DFARS Final Rule Prohibits Conflicts of Interest in Certain Consulting Services

The Department of Defense (DoD) has finalized a rule that will significantly impact contractors providing management, scientific, and technical consulting services. Published in the Federal Register on August 25, 2025, and effective October 24, 2025, the rule (DFARS Case 2024-D007) implements section 812 of the FY 2024 National Defense Authorization Act (NDAA). Under the new requirement, contracting officers cannot award contracts assigned to NAICS codes beginning with 5416 if the offeror, or its subsidiaries or affiliates, holds a contract for consulting services with certain covered foreign entities, unless an approved conflict-of-interest mitigation plan is in place.

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

DFARS Final Rule Updates Acquisition-Related Thresholds for Inflation

The Department of Defense (DoD) has finalized changes to acquisition-related thresholds in the Defense Federal Acquisition Regulation Supplement (DFARS) to reflect inflation. Published in the Federal Register on August 25, 2025, and effective October 1, 2025, this rule (DFARS Case 2024-D002) fulfills the statutory requirement under 41 U.S.C. 1908 to review and adjust thresholds every five years using the Consumer Price Index (CPI) for all urban consumers.

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

When Should I Be Concerned About the FAR Overhaul?

A little background – On April 15, 2025, Executive Order 14275, Restoring Common Sense to Federal Procurement, was issued. The intent of this order was to make revolutionary changes to the Federal Acquisition Regulations (FAR) to make the federal acquisition process more efficient and cost-effective. Section 2 states, “It is the policy of the United States to create the most agile, effective, and efficient procurement system possible. Removing undue barriers, such as unnecessary regulations, while simultaneously allowing for the expansion of the national and defense industrial bases is paramount. Accordingly, the FAR should contain only provisions required by statute or essential to sound procurement, and any FAR provisions that do not advance these objectives should be removed.”

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Are Representations (Reps) and Certifications (Certs) Required of Subcontractors?

If only the Government made this an easy answer. There are some representations and certifications that you need to get from your subcontractors. However, many in both industry and the Government think the requirement for “Reps and Certs” flows down in all cases.

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

Deltek Costpoint Procurement for Manufacturers: Requisitions, Standard Text, and CMI

Are you taking full advantage of all the features that Deltek Costpoint’s Procurement modules can provide to your Manufacturing business? We regularly work with clients to assess their current utilization of the procurement modules and make recommendations on how they can better utilize this powerful capability. In this multi-part article series, we will discuss some of the many Costpoint Procurement features that we want to ensure you are aware of, to help your manufacturing procurement processes run even better. Many of these apply even if you are not a manufacturing business and are just procuring goods & services.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Property Management, Deltek Costpoint, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting

Is Your Ethics Program Prepared for Increased Scrutiny from the DOJ and Auditors?

In May of 2023, Ms. Jamie Brabston, Director and Legal Counsel at Redstone GCI, wrote an article addressing the Federal Acquisition Regulations (FAR) requirements expected of contractors receiving contracts for supplies and services from the federal government. These requirements are implemented through FAR 52.203-13, Contractor Code of Business Ethics and Conduct, which is included in contracts and subcontracts expected to exceed $6M, and the period of performance is 120 days or longer.

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Topics: Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200), Organizational Change Management Consulting

Can Government Contractors Recoup Tariffs Imposed on Government Contracts?

President Trump issued several executive orders addressing tariffs. American First Trade Policy dated January 20, 2025 and Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment dated April 9, 2025. In addition, he has also issued a 90-day pause to some countries and is planning to reduce tariffs on certain industries such as US auto tariffs (see Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States dated April 29, 2025). It is clear that tariffs are impacting the supply chain and government contractors.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting

Protect Your Federal Contracts by Avoiding Tariff Risks from the Start

Well one of the endless numbers of administratively burdensome requirements the Federal Government places on your contracts may just be the silver bullet you need. Review your contracts and look for FAR 52.225-8, Duty-Free Entry, and DFARS 252.225-7013, Duty-Free Entry.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR)

Terminated Contracts and Government Property Disposition


Terminated contracts do not relieve a contractor from dispositioning and closing out Government property. This will become a bigger issue as more and more agencies receive funding cuts or contracts are simply terminated.

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

What is a Split Purchase in Government Contracting?

There is no definition of split purchases in the Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation Supplement (DFARS). However, the Defense Contract Management Agency reviews purchase order files for split purchases during a Contractor Purchasing System Review. The Government considers a split purchase when a contractor intentionally breaks down a requirement to stay under a regulatory threshold (e.g., micro-purchase, simplified acquisition threshold, or Truthful Cost or Pricing Data Act (TINA)) in order to circumvent procurement requirements or avoid having to compete.

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