The last blog in this series focused on who (what) OFCCP is, what they require of contractors of various sizes and why compliance is important. Now we want to provide a bit more clarity as to what these requirements are and later in the series, how those requirements impact your processes and policies.
Topics: Government Compliance Training, Human Resources, Office of Federal Contract Compliance Programs
As mentioned in a previous blog, OFCCP’s Contractor Portal, we are kicking off a blog series related to OFCCP and Affirmative Action requirements for contractors of all sizes. We begin this series by laying the groundwork of who (or what) OFCCP is and what affirmative action is. This series will focus on supply and service contractors; however, construction contractors may also find it helpful. Regardless of the type of contractor, our HR Team is available to assist with all of your OFCCP compliance and Affirmative Action Program (AAP) needs.
Topics: Government Compliance Training, Human Resources, Office of Federal Contract Compliance Programs
On July 9th, 2021, the Department of Defense (DoD)issued a final rule in the Federal Register to implement 10 U.S.C. 2330a which requires the DoD to establish a data collection system to provide certain management information about an awarded contract or task order that is valued in excess of $3 million. This new rule is applicable for the following service acquisition portfolio groups:
You may read the entire rule here.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, System Award Management (SAM), Government Regulations
The focus of fraud used to be primarily on defense contractors, health care providers and health care suppliers. However, other companies are now being exposed to the Federal Claims Act (FCA) including software companies, private equity financiers, insurance companies, and educational institutions. Additionally, fraud is not just related to companies receiving the funds.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DOD IG, Government Compliance Training, Paycheck Protection Program (PPP) Loans
DCAA Auditor Training
DCAA website provides that new auditors receive in-depth professional training from DCAA’s Defense Contract Audit Institute (DCAI), along with on-the-job training at their assigned field audit office. DCAI is located in Atlanta, GA and provides auditors with an excellent basis on which to start their careers in contract audit. Many at Redstone GCI can speak from personal experience that, once you get past the exciting MARTA ride from the airport, the instructors at DCAI provide a good hands-on learning environment. However, we are not sure if it is a subliminal message piped into the classroom or local indoctrination at assigned field offices, but the auditors are coming away with the impression that no contractors can be trusted, and a good audit opinion has to include questioned cost.
Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DOD IG, Government Compliance Training, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
You’re probably not feeling quite like THIS about training, but we do want to remind you of a few topics that you, as a federal government contractor, need to address with your workforce on a fairly regular basis. We can’t hit them all, but this is a list of those that should be on the radar of your Human Resources staff and are relevant to most contractors.
Topics: Contracts & Subcontracts Administration, Government Compliance Training, Human Resources, Office of Federal Contract Compliance Programs
FAR Part 31, Cost Principles, is the regulation that government contractors must follow in order to account for cost on most government contracts. Within FAR Part 31 is FAR 31.205, Selected Costs. This part of the cost principles regulation specifically spells out unallowable cost that the government will not pay for under a government contract. This section starts at FAR 31.205-1 and goes all the way up to FAR 31.205-52. However, it should be noted that FAR 31.205-2, 5, 9, 24, 45, and 50 are “Reserved” – These reserved cost areas went the way of the dinosaur over time, hopefully not to return. For example, FAR 31.204-2, Automatic Data Processing Equipment Leasing Costs, required an annual demonstration that leasing computer equipment was cost-effective, i.e., lowest cost to the Federal Government.
Topics: Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Timekeeping compliance is a combination of several critical pieces, involving everyone within an organization. With specific requirements for government contracts, it is crucial to develop a structure and process for timekeeping and compensation in government contracts. Here are some considerations when reviewing your company’s timekeeping compliance:
Topics: Government Compliance Training
The objectives of a timekeeping system are to ensure that labor costs are accurately and timely identified as either direct or indirect in the accounting system. For certain contract types (e.g. cost-type), these accumulated labor costs are reported and billed to the customer. It is the contractor’s responsibility to ensure that the labor costs posted in the timekeeping system are proper and reliable.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Human Resources
Are you prepared for a compliance evaluation from the Office of Federal Contract Compliance Programs (OFCCP)? If you’re a government contractor or subcontractor, you likely need to be. The OFCCP is under the umbrella of the Department of Labor and their goal is to “protect workers, promote diversity and enforce the law.” OFCCP administers the following laws, all of which are specific to government contractors:
Topics: Contracts & Subcontracts Administration, Government Compliance Training, Human Resources, Office of Federal Contract Compliance Programs
