Did the Door Just Open for Inflation Relief on DoD Fixed-Priced Contracts?

Yes, the door just opened for potential relief from unanticipated inflation on fixed-priced contracts, but what’s beyond the door is still unclear. This year’s National Defense Authorization Act (NDAA) includes Section 822, Modification of Contracts to Provide Extraordinary Relief Due to Inflation Impacts, which builds upon DoD’s September 9, 2022, inflation guidance through use of FAR Part 50, Extraordinary Contractual Actions and the Safety Act, requests submitted to your contracting officer to provide an upward adjustment (increase contract value) and this can be done for prime and subcontractors. Note that this NDAA section does not create an obligation for the Government to pay for unanticipated inflation, but it is a “discretionary” expenditure where the Government may pay for the effects of unanticipated inflation. What remains to be seen is exactly how and how much will be provided to your contract(s).

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Topics: Compliant Accounting Infrastructure, Contracts and Subcontracts Administration, DFARS Business Systems, Government Regulations

Why are Schedules B, C, D, and Fringe Important?

Schedules B, C, D, and Fringe are some of the most important parts of the Incurred Cost Submission. This vLOG will briefly explain the Incurred Cost Submission, how to complete Schedules B, C, D, and Fringe, and the importance of each schedule.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Contracts and Subcontracts Administration, DCAA Audit Support, Vlog

How to Deal with a Difficult DCAA Auditor

You pride yourself on working well and getting along with everyone, at least professionally. However, there is an auditor that seems to get under your skin. What do you do? Well, although there may not be a “magic bullet” to all make it better. I propose the following to get you through the situation at hand:

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Topics: Contracts and Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

The Importance of Schedule K in the Incurred Cost Submission

Schedule K is one of the most important parts of the Incurred Cost Submission and is an area of great interest for the Government and its auditors. This VLOG will briefly explain the Incurred Cost Submission, how to complete Schedule K, and the importance of Schedule K.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Contracts and Subcontracts Administration, Vlog

FAR Final Rule: Small Business Opportunities Overseas – Don't Pack Your Bags Yet


DoD issued a final rule on April 26, 2022, amending the FAR to support the Small Business Administration regulation of including overseas contracts in agency small business contracting goals. The final rule is effective May 26, 2022.

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Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts and Subcontracts Administration, DFARS Business Systems

ASBCA Case Helps Nail Down Record Retention Requirements


In the ASCBA Case 61691 Doubleshot, Inc. July 19, 2022 Decision, the Board supported what we believe is the correct reading of the records retention requirement under the FAR related to Cost-Reimbursable contracts. FAR 52.215-2, Audit and Records, requires contractors to make available until 3 years after final payment or any shorter period specified in Subpart 4.7.[1] FAR 4.705-2(b) limits the required retention period to 2 years from the end of fiscal year for pay related records (e.g., timesheet or cards).[2] So provided you submit your Incurred Cost Submission (required by FAR 52.216-7, Allowable Cost and Payment Clause) on time, you only need to maintain any of the records listed in FAR Subpart 4.7 for the time period set forth in that section of the FAR.

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Topics: Contracts and Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

What is Schedule I in the Incurred Cost Submission?

Schedule I is the most important part of the Incurred Cost Submission and is the single area of great interest for the Government and its auditors. This VLOG will briefly explain the Incurred Cost Submission, the importance of Schedule I, and how to resolve potential issues.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts and Subcontracts Administration, Vlog

Are Adjusting Billings to Final Year-End Rates Really That Important?


Yes, they are! Did your company make it through its year-end and closing of last year’s books? If so, hooray! But is it really over for those that have Government cost-type contract billings? Not really. OK, as the Federal Acquisition Regulation (FAR) 42.704, Billing rates, allows interim payments through contract performance with the intent of making the contracting officer or contract auditor approved provisional billings rates as close as possible to the expected final indirect rates. This allows you to bill your costs throughout the year of your cost-type Government contract billings. Now that you know what the year-end indirect rates really are, there is one more thing to do: adjust the provisional indirect billing rates to actual rates in a Public Voucher (Standard Form 1034). Those year-end indirect rates should be net of any unallowable costs in FAR Part 31, Contract Cost Principles and Procedures. Sounds easy. It really should not be that difficult.

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Topics: Compliant Accounting Infrastructure, Contracts and Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Benefits of Contracts Module in Unanet

Have you considered populating the contracts module in Unanet with your data, but haven’t taken the time to do it yet? Let’s talk through the benefits of using the Contracts module.

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Topics: Compliant Accounting Infrastructure, Contracts and Subcontracts Administration, Unanet

Understanding the Differences Between Purchase Orders and Subcontracts


There seems to be a lot of questions and misconceptions about purchase orders and subcontracts. Is there a difference? When is it appropriate to issue either instrument?

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Topics: Small Business Compliance, Contracts and Subcontracts Administration, Contractor Purchasing System Review (CPSR)