DCAA Wants to Re-Connect with Government Contractors

The Defense Contract Audit Agency (DCAA) wants to re-connect with you. About four years ago, DCAA was looking around and evaluating its workload and saw a problem: it was going away. With a previously perennial favorite of the incurred cost backlog finally going away and few incurred cost audits due to sampling, DCAA had to look for how it can still be important to the acquisition community.

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

Subcontractors Can Request the Nontraditional Defense Contractor Exception

The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a Memorandum dated May 5, 2024, to Agencies on the Treatment of Nontraditional Defense Contractors.

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

Maximizing Efficiently by Using Unanet CRM to Track Opportunities

What is your company using to track Opportunities? A robust Customer Relationship Management (CRM) solution or spreadsheets and sticky notes? As companies grow, it’s imperative that your team adapts to stay competitive and win contracts. A lot of business development teams track opportunities in Excel. First, bravo for using Excel and not a sticky note. You are on the right track! What if I told you that using a CRM to track opportunities would allow you to gain efficiency, never miss a due date, and project future revenue?

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Topics: Contracts & Subcontracts Administration, Unanet

When to Request a Consent to Subcontract If You Don't Qualify for a Purchasing Review

Probably now. Depending on the type and dollar amount of your subcontracts, FAR 52.244-2 Subcontracts clause requires a contractor that does not have an approved purchasing system (never been reviewed or is disapproved) to obtain written consent from the Contracting Officer before subcontract award.

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

The CAS Board is Looking for Input on its Proposed Changes Related to Revenue and Right of Use Leases

In the June 27, 2024 Federal Register, the Cost Accounting Standards Board (CASB) put out a notification that it was looking for input on its efforts to conform Cost Accounting Standards (CAS) to Generally Accepted Accounting Principles (GAAP) related to operating revenue and lease accounting. Back on March 13, 2019, the CASB published a Discussion Paper to collect initial input on the conformance of CAS to GAAP. Then on November 5, 2020, the CASB published a notice of proposed rulemaking specifically addressing operating revenue and lease accounting.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)

DFARS Final Rule on Commercial Products Procured Under Major Weapon Systems

DoD issued a final rule DFARS Case 2023-D010 on May 30, 2024, amending The Defense Federal Acquisition Regulation Supplement (DFARS) implementing Section 803 of the National Defense Authorization Act on data required in support of commerciality determinations and price reasonableness under procurements for major weapon systems. The purpose is to provide additional guidance related to the data required to support a request for a commercial determination and the price reasonableness process.

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

Get Up to Speed on Significant Changes to 2 CFR Regulations Effective October 2024

The Office of Management and Budget (OMB) issued a final rule revising 2 Code of Federal Regulations (CFR), now called OMB Guidance for Federal Financial Assistance, to streamline and clarify the rules for federal financial assistance (e.g., grants and cooperative agreements). Agencies must implement the Final Rule by October 1, 2024. These rules will apply to new grants and can be applied to existing grants by a bi-lateral modification. Although OMB indicates that agencies may apply the new rules beginning June 21, 2024, we believe most federal agencies will wait so that both the agencies and the recipients have time to read and digest some of these updates.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

The CAS Board is Looking to Address CAS Applicability When it Comes to IDIQ Contracts

In the June 18, 2024 Federal Register, the Cost Accounting Standards Board (CASB) put out a notification that it was looking for input on how Cost Accounting Standards (CAS) applicability should be handled when it comes to Indefinite Delivery Vehicles (IDVs) (i.e., Indefinite Delivery Indefinite Quantity (IDIQ) contracts). This goes back to an old CASB case from three years ago – CASB Case 2021-01, Application of Cost Accounting Standards (CAS) to Indefinite Delivery Vehicles (IDVs).

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)

Employee Stock Ownership Plan (ESOP) is the Gift That Keeps on Giving

Besides the potential tax benefits of an Employee Stock Ownership Plan (ESOP), the National Defense Authorization Act (NDAA) for Fiscal Years 2022 and 2024 has introduced an additional benefit for employee-owned businesses contracting with the Department of Defense (DoD). A pilot program that will allow for the award of follow-on contracts without competition.

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Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Training is an Allowable Cost and Required for Government Contractors

Training and employee development, in our opinion, must be looked at as a necessary investment in the future of a business as well as the business’ key resource - its employees. That said, those businesses in the government contracting industry are also facing an ever-expanding list of required or at least expected training that is necessary to maintain compliance with their growing list of contract clauses.

Contract Requirements and Expectations for Training

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources, Federal Acquisition Regulation (FAR), Organizational Change Management Consulting