Major Contract Year End Reporting Requirements for Government Contractors

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.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Commercial Solutions Opening – Looking to Bring New Entrants into the DoD Marketplace

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.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)

SAM Registrations: Check Often and NEVER Let It Lapse!

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.

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Topics: Small Business Compliance, Contracts & Subcontracts Administration, Federal Acquisition Regulation (FAR)

Is the DoD Simplifying Government Property Clauses?

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).

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Topics: Contracts & Subcontracts Administration, Government Property Management, Federal Acquisition Regulation (FAR)

Recent ASBCA Decision – Understand Just What You are Getting With an IDIQ Contract

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.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

Recent ASBCA and Court of Appeals Decisions Impacting Undefinitized Contract Actions


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.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

What to Do and Not to Do When DCAA Cites Findings Against Your Company


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?

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Labor Qualifications under Time and Material Contracts

All Time and Material (T&M) contracts with the Federal Government, even commercial ones under Federal Acquisition Regulations (FAR) part 12, have one big thing in common. That big thing is that all of the labor hours delivered must be performed by individuals meeting the labor qualifications specified in the contract. The Federal Government uses very strong language in its contract requirement related to this, stating the hours “will not be paid to the extent the work is performed by individuals that do not meet the qualifications.”

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Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

DCAA Audit Programs Impacting Small Business


Starting back in 2021, DCAA issued updates to its audit programs supporting the audit of incurred cost. Here are a few interesting things we noted in the updates.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

The Debt Ceiling – What Does It Mean to Government Contractors?

Does a Government default due to the debt ceiling result in a Government shutdown? Well maybe. It all depends on how the Government reacts or directs its contracting officers to react. A default is different than the – shall we say itnormalyes, we said it – Government shutdowns we have been dealing with for the past decade or so.

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Topics: Government Shutdown, Government Regulations, Federal Acquisition Regulation (FAR)