Redstone Government Consulting Blog | Government Compliance Training

Training and employee development, in our opinion, must be looked at as a necessary investment in the future of a business as well as the business’ key resource - its employees. That said, those businesses in the government contracting industry are also facing an ever-expanding list of required or at least expected training that is necessary to maintain compliance with their growing list of contract clauses.

Contract Requirements and Expectations for Training

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources, Federal Acquisition Regulation (FAR), Organizational Change Management Consulting

The Office of the Under Secretary of Defense, Defense Pricing and Contracting (DPC) issued a guidance memorandum dated March 18, 2024 to Agencies based on the results of the Department of Defense (DoD) Inspector General (IG) Audit of DoD Compliance on Whistleblower Protection Requirements. While the DoD IG found in most cases, that Contracting Officers included the DFARS 252.203-7002 Requirement to Inform Employees of Whistleblower Rights clause in contracts, they did not verify whether contractors were complying with the clause.

Topics: Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

Implementing the proper human resources information systems (HRIS) brings many benefits to HR teams and the businesses they support. These benefits may include automating processes, efficient talent acquisition, effective employee management, proper time tracking, increased employee engagement, and more. Poor execution of the implementation can create havoc, causing frustration, confusion and a lack of employee engagement. Improper security assignments will cause employees to see the information they shouldn't or managers to be unable to see what they should. In worst cases, employees may not get paid correctly or at all if a system is not setup properly and thoroughly tested. These are just some of the issues that could result from not choosing a partner who is dedicated to knowing your business needs and minimizing the challenges as much as possible. Some complications are expected, but the right partner will find a way to navigate or even avoid them effectively. We utilize the UKG Ready HRIS solution for HR, Payroll, and Timekeeping at Redstone Government Consulting, as we find it can fully meet our clients' needs, not only for our Federal Government Contractor clients but also for any clients looking for a full-suite solution.

Topics: Government Compliance Training, DCAA Audit Support, Human Resources, UKG Ready HR Software Consulting

Current and accurate timekeeping is one of the most important responsibilities of a contractor and its employees when they have Government cost reimbursement and time and material/labor hour contracts. Direct labor is one of the significant elements of cost incurred and billed on Government contracts. FAR 16.301-3(a)(3) requires contracting officers to ensure a contractor has an adequate accounting system, which includes a timekeeping system, before award of a cost reimbursable contract. While there is no specific reference to an adequate timekeeping system for T&M/Labor hour contracts, FAR 52.232-7 requires the contractor to be able to support the hours and labor qualifications of the employees charged to the contract. Auditors will request documentation to support employee qualifications and labor hours on T&M/Labor hour contracts. An adequate timekeeping system includes having a written timekeeping policy and procedure to ensure the accuracy and integrity of direct labor costs charged and billed to Government contracts.

Topics: Compliant Accounting Infrastructure, Government Compliance Training, DFARS Business Systems, DCAA Audit Support

On August 9, 2023, DCAA issued guidance to its auditors revising the real-time labor and material testing requirements. DCAA historically referred to these procedures as Mandatory Annual Audit Requirements (MAARs) 6 and 13. DCAA states in its guidance what its auditors need to know is that “[l]abor and material are two of the most significant cost elements billed under government contracts. As such, one of the primary reasons … [DCAA] audit[s] labor and material costs incurred is to determine the accuracy of the charges. The real-time verification of these costs as they are incurred provides valuable confirmation of the accuracy of the charges and can only be accomplished during the accounting period to which they apply.” I cannot really argue with this statement.

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources

In August of 2023, the Defense Contract Audit Agency (DCAA) changed what is used to refer to as Mandatory Annual Audit Requirements (MAARS) 13 audits to Real-Time Audits of Purchase Existence and Consumption. This change was to eliminate the mandatory part of the requirement and introduce greater flexibility based on the auditor’s risk assessment of the contractor.

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources

In August of 2023, the Defense Contract Audit Agency (DCAA) changed what it called Mandatory Annual Audit Requirements (MAARS) 6 audits to Real-Time Audits of Labor. This change was to eliminate the mandatory part of the requirement and introduce greater flexibility based on the auditor’s risk assessment of the contractor.

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources

Mandatory Annual Audit Requirements (MAARs) 6 (labor) and 13 (material purchases) are two of DCAA’s mandatory annual audit requirements performed for incurred cost audits. These MAARs, established decades ago, have customarily been performed on a “real-time” basis within the year in which the costs were incurred. However, DCAA has recently revised their audit guidance in a Memorandum for Regional Directors (MRD) titled “Revised Procedures for Real-Time Audits of Labor and Purchase Existence and Consumption.”

Topics: Compliant Accounting Infrastructure, Small Business Compliance, Government Compliance Training, DCAA Audit Support, Government Regulations

In late 2008, the Final Rule on Contractor Code of Business Ethics and Conduct (“CoBEC”) was added to FAR Part 3 (Improper Business Practices and Personal Conflicts of Interest) in response to the heightened focus on increased lapses in corporate ethical behavior. FAR Subpart 3.10 sets forth guidance for all contractors with regard to enhanced ethical and compliance standards and requires the insertion of the clause at FAR 52.203-13 in solicitations and contracts if the value of such contract is expected to exceed $6 million, and the performance of which is 120 days or longer. DCAA focuses on compliance with FAR 52.203-13 when conducting accounting system audits.

Topics: Government Compliance Training, Human Resources, Federal Acquisition Regulation (FAR)

Throughout this series, we’ve explored the fundamentals of compliance with the regulations administered by the Office of Federal Contractor Compliance Programs (OFCCP) and many of the components of a written Affirmative Action Plan. In this final blog of the series, we will answer a question frequently asked of us…What do you do with all this information?

Topics: Government Compliance Training, Human Resources, Office of Federal Contract Compliance Programs