3.2 for awards after October 1, 2024
Topics: Accounting System Compliance, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
The Department of Defense (DoD) issued a final rule on September 10, 2025, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate the requirements of the Cybersecurity Maturity Model Certification (CMMC) for FAR-based contracts and subcontracts, effective November 10, 2025.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Grants & Cooperative Agreements (2 CFR 200)
Department of Defense (DoD) issued a final rule on September 10, 2025, amending Defense Federal Acquisition Regulation Supplement (DFARS), incorporating contractual requirements under the Cybersecurity Maturity Model Certification (CMMC) program as part of the National Defense Authorization Act for FY 2020 to enhance cybersecurity for the US defense industrial base. The final rule is effective November 10, 2025.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
Just like all other business systems required for federal Government contract work, the Government property system requires compliant policies and procedures for an adequate system determination. While procedures are only a single part of a contractor’s property management system, they are the backbone of how the system should operate.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)
If you have any grants or cooperative agreements (i.e., federal awards under 2 CFR 200), you must annually determine whether you must obtain an audit, as required by 2 CFR Subpart F. These are referred to as “Single Audits.” And yes, even if you get audited by the Defense Contract Audit Agency (DCAA) or one of its hired Independent Public Accountants (IPAs) for your FAR-based contract or subcontracts, if you have a grant, you will need a second audit.
Topics: Accounting System Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
Well, of course, The Department of Defense (DOD) can. The three most common situations where DoD requires cost data on a fixed price contract are:
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)
The Federal Acquisition Regulatory (FAR) Council, consisting of the Office of Federal Procurement Policy (OFPP), DoD, GSA, and NASA, has finalized changes to acquisition-related thresholds in the FAR to account for inflation. Published in the Federal Register on August 27, 2025, and effective October 1, 2025, this rule (FAR Case 2024-001, FAC 2025-06) fulfills the statutory requirement under 41 U.S.C. 1908 to review and adjust thresholds every five years using the Consumer Price Index (CPI) for all urban consumers.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)
