Redstone Government Consulting Blog | Compliant Accounting Infrastructure (24)

Not only do you get to pay for the audit, you get pay for the CPA to support an audit of the audit!

Topics: Compliant Accounting Infrastructure, Small Business Compliance, DFARS Business Systems

On April 21, 2014, the DAR editor submitted a proposed new DFARS rule (DFARS Case 2012-042) for Business Systems Compliance to OMB’s Office of Information and Regulatory Affairs (OIRA).  Generally, this is the last step prior to the publication of the new rules.  The full body of the proposed rule has not been published; however, OIRA has published the following abstract on May 23, 2014 as part of its semiannual compilation of all pending federal regulations:

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Compliance Training, DFARS Business Systems, DCAA Audit Support

The Department of Energy (DOE) has released its proposed amendments to the Department of Energy Acquisition Regulations (DEAR) which would subject certain DOE contracts to business systems criteria and penalties for failure to maintain adequate internal controls governing those systems.  The proposed rule, published on April 1 2014, makes official a DOE FY 2013 promise of implementing formal regulations which would mirror systems requirements already in place for DOD contracts, those systems of which are defined in DFARS 252.242-7005.

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Compliance Training

In a recent Federal Circuit ruling, KBR found out that “simple negligence” in its calculations of a reasonable price range for subcontractor’s price proposal resulted in a “Gross Negligence ruling” by the courts. Kellogg Brown & Root Services, Inc. (KBR) v. U.S., No. 203-5030, slip op. (Fed. Cir. Feb, 3, 2014).

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE)

Two recent decisions by the General Accountability Office (GAO) and the ASBCA make it clear that the contractor will be held responsible for incorrect assumptions when they fail to follow up on known inconsistencies or missing information with the government, even when the government is responsible for providing the information.

Topics: Compliant Accounting Infrastructure, Small Business Compliance

The Department of Defense issued a final rule revising the DFARS “Proposal Adequacy Checklist” on January 29, 2014 to eliminate question 19 of that checklist which addresses whether the contractor cost proposal, to which the checklist applies, demonstrates that price analysis of costs for all proposed commercial items was performed.  The DOD determined that questions 14 and 17 address price analysis for all proposed materials and subcontracts, commercial or otherwise, therefore making question 19 duplicative and unnecessary. 

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE)

Non-U.S. contractors have many misconceptions as to what rules and regulations they must comply with under U.S. Government contracts. The two most common misunderstandings non-U.S. entities have are (1) their country laws trump U.S. laws and regulations, and (2) Federal Acquisition Regulations (FAR) rules on cost collection and allocations are less strenuous for non-U.S. contractors. These two misconceptions could not be further from the truth.

Topics: Non-US Government Contractor, Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DFARS Business Systems

The National Defense Industrial Association’s (NDIA) September Procurement Division Committee meeting provided insights and information that we believe is of  interest to our readers.  These comments are our own interpretations and opinions based upon our presence at the meeting.

Topics: Compliant Accounting Infrastructure, Sequestration, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration

One of the primary goals for a contractor notified of an impending Defense Contract Audit Agency (DCAA) audit should be to understand the audit process and, if possible, to develop a positive working relationship with auditors.  In other words, to work with rather than against the auditor.

Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support

The Department of Defense (DOD) June 28, 2013 “Performance of the Defense Acquisition System” annual report states that little difference exists between fixed price and cost-plus contracts when it comes to predicting or controlling costs. 

Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Compliance Training