The FAR Council submitted a proposed rule amending FAR subparts, provisions, and clauses on October 3, 2023, to implement an Executive order on cyber threats, incident reporting, and information sharing for Federal contracts. This revision is being made to strengthen and standardize contractual requirements for cybersecurity across Federal agencies. The proposed rule also implements OMB Memorandum M-21-07 Completing the Transition to internet Protocol Version 6 (IPv6), dated November 19, 2020.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
The FAR Council published an interim rule effective June 2, 2023, that bans TikTok on contractor and contractor employee electronic devices that are used in the performance of federal contracts.
Topics: DFARS Business Systems
If you have an upcoming Defense Federal Acquisition Regulation Supplement (DFARS) estimating system audit, you need to plan for it, and the sooner, the better. Don't wait until the Defense Contract Audit Agency (DCAA) begins sending you its requests for information. But how do you prepare? Perhaps a place to start is first understanding what this audit entails and knowing what DCAA may cite as common findings.
Topics: DFARS Business Systems, DCAA Audit Support, Estimating System Compliance
We have discussed recently how DoD has an increased interest in government property, especially the property that contractor’s control and maintain. RGCI has helped clients with government property issues more in the past four years than the previous ten years combined.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Property Management
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.
Topics: Compliant Accounting Infrastructure, DFARS Business Systems, Deltek Costpoint
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.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)
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.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
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.
Topics: DFARS Business Systems, Government Property Management
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.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cybersecurity
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.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination