Redstone Government Consulting Blog | Contracts & Subcontracts Administration (10)

Indefinite Delivery Indefinite Quantity (IDIQ) contracts often look like a big money opportunity for contractors – but looks can be deceiving. Many IDIQs are multi-awards, meaning you are just one of many contractors that may get task orders awarded under the contract. On top of that, the required minimum the Government must buy under the IDIQ is, in most cases, very low. So, it turns out that millions of dollars of anticipated business fizzles down to $2,500 – which may have a shocking impact to your return on investment.

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

Comparison to FAR

Like CAS 401, CAS 402, and CAS 405, CAS 406 is part of modified CAS coverage and is one of the first CAS standards a company encounters. It likely will not call for any changes to the company’s cost accounting system if you are compliant with FAR 31.203(g)(2) (Indirect costs). FAR states that for contracts not subject to CAS:

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

April 25, 2023; the Court of Appeals agreed with the Armed Services Board of Contract Appeals (ASBCA) that a contractor cannot take a unilaterally established Undefinitized Contract Action (UCA) to the Board without first submitting a certified claim request for a final decision by the contracting officer.

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

So, the Defense Contract Agency Audit (DCAA) auditor comes into your office, performs an audit, and…they have findings. What do you do? Wait…is there something that I should not do?

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

All Time and Material (T&M) contracts with the Federal Government, even commercial ones under Federal Acquisition Regulations (FAR) part 12, have one big thing in common. That big thing is that all of the labor hours delivered must be performed by individuals meeting the labor qualifications specified in the contract. The Federal Government uses very strong language in its contract requirement related to this, stating the hours “will not be paid to the extent the work is performed by individuals that do not meet the qualifications.”

Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

Unanet recently released multiple updates to the Contracts Module. Contract clauses were one of the updates that had everyone excited. This new functionality is great if you plan on using it to its full capability. There are multiple steps to this process, which can be time-consuming, so you’ll want to set aside time and plan ahead to complete this process.

Topics: Contracts & Subcontracts Administration, Unanet

Comparison to FAR

Like CAS 401 and CAS 402 (see previous blog posts on these CAS Standards), CAS 405 is part of modified CAS coverage and is one of the first CAS standards a company encounters. Compliance with this standard will likely not call for any changes to the company’s cost accounting system if the company is compliant with FAR 31.201-6 (Accounting for Unallowable Costs) because the FAR clause has more requirements than CAS 405.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Comparison to FAR

Like CAS 401, CAS 402 is part of modified CAS coverage and is one of the first CAS standards a company encounters. It likely will not call for any changes to the company’s cost accounting system because Federal Acquisition Regulations (FAR) 31.202 (Direct costs) and 31.203 (Indirect costs) give us words very similar to the CAS words.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Whether you call it “defective pricing” (DP) or Truth in Negotiations Act (TINA) or even the current labeling of Truthful Cost or Pricing Data Act (TCoPD - 41 USC Ch. 35) there is not much new about the impact to Federal Government contractors. The law supporting this goes back to 1962 in an environment where Congress believed contractors were overcharging the Government for negotiated goods or services. My how times have not changed. This could also describe our current Congress and may create worry among government prime and subcontractors.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Federal Acquisition Regulation (FAR), Estimating System Compliance

DoD Issued a Final Rule amending the Defense Acquisition Regulation Supplement (DFARS) to require contracting officers to consider Supplier Performance Risk System (SPRS) risk assessments when evaluating a suppliers quote or offer. The final rule is effective March 22, 2023. The Supplier Performance Risk System (SPRS) is the authoritative source to retrieve supplier product and performance information assessments for the DoD acquisition community to use in identifying, assessing, and monitoring unclassified performance.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Cybersecurity