6 Pitfalls of Accounting and ERP System Implementations

Many things can hamper the successful implementation of a new accounting and ERP system. Although our team specializes in Deltek Costpoint implementations, we believe the following six mistakes can create significant pitfalls for the implementation of any system.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, Deltek Costpoint

Commercial Solutions Opening – Looking to Bring New Entrants into the DoD Marketplace

The National Defense Authorization Act (NDAA) for Fiscal Year 2022 and 2023 permanently authorized the Department of Defense (DoD) “to acquire innovative commercial products and commercial services through a competitive selection of proposals resulting from a general solicitation, known as a commercial solutions opening (CSO).” On August 17, 2023, the final rule was published in the Federal Register under DFARS Case 2022-D005 changing several parts of the DFARS – with most of the changes within DFARS part 212.

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

OMB Extends Deadline for Software Supply Chain Security to Submit Attestation Forms

On June 9, 2023, the Office of Management and Budget (OMB) issued M-23-16, Update to Memorandum M-22-18, providing an extension to the deadline for software developers to submit attestation forms to Federal agencies.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity

Department of Defense Has a Problem with Audits (Their Own)

The Department of Defense has failed an audit - five in a row, to be exact. Federal law mandates audits for all federal agencies, and until 2017, the Department of Defense was never able to satisfy this requirement. It is a very tall task – auditing an agency that controls over half of the discretionary spending in the United States. But in 2017, DoD underwent a financial audit for the first time. They did not pass, but that was never expected. There have also been audits each year since, and while the Agency has not yet passed an audit, it has improved each time.

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Topics: DFARS Business Systems, Government Property Management

Draft Self-Attestation Form for Software Producers Available for Comment by June 26, 2023

On April 27, 2023, The Cybersecurity and Infrastructure Security Agency (CISA) of The Department of Homeland Security (DHS) published a draft Secure Software Development Attestation Form. Software producers that sell to the government will be required to complete the self-attestation form to attest that the software they produce was developed in conformity with specified secure development practices.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity

NDAA 2023 Specifies Data Required to Support Commercial Determinations

The National Defense Authorization Act (NDAA) 2023, Section 803 amended the data that contractors are required to supply for commercial products at the subsystem, component and spare-part levels for major weapons system. While a DFARS proposed rule is being drafted, we expect Contracting Officers and DCMA Commercial Item Group (CIG) to begin requiring this information for proposed commercial products in advance of the DFARS proposed rule.

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination

What is the Purpose of a Contractor Purchasing System Review (CPSR)?

The purpose of a CPSR is to determine if a contractor’s purchasing system and related internal controls comply with applicable laws and regulations, are effective over compliance with applicable laws and regulations, and are adequate and operating effectively. Contractors should evaluate their purchasing system by using the following regulations and DCMA guidance:

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Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)

DoD Final Rule Requires Contracting Officers to Consider SPRS Risk Assessments

DoD Issued a Final Rule amending the Defense Acquisition Regulation Supplement (DFARS) to require contracting officers to consider Supplier Performance Risk System (SPRS) risk assessments when evaluating a suppliers quote or offer. The final rule is effective March 22, 2023. The Supplier Performance Risk System (SPRS) is the authoritative source to retrieve supplier product and performance information assessments for the DoD acquisition community to use in identifying, assessing, and monitoring unclassified performance.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Cybersecurity

CEOs Need to Document That IR&D Projects Advance the Needs of DoD

DoD issued a DFARS Final Rule on Treatment of Incurred Independent Research and Development Costs (DFARS Case 2017-D019). The rule is effective January 31, 2023.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems

The ASBCA Giveth and the Federal Circuit Taketh Away

In a saga which conjures up the phrase: “It ain’t over till it’s over” (quotation attributed to the late, great Yogi Berra), the US Court of Appeals for the Federal Circuit (Case 21-2304) in a decision dated 01-3-2023, reversed an ASBCA Decision (60091, et al), the latter having found Raytheon’s policies for tracking potentially unallowable Lobbying and Organization costs to be reasonable, thus allowable.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems