Redstone Government Consulting Blog | DFARS Business Systems (7)

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.

Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

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.

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

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

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

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.

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

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.

Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

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.

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

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.

Topics: DFARS Business Systems, Deltek Costpoint

In 2017 Congress directed through the National Defense Authorization Act (NDAA) that changes be made to the treatment of independent research and development (IR&D) costs and required the Defense Contract Audit Agency to provide as part of its annual report to Congress both independent research and development and bid and proposal (B&P) costs expended by DoD contractors. Congress intended this change to apply to indirect costs incurred on or after October 1, 2017. The Defense Acquisition Regulation (DAR) Council must have read over that part.

Topics: Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations

DCMA updated the Contractor Purchasing System Review (CPSR) Handbook on September 10, 2021.

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

DoD Inspector General Audit on Whistleblower

We issued a blog in May 2021 addressing the Department of Justice, Inspector General. The IG found that DOJ contracts did not comply with the whistleblower requirements to include whistleblower clauses in the contract, disseminate the rights and protections in writing to employees, and include required information in confidentiality agreements/statements to employees. We indicated we would not be surprised to see the DoD IG pick up on this area and review DoD Contractors.

Topics: DOD IG, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR)