Redstone Government Consulting Blog | Estimating System Compliance

The FAR Council issued a proposed rule on November 29, 2024 to amend the FAR to increase acquisition related thresholds for inflation.

Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance

In the June 27, 2024 Federal Register, the Department of Defense (DoD) is proposing to change the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a section of the National Defense Authorization Act for Fiscal Year 2021 requiring that the generally accepted auditing standards (GAAS) definition of a “material weakness” be used in place of the current definition of a “significant deficiency” when evaluating a contractor’s business system.

Topics: Small Business Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance

There is no such thing as a risk-free interaction with the Government when it comes to submitting data.

Topics: Proposal Cost Volume Development & Pricing, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

If this were only a simple question. The most straightforward answer is that it is a good idea for any company to have policies and procedures. If that company is going to do business with the US Government those policies and procedures are going to have to be expanded as each contract may present additional requirements. To help you understand the complex level of requirements we will address the major business systems and other key areas.

Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR), Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance

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

Whether you call it “defective pricing” (DP) or Truth in Negotiations Act (TINA) or even the current labeling of Truthful Cost or Pricing Data Act (TCoPD - 41 USC Ch. 35) there is not much new about the impact to Federal Government contractors. The law supporting this goes back to 1962 in an environment where Congress believed contractors were overcharging the Government for negotiated goods or services. My how times have not changed. This could also describe our current Congress and may create worry among government prime and subcontractors.

Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Federal Acquisition Regulation (FAR), Estimating System Compliance

Oftentimes when supporting the production of cost volumes and pricing exercises for clients, we’re given a basis of estimate (BOE) that has been written by someone on the technical team. Even being a group of accounting and compliance professionals who know little in areas such as cyber, engineering, or other technical areas of the scope of work, we’re left scratching our heads. This usually leads to several back-and-forth discussions centered around gleaning enough information from the technical team to pass the proverbial government “sniff test”.

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Small Business Compliance, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

The Department of Defense (DoD) released new final rulings on October 28, 2022, but what are they and are they really important? Let’s look at significant ones and what’s important:

Topics: DFARS Business Systems, Government Regulations, Estimating System Compliance

Importance of Basis of Estimate

The proposal is often the procurement parties’ first introduction to a company. It is important to remember that different readers are looking for different types of content from the proposal. From an auditor’s viewpoint, an important part of a contractor’s cost estimating process is preparing the basis of estimate (BOE).

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

In the ASCBA Case 61691 Doubleshot, Inc. July 19, 2022 Decision, the Board supported what we believe is the correct reading of the records retention requirement under the FAR related to Cost-Reimbursable contracts. FAR 52.215-2, Audit and Records, requires contractors to make available until 3 years after final payment or any shorter period specified in Subpart 4.7.[1] FAR 4.705-2(b) limits the required retention period to 2 years from the end of fiscal year for pay related records (e.g., timesheet or cards).[2] So provided you submit your Incurred Cost Submission (required by FAR 52.216-7, Allowable Cost and Payment Clause) on time, you only need to maintain any of the records listed in FAR Subpart 4.7 for the time period set forth in that section of the FAR.

Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance