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.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
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.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)
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.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
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.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
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).
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)
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.
Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
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
What is the state of your contract tracking? Are you using a spreadsheet? Do you scramble during an audit to locate and update contract briefs? Is modification information stuck with contracts, and is cost & revenue data stuck in finance? Do you want to connect your data from lead to opportunity to contract to project to close out? Are you manually tracking important FAR clauses and flowing those down to your subs?
Topics: Contracts & Subcontracts Administration, Deltek Costpoint
The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a guidance memorandum dated March 18, 2024 to Agencies based on the results of the Department of Defense (DoD) Inspector General (IG) Audit of DoD Compliance on Whistleblower Protection Requirements. While the DoD IG found in most cases, that Contracting Officers included the DFARS 252.203-7002 Requirement to Inform Employees of Whistleblower Rights clause in contracts, they did not verify whether contractors were complying with the clause.
Topics: Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)
Cost Accounting Standard (CAS) 420 outlines accounting standards for Independent Research and Development (IR&D) and Bid & Proposal (B&P) costs incurred by government contractors, ensuring consistent and transparent reporting.
Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)