Protect Your Federal Contracts by Avoiding Tariff Risks from the Start

Well one of the endless numbers of administratively burdensome requirements the Federal Government places on your contracts may just be the silver bullet you need. Review your contracts and look for FAR 52.225-8, Duty-Free Entry, and DFARS 252.225-7013, Duty-Free Entry.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR)

Executive Orders Target Government-Wide Acquisition Overhaul


President Trump has signed several Executive Orders (EO) addressing ways to improve the acquisition process through simplifying the regulations, utilizing competitive marketplace and commercially available products and services, consolidating procurements at General Services Administration (GSA), and now overhauling the Department of Defense acquisition processes.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Terminated Contracts and Government Property Disposition


Terminated contracts do not relieve a contractor from dispositioning and closing out Government property. This will become a bigger issue as more and more agencies receive funding cuts or contracts are simply terminated.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

Executive Order to Overhaul the Defense Acquisition System

On April 9, 2025, President Trump signed the Executive Order (EO), Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base. The EO indicated that the factory floor is as significant as the battlefield, and the current defense acquisition system must have a comprehensive overhaul to deliver state-of-the-art capabilities at speed and scale.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Is DCAA’s Reorganization the First Step in the Dissolution of DCAA?


On April 7, 2025, Defense Contract Audit Agency (DCAA) Director Ms. Jennifer Desautel announced a major DCAA reorganization to her staff that is perhaps DCAA’s largest since its 1965 inception. With the current federal government’s stress on efficiency and cost reduction, DCAA faced increased pressure to contain its costs and become more efficient. As a result, Ms. Desautel immediately began reorganizing the field and headquarters offices. DCAA will now have three Directorates (shown below): Land, Sea, and Air.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

What is a Split Purchase in Government Contracting?

There is no definition of split purchases in the Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation Supplement (DFARS). However, the Defense Contract Management Agency reviews purchase order files for split purchases during a Contractor Purchasing System Review. The Government considers a split purchase when a contractor intentionally breaks down a requirement to stay under a regulatory threshold (e.g., micro-purchase, simplified acquisition threshold, or Truthful Cost or Pricing Data Act (TINA)) in order to circumvent procurement requirements or avoid having to compete.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

Affirmative Action and DEI After EO 14173 Ending Illegal Discrimination and Restoring Merit-Based Opportunity

Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, has left many unsure as to what you can, cannot, should, or should not do. You are not alone! There are many unanswered questions, so we do not and could not claim to have all the answers, but we do have some thoughts and suggestions to consider at this stage.

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Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Federal Acquisition Regulation (FAR)

What You Really Need to Know About Navigating Through Contract Terminations


It may be an understatement to say defense contractors are currently living in changing times. Change has happened in our government administration resulting in some changes in priorities in federal government programs. This can translate into federal government contracts being changed, suspended, stopped, or even terminated. Although contract terminations seem complex, you can navigate through the complexities by reading and understanding your contract clauses, the acquisition rules, working with your contracting officer, and knowing your cost reporting system and how it can comply with contracting regulations.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations

Do Any DoD Class Deviations Affect Your Contracts or Subcontracts?

What is a Department of Defense (DoD) class deviation? It is a deviation from the Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation (DFARS) that affects more than one contract. They are issued by an authorized official and are used to deviate from the FAR or DFARS and offer flexibility in the acquisition process. Class deviations are supposed to be temporary. If the class deviation will become permanent, the Government is supposed to issue a proposed revision to the FAR or DFARS.

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Topics: Contracts & Subcontracts Administration, System Award Management (SAM), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Cybersecurity

The Federal Funding and Accountability Transparency Act Subaward Reporting System is Retiring in Early March 2025

The Federal Funding and Accountability Transparency Act (FFATA) requires prime contractors to report their first-tier subcontracts and grant recipients to report their first-tier subawards using the Federal Funding and Accountability Transparency Act Subaward Reporting System website.

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Topics: Employee & Contractor Compensation, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)