Indirect Rates for Grants and Cooperative Agreements

You are putting together a proposal in response to a Funding Opportunity Announcement (FOA) for a grant or cooperative agreement. It’s pretty simple. Just estimate direct labor, equipment, other direct costs, and my indirect rates. Correct? Well, maybe, but your indirect rates can be complex.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)

Subcontractors Can Request the Nontraditional Defense Contractor Exception

The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a Memorandum dated May 5, 2024, to Agencies on the Treatment of Nontraditional Defense Contractors.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

When to Request a Consent to Subcontract If You Don't Qualify for a Purchasing Review

Probably now. Depending on the type and dollar amount of your subcontracts, FAR 52.244-2 Subcontracts clause requires a contractor that does not have an approved purchasing system (never been reviewed or is disapproved) to obtain written consent from the Contracting Officer before subcontract award.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

The CAS Board is looking to Drop Cost Accounting Standards (CAS) 408 and 409

In the June 27, 2024 Federal Register, the Cost Accounting Standards Board (CASB) put out a notification that it was looking for input on its efforts to conform Cost Accounting Standards (CAS) to Generally Accepted Accounting Principles (GAAP) for Compensated Personal Absence (CAS 408) and Depreciation of Tangible Capital Assets (CAS 409). Back in March of 2019, the CASB published a Discussion Paper to collect initial input on the need for CAS 408 and 409 based on the changes that had been made to GAAP since the 1970’s.

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Topics: Compliant Accounting Infrastructure, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

DFARS Final Rule on Commercial Products Procured Under Major Weapon Systems

DoD issued a final rule DFARS Case 2023-D010 on May 30, 2024, amending The Defense Federal Acquisition Regulation Supplement (DFARS) implementing Section 803 of the National Defense Authorization Act on data required in support of commerciality determinations and price reasonableness under procurements for major weapon systems. The purpose is to provide additional guidance related to the data required to support a request for a commercial determination and the price reasonableness process.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

DoD Implementing the Congressional Direction to Align DFARS with GAAS

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.

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Topics: Small Business Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Cost Accounting Standard (CAS) 409 - Depreciation of Tangible Capital Assets

Cost Accounting Standard (CAS) 409 provides the criteria for assigning costs (i.e., depreciation) of tangible capital assets to cost accounting periods and allocating those costs to contracts in an objective and consistent manner.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, DFARS Business Systems, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Is Submitting Other Than Certified Cost or Pricing Data Risk-Free?

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

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

Cost Accounting Standard (CAS) 404 - Capitalization of Tangible Assets

CAS 404 provides the criteria for determining whether to assign the cost of a capital asset as a period expense when acquired or capitalize the item as a tangible asset and spread the cost over two or more accounting periods.

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Employee Stock Ownership Plan (ESOP) is the Gift That Keeps on Giving

Besides the potential tax benefits of an Employee Stock Ownership Plan (ESOP), the National Defense Authorization Act (NDAA) for Fiscal Years 2022 and 2024 has introduced an additional benefit for employee-owned businesses contracting with the Department of Defense (DoD). A pilot program that will allow for the award of follow-on contracts without competition.

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Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)