Expect More Grant Awards from DOE on the Genesis Mission to Build an AI Platform

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.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)

Whistleblowers Continue to File Qui Tam Suits for Cybersecurity Noncompliance

On December 5, 2025, the Department of Justice (DOJ) reported another settlement under the False Claims Act (FCA) related to cybersecurity. Swiss Automation agreed to pay $421,234 to the Government as a result of failing to provide adequate cybersecurity controls for drawings of parts supplied to Department of Defense (DoD) prime contractors. The qui tam suit under the False Claims Act (FCA) was brought forward by a whistleblower, not an Information Technology (IT) employee, but a Quality Control Manager of the company. The whistleblower received $65,291.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Item Determination

Are You Prepared for the 2025 Compliance Supplement and Audit Changes

On November 26, 2025, the Office of Management and Budget (OMB) issued the 2025 Compliance Supplement. The Supplement outlines the compliance requirements to assist auditors in understanding the Federal program’s objectives, procedures and requirements when performing a Single audit for fiscal years beginning after June 30, 2024. The Compliance Supplement is normally issued in the spring of each year; however, OMB delayed its issuance to incorporate significant updates to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, in October 2024. In order to assist auditors with the different requirements, Part 3 Compliance Requirements of the Supplement was divided into two Parts for audit testing as follows:

  • Part 3.1 for awards subject to 2 CFR 200 prior to October 2024 and
  • Part 3.2 for awards after October 1, 2024
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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

Do Cybersecurity Maturity Model Certification (CMMC) Requirements Apply to Grants?

The Department of Defense (DoD) issued a final rule on September 10, 2025, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate the requirements of the Cybersecurity Maturity Model Certification (CMMC) for FAR-based contracts and subcontracts, effective November 10, 2025.

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Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Grants & Cooperative Agreements (2 CFR 200)

DFARS Final Rule for Cybersecurity Maturity Model Certification (CMMC) program

Department of Defense (DoD) issued a final rule on September 10, 2025, amending Defense Federal Acquisition Regulation Supplement (DFARS), incorporating contractual requirements under the Cybersecurity Maturity Model Certification (CMMC) program as part of the National Defense Authorization Act for FY 2020 to enhance cybersecurity for the US defense industrial base. The final rule is effective November 10, 2025.

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

Are Your Government Property Procedures Enablers?

Just like all other business systems required for federal Government contract work, the Government property system requires compliant policies and procedures for an adequate system determination. While procedures are only a single part of a contractor’s property management system, they are the backbone of how the system should operate.

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

If You Receive Federal Grants Then a Single Audit May Be Required

If you have any grants or cooperative agreements (i.e., federal awards under 2 CFR 200), you must annually determine whether you must obtain an audit, as required by 2 CFR Subpart F. These are referred to as “Single Audits.” And yes, even if you get audited by the Defense Contract Audit Agency (DCAA) or one of its hired Independent Public Accountants (IPAs) for your FAR-based contract or subcontracts, if you have a grant, you will need a second audit.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

Can DoD ask a Contractor for Cost Data on a Fixed-Price Contract or Subcontract?

Well, of course, The Department of Defense (DOD) can. The three most common situations where DoD requires cost data on a fixed price contract are:

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)

FAR Final Rule Updates Acquisition-Related Thresholds for Inflation

The Federal Acquisition Regulatory (FAR) Council, consisting of the Office of Federal Procurement Policy (OFPP), DoD, GSA, and NASA, has finalized changes to acquisition-related thresholds in the FAR to account for inflation. Published in the Federal Register on August 27, 2025, and effective October 1, 2025, this rule (FAR Case 2024-001, FAC 2025-06) 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)

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)