OMB’s new guidance directs agencies to expand commercial acquisitions and justify non-commercial awards. Government contractors may see closer review of commerciality, pricing, option periods, and cost-reimbursement contracts, making support for market research and contract decisions more important.
Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting
DCAA recently released Version 1.04 of the ICE Model that utilizes Microsoft Power Query to prepare incurred cost proposals. For government contractors preparing annual incurred cost submissions with Microsoft Power Query, this update should be used in replacement of the previous version released. Both the April 2026 Power Query version and the May 2019 Visual Basic version remain available, but each version carries different considerations for preparation, review, and submission through the Contractor Submission Portal.
The updated Power Query version is intended to improve compatibility with contract information such as contract ceiling issues on Schedule I. The instructions have been revised to provide better clarification of information required to properly run the power query version. The original Visual Basic version remains available, but contractors using this version need to be aware of a specific restriction in the Contractor Submission Portal. Files prepared in the Visual Basic version must be saved as .xls or .xlsx before uploading to the Contractor Submission Portal. The Contractor Submission Portal will not accept .xlsm macro files.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)
The FY 2026 NDAA, Section 1807, directs DoD to maintain Project Spectrum, a no-cost online platform offering cybersecurity training, tools, and resources for small and medium-sized government contractors. Originally launched in 2019, the platform supports CMMC compliance and is available to any company pursuing DoD work, regardless of current contract status.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting
The Department of War has introduced an Acquisition Transformation Strategy aimed at prioritizing commercial solutions and expanding participation from nontraditional contractors. While the direction signals reduced barriers and faster acquisition, contractors must evaluate how evolving expectations, timing, and risk tolerance will affect compliance, pricing, and engagement strategies.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Determination
Recent DFARS class deviations associated with the FAR and DFARS overhaul reorganized several cybersecurity clauses, leading to confusion about government contractor self-assessment requirements. Although certain DFARS provisions were removed or renumbered, government contractors handling Federal Contract Information (FCI) must still conduct CMMC Level 1 self-assessments and post results in Supplier Performance Risk System (SPRS).
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Manufacturing Operations Consulting
Contractors pursuing competitive prime awards under FAR Part 15 face heightened expectations for cost realism, documentation, and historical support. Agencies rely on detailed cost narratives and supporting data to make best value determinations. Weak or unsupported pricing can delay negotiations or undermine award decisions, making early preparation and internal alignment critical to proposal success.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Section 1826 of the FY 2026 National Defense Authorization Act shifts DoD treatment of nontraditional defense contractors from discretionary to mandatory exemptions from key cost and business system requirements. With no dollar threshold and rulemaking still pending, government contractors must evaluate timing, contract status, and downstream compliance implications.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Commercial Determination
Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
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Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
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For the last few years, our friends at the Defense Contract Audit Agency (DCAA) have been very helpful by publishing the Contractor Compensation Cap in the December timeframe. This year, I am guessing that the Government shutdown has diverted their attention. To help our clients, we have calculated the 2026 amount of the cap.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)