Does Micro-Purchase Threshold Apply to Government Contractors?


Government Contractor Purchases below the Micro-Purchase Threshold Require NO Documentation

This is a common misconception within the GOVCON community. While the expectations are clearly less documentation and effort are required than that of a larger dollar value purchase, there is not a magic threshold at which NO documentation of the fair and reasonable price is allowed.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Contracts Administration, Defense Contractors, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

DCAA Trying to Stretch FAR Yet Again


At the end of each of the DCAA audit programs for contractor business systems, DCAA discusses what it refers to as “Less Severe Significant Deficiencies.” These are clearly deficiencies which do not meet the DFARS definition of a “Significant deficiency.”[1] As a result, the withhold requirement provided for in DFARS 252.242-7005 cannot be applied.

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Topics: Compliant Accounting Infrastructure, Contracts Administration, Defense Contractors, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

Intercompany Transaction Cost Restrictions and Allowability for Government Contractors


As more and more companies are acquiring companies or being acquired, a predominant question that arises is can I do work with my new or existing affiliates. The simple answer is yes, but there are specific requirements in the FAR on how transactions are performed between affiliates. The requirements of intercompany transactions are found in two primary cost principles FAR 31.205-26 – Materials Costs and FAR 31.205-36 Rental Costs.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Is Your Estimate at Completion on a Progress Payment Higher than the Contract Price?


This is the third blog in a three-part series on progress payments for Government contractors. In this blog we will discuss the estimate to complete, and the adjustments needed when there is a projected loss on a contract.

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Topics: Compliant Accounting Infrastructure, Contracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Progress Payments

Aren’t All Incurred Cost on My Contract Eligible for Reimbursement on My Progress Payment?


This is the second blog in a three-part series on progress payments. This blog addresses Line 5, Contract Price and Line 11, Total eligible costs on the SF1443 Contractor’s Request for Progress Payment Form.

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Topics: Compliant Accounting Infrastructure, Contracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)

Department of Defense (DoD) Increases Progress Payment Rates


This is the first blog on a three-part series on progress payments and discusses progress payments and the applicable rates.

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Topics: Compliant Accounting Infrastructure, Contracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Progress Payments

The What, How and When of the Material Management and Accounting System (MMAS)

Defense Federal Acquisition Regulations Supplement (DFARS) Business Systems have come into focus as DCAA and DCMA increase their audits of these business systems. This blog will help to provide the specific requirements of the Material Management Accounting System (MMAS) and the difference in MMAS and other business system reviews.

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Topics: DFARS Business Systems, Material Management and Accounting System (MMAS)

Defective Pricing Audits? Time to Check that Your Procedures are in Order

DCAA has caught up on their incurred cost backlog and is concentrating effort on Truth in Negotiations Audits (i.e., Defective Pricing). The objective of the Truth in Negotiations audit is to determine whether a negotiated contract price was increased by a significant amount because a contractor did not submit or disclose current, accurate or complete cost or pricing data.

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Topics: Cost and Pricing and Budgeting, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

ASBCA No. 61709 – A Cautionary Tale for Subcontractors with Government Property

On June 24, 2021, the Armed Services Board of Contract Appeals (ASBCA) opinioned that Intellicheck, Inc., a subcontractor, did not have privity of contract or even an implied-in-fact contract with the Government to allow for the recovery of costs incurred by Intellicheck, Inc. to maintain and store Government property after the completion of a Task Order for the Navy. A tale as old as time, the Government lets years go by before taking action to dispose of its property being held by a subcontractor. Then finds a legal out for not paying the costs the Government caused to be incurred.

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Topics: Defense Contractors, DFARS Business Systems, Government Regulations, Government Property Management

What to Expect in a Full DCAA DFARS Business System Audit of Your Accounting System

Source: Deltek blog

A full DCAA Business System Audit can be the longest and one of the most difficult audits a government contractor can experience. To provide some perspective, at a recent audit of one of our clients, DCAA sent 15 auditors to perform the audit. In general, our experience is that these audits take 12 months to over 18 months for DCAA to perform.

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Topics: DFARS Business Systems