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, Deltek Costpoint

DFARS Case 2017-D018 – Changes to DFARS Requirements for Independent Research and Development

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.

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

The Updated DCMA Contractor Purchasing System Review (CPSR) Handbook has Arrived

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

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

The DoD IG has started the audit – Are your Whistleblower policies up to date?

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.

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

DFARS Case 2020-D008 – Prohibition on Pricing based on Historical Prices

In 2020 Congress directed through the National Defense Authorization Act (NDAA) that contracting officers be prohibited from determining that the price of a contract or subcontract is fair and reasonable based solely on historical prices paid by the Government. Congress goes on to provide that if the contractor fails to provide data supporting the proposed price, the contractor is ineligible for award, unless the head of the contracting activity (HCA) determines that it is in the best interest of the Government to make the award. Let’s face it they are saying contracting officer should be asking for “cost data.”

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

Provisional Billing Rates

This video and article discuss the importance of provisional billing rates for government contractors. If you have cost-reimbursable vouchers or progress payments based on costs, you want to make sure you have established provisional billing rates.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, DCAA Audit Support, Vlog

More to Report if you have DoD Service Contracts

On July 9th, 2021, the Department of Defense (DoD)issued a final rule in the Federal Register to implement 10 U.S.C. 2330a which requires the DoD to establish a data collection system to provide certain management information about an awarded contract or task order that is valued in excess of $3 million. This new rule is applicable for the following service acquisition portfolio groups:

  • logistics management services
  • equipment-related services
  • knowledge-based services
  • electronics and communications services

You may read the entire rule here.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, System Award Management (SAM), Government Regulations

Travel Costs Regulation & Myths for Government Contractors

Have questions regarding what travel costs are allowable? Do you think the travel regulations say you can never have first-class airfare reimbursed? Or do you think the regulation says you are restricted to a compact rental car? For the answer to these questions and more, check out our video on travel regulations and myths!

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems, Vlog

Acceptable Estimating System: NITAAC CIO-SP4 Points Scoring

The National Institutes of Health Acquisition and Assessment Center (NITAAC) released its long-awaited Request for Proposal (RFP) for the Chief Information Officer – Solutions and Partners (CIO-SP4) program on May 25, 2021. Phase I of the evaluation of offeror proposals will consist of validation of the offeror’s completed self-scoring sheet and ranking the offerors based on this scoring. Only the highest rated offerors will advance to phase 2 of the evaluation. Accordingly, every point counts!

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Estimating System Compliance

What Information Should I Include in a Commercial Item Determination?

A commercial item determination should define the item or service, document market research, identify the FAR 2.101 Commercial Item definition, and include a “determination” that the item is commercial. Sounds easy right!

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Commercial Item Determination