The FAR Council submitted a proposed rule amending FAR subparts, provisions, and clauses on October 3, 2023, to implement an Executive order on cyber threats, incident reporting, and information sharing for Federal contracts. This revision is being made to strengthen and standardize contractual requirements for cybersecurity across Federal agencies. The proposed rule also implements OMB Memorandum M-21-07 Completing the Transition to internet Protocol Version 6 (IPv6), dated November 19, 2020.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
Well – besides being the first thing your friendly DCAA auditor will ask you for, they should be something your employees use and rely on daily. The last thing you want is one of your employees telling an auditor they have never seen or read the company’s policies and procedures. The joy that will come across the auditor’s face will be truly shocking – and – the sadness that will come across your face when the Business System Deficiency Reports start to arrive, requiring endless responses and corrective action plans, will be just as shocking. This fairytale has no happy ending, at least not for you and your company – just a drain on your resources and more audit oversight.
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
FAR 31.205-20 provides that interest is unallowable on Federal Government contracts, no matter how it is calculated or presented in your financial books and records. This means you cannot propose, bill, or claim your interest expense.
Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
As the fiscal year draws to a close, government contractors are gearing up to meet their year-end reporting requirements. Navigating the maze of regulations and clauses can be daunting, but with a clear understanding, the process becomes manageable. This article aims to shed light on the major contract reporting requirements for all government contracts.
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
The National Defense Authorization Act (NDAA) for Fiscal Year 2022 and 2023 permanently authorized the Department of Defense (DoD) “to acquire innovative commercial products and commercial services through a competitive selection of proposals resulting from a general solicitation, known as a commercial solutions opening (CSO).” On August 17, 2023, the final rule was published in the Federal Register under DFARS Case 2022-D005 changing several parts of the DFARS – with most of the changes within DFARS part 212.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)
In the world of federal contracting, every detail matters. A recent ruling by the Court of Federal Claims (CFC) has highlighted the critical importance of maintaining an active registration in the SAM.GOV System. Based on the interpretation of FAR Clause 52.204-7, this ruling underscores the fact that even a minor lapse in a contractor's SAM registration status can lead to disqualification from a potential award.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, Federal Acquisition Regulation (FAR)
The Department of Defense is proposing a change to the Defense Federal Acquisition Regulation Supplement (DFARS) that would consolidate four existing Government property clauses into a single clause. The requirements of the four clauses are not going away but are being simplified to help both contractors and Government personnel in dealing with the requirements of Government property, in particular Government-Furnished property (GFP).
Topics: Contracts & Subcontracts Administration, Government Property Management, Federal Acquisition Regulation (FAR)
Indefinite Delivery Indefinite Quantity (IDIQ) contracts often look like a big money opportunity for contractors – but looks can be deceiving. Many IDIQs are multi-awards, meaning you are just one of many contractors that may get task orders awarded under the contract. On top of that, the required minimum the Government must buy under the IDIQ is, in most cases, very low. So, it turns out that millions of dollars of anticipated business fizzles down to $2,500 – which may have a shocking impact to your return on investment.
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
April 25, 2023; the Court of Appeals agreed with the Armed Services Board of Contract Appeals (ASBCA) that a contractor cannot take a unilaterally established Undefinitized Contract Action (UCA) to the Board without first submitting a certified claim request for a final decision by the contracting officer.
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
So, the Defense Contract Agency Audit (DCAA) auditor comes into your office, performs an audit, and…they have findings. What do you do? Wait…is there something that I should not do?
Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)