What Should I Do if My Contract or Grant is Affected by Executive Orders?

Executive Order Impacting Funding on Contract or Grant Work

The President issued an Executive Order (EO) on January 20, 2025, to immediately pause the disbursement of funds appropriated through the Inflation Reduction Act of 2022 (Public Law 117-169) or the Infrastructure Investment and Jobs Act (Public Law 117058). This relates to programs for issuing grants, loans, contracts, or any other financial disbursements of such appropriated funds. The Office of Management and Budget issued a guidance memo on January 28 and rescinded the memorandum on January 29.

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200), REAs, Claims & Terminations

Instruction from a Contracting Officer’s Representative (COR) for Government Contractors

FAR 1.604 allows a contracting officer (CO) to designate a representative to assist the CO in the technical monitoring and administration of a contract. The CO authorizes the contracting officer’s representative (COR) to perform many important tasks to assist the CO in administrating the contract during performance. However, FAR 1.602-2(d)(5) specifically prohibits the CO from authorizing the COR “to make any commitments or changes that affect price, quality, quantity, delivery, or other terms and conditions of the contract nor in any way direct the contractor or its subcontractors to operate in conflict with the contract terms and conditions.”

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations

The Importance of FAR 31.201-3 Determining Reasonableness

Does the Government find most of the cost incurred by a contractor to be reasonable? I must say it does appear that way. Defense Contract Audit Agency (DCAA) FY 2023 Report to Congress shows that of the $186B incurred cost audited, there was only $1.1B in audit exceptions (.6%). So, the world is good, and we can move on. If that were only the case. Remember that while this percentage is low, this is money you have already spent that the Government will not pay you for, which directly impacts your bottom line.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

DCAA Publishes the 2025 Compensation Cap

Again, this year our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2025 compensation cap amount is $671,000. Below we have provided the compensation caps going back to 2019.

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Topics: Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Common Errors and Fixes in Deltek Costpoint’s Billing Module

Deltek Costpoint’s Billing Module is designed to facilitate the invoicing process while adhering to complex government regulations. Whether you’re billing fixed-price contracts, time and materials (T&M), or cost-plus contracts, mastering its capabilities can significantly enhance efficiency and accuracy in your financial workflows. In this article we delve into some fundamental tips and tricks to help you harness the full power of Deltek Costpoint for billing purposes.

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Topics: DCAA Audit Support, Deltek Costpoint

Timekeeping and Compliance in Unanet for Government Contractors

Unanet provides a comprehensive suite of features tailored to help government contractors efficiently manage people and projects. These features are designed not only to enhance cost control and profitability but also to improve overall performance while ensuring compliance with complex government regulations. At Redstone GCI, we’ve seen firsthand how proper implementation of Unanet can streamline operations, significantly reducing processing costs compared to outdated or manual systems. With its robust capabilities, Unanet is built to meet the stringent requirements of federal government timekeeping and expense reimbursement, making it a valuable tool for contractors aiming to maintain compliance and improve operational efficiency. Our team specializes in helping government contractors unlock the full potential of Unanet, ensuring it is implemented and utilized effectively to deliver maximum value.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Unanet

FASB Proposed Change Impacting Cost Accounting for Software

Normally, I make numerous references to the Federal Acquisition Regulations (FAR) when writing. However, there is only one FAR reference for this topic, and then we must turn to the Accounting Standards Codification (ASC). In this case, that single FAR reference is FAR 31.201-2(a)(3).

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)

Cost Accounting Standard (CAS) 411 – Accounting for Acquisition of Material Cost

CAS 411 provides criteria for accounting for the measurement and assignment of material costs to cost objectives and follows generally accepted accounting principles (GAAP).

What is the Purpose of CAS 411?

If you don’t have contracts subject to full CAS, then FAR 31.205-26 Material costs requires contractors to implement GAAP when accounting for material. Material costs can either be charged direct to a contract or assigned to contracts through inventory accounts. Material that is charged direct should be identified on the purchase order and material assigned through an inventory account should be consistently applied by category of material. While CAS 411 requires written policies for accounting for material, it is a best practice to establish written policies whether CAS 411 is applicable or not.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS)

New DCAA Director Appointment Brings Potential Opportunities

The Department of Defense (DoD) Comptroller announced the new Defense Contract Audit Agency (DCAA) Director on October 21, 2024, as Ms. Jennifer Desautel. Ms. Desautel was previously the Assistant Director, Policy and Quality was responsible for the formation, development and issuance of contract audit policy and quality assurance within DCAA and its over 4,000 employees in nearly 300 locations. The DoD Comptroller in his announcement sited her extensive experience with DCAA operations and mission as well as her strong alliances across DoD and industry made her ideally suited to lead DCAA.

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Topics: Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Government Regulations

Don’t Forget the Government Property During Contract Closure

So, the title is maybe a little misleading, and don’t worry – DCMA won’t let you forget the Government property during contract closure. Government property closeouts are only a singular piece to the contract closeout process. And like with all things Government property, the closeout process takes teamwork from both the contractor side and the Government side to be successful.

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