The United States Supreme Court has ruled that the International Emergency Economic Powers Act does not authorize presidential tariffs, effectively invalidating prior IEEPA-based duties. This decision creates uncertainty around potential refunds and shifts attention to new tariff measures now in effect. Importers and trade compliance teams must reassess duty exposure, documentation practices, and forward-looking trade strategies in a rapidly changing regulatory environment.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Estimating System Compliance, Manufacturing Operations Consulting
Contractors pursuing competitive prime awards under FAR Part 15 face heightened expectations for cost realism, documentation, and historical support. Agencies rely on detailed cost narratives and supporting data to make best value determinations. Weak or unsupported pricing can delay negotiations or undermine award decisions, making early preparation and internal alignment critical to proposal success.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Section 1826 of the FY 2026 National Defense Authorization Act shifts DoD treatment of nontraditional defense contractors from discretionary to mandatory exemptions from key cost and business system requirements. With no dollar threshold and rulemaking still pending, government contractors must evaluate timing, contract status, and downstream compliance implications.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Commercial Item Determination
Congress has directed NIH and the Department of Defense to maintain negotiated indirect cost rates and restrict the use of rate caps within recent appropriations legislation. The update may affect grant funding, reimbursement expectations, and agreement terms. Organizations should understand how timing and regulatory alignment influence existing and future awards.
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
Congress and recent appropriations legislation have restricted federal agencies from applying indirect cost rate caps on grants, reinforcing the use of negotiated rates. The change affects DOE and other agencies and may require organizations to review award terms, reimbursement eligibility, and timing considerations tied to indirect cost recovery.
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
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Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
In reference to the now outdated terminology “Multiple Personality Disorders” (now “DID” or Dissociative Identity Disorder), my focus is on two Government actions, the 2026 NDAA (National Defense Authorization Act) and the very recent EO (Executive Order), “Prioritizing the Warfighter in Defense Contracting.” Before getting into the substance of this blog, just to note that one can only hope that the proposed/legislated changes to improve the efficiencies and effectiveness of the procurement process (for the Department of War and more broadly the US Government) will actually succeed and not be just one more set of idealized and unfulfilled political promises.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
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Recent statutory changes under the FY 2026 National Defense Authorization Act revise the applicability thresholds for the Cost Accounting Standards and limit certain post-award contract price adjustments. These updates affect how contractors evaluate fixed-price awards, accounting practice changes, and clause timing, as regulatory implementation is expected within 180 days of enactment.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
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For the last few years, our friends at the Defense Contract Audit Agency (DCAA) have been very helpful by publishing the Contractor Compensation Cap in the December timeframe. This year, I am guessing that the Government shutdown has diverted their attention. To help our clients, we have calculated the 2026 amount of the cap.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)
On November 24, 2025, President Trump signed EO 14363, Launching the Genesis Mission to accelerate America’s race for global dominance in the application of AI to scientific discovery and scientific challenges.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)