Organizational Conflicts of interest have increasingly gained attention from the Government and Government contractors. Organizational Conflicts of Interest (OCI) are discussed in the Federal Acquisition Regulation (FAR) subpart 9.5. OCI rules are meant to prevent conflicting roles or unfair competitive advantage in government contracting. Assessment of OCI is very fact specific, and mitigations should be sculpted to fit your contracts and situation.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration
We have received a number of inquiries from clients related to cost allowability for Employee Stock Ownership Plans (ESOPs). In this Part II, we focus on the cost allowability rules and regulations for government contractors (Part I provided a more general description of ESOPs).
Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Updated May 19, 2025
Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
As we (Redstone Government Consulting, Inc.) began to plan our September 21, 2017 Redstone Edge, we sought out speakers and potential attendees from government agencies, including those from DCAA (Defense Contract Audit Agency) and DCMA (Defense Contract Management Agency). In both cases, their potential speakers had a list of questions which seemed to be unnecessary, but related to OGE (Office of Government Ethics) regulations and interpretations, to identify and otherwise prohibit anything which might be an illegal (or at least unethical) gratuity. Although we might not be a “government contractor”, for those who are, there is another regulation in play; FAR 52.203-3 prohibits government contractors from offering gratuities to government employees.
Topics: Redstone GCI, Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support
Companies that incur significant costs for training and education of their workforce should have formal policies and procedures in place to ensure reimbursement on their government contracts and subcontracts. As with all types of costs, there are three major components to consider: allowability, allocability and reasonableness.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources
In ASBCA Case No. 61040, 61101, Sonoran Technology appeals their claim for an equitable adjustment due to an increase in the Service Contract Act Wage Determination after contract award. The solicitation that controlled this contract award included a SCA wage determination and a Collective Bargaining Agreement (CBA). The bidders were required to use the current SCA wage determination (at the time of the bid) in the formulation of their proposals submitted to the Government. For future increases in SCA wages and/or benefits, the FAR and the contract have provisions/clauses which cover a contract price change for a wage determination for a multi-year contract. The issue here whether a new wage determination, incorporated into the contract, prompted a responsibility for the government to adjust the contract price to compensate Sonoran for a corollary increase in its state gross receipts taxes.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources
The objectives of a timekeeping system are to ensure that labor costs are accurately and timely identified as either direct or indirect in the accounting system. For certain contract types (e.g. cost-type), these accumulated labor costs are reported and billed to the customer. It is the contractor’s responsibility to ensure that the labor costs posted in the timekeeping system are proper and reliable.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources
Having a well-defined travel policy is important to your employees, managers, accounting staff, contract customers, and auditors. A one-size-fits-all policy may be suitable for some companies, while others may benefit from having multiple policies focused on the business base and/or contract requirements.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration
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.
Topics: Compliant Accounting Infrastructure, Contractor Purchasing System Review (CPSR)
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?