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 will have to be expanded, as each contract may present additional requirements. To help you understand the complex requirements, we will address the major business systems and other key areas.
Topics: Accounting System Compliance, 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 on Federal Government contractors. The law supporting this dates back to 1962, when 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: Accounting System Compliance, 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
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
This is a common misconception within the GOVCON community. While the expectations are clearly less documentation and effort are required than that of a larger dollar value purchase, there is not a magic threshold at which NO documentation of the fair and reasonable price is allowed.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
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: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
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!
Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Estimating System Compliance