IMPORTANT UPDATE: DoD Simplifies Government Property Clauses

Last year, we wrote about the Department of Defense (DoD) proposing a change to the Defense Federal Acquisition Regulation Supplement (DFARS) that would possibly simplify Government property clauses by consolidating four clauses into a single management clause. This became a reality in December 2023 when the DoD issued a final rule consolidating the four clauses into DFARS 252.245-7005, Management and Reporting of Government Property. The new clause had an effective date of January 22, 2024.

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

Avoid a Hefty Tax Bill with State Sales and Use Tax Exemptions on Government Contracts

Contractors need to understand the laws for applying state sales and use taxes to purchased goods and services on government contracts. It can be a costly mistake that eats away at your profit.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

What Policies and Procedures Should a Government Contractor Have?

If this were only a simple question. The most straightforward answer is that it is a good idea for any company to have policies and procedures. If that company is going to do business with the US Government those policies and procedures are going to have to be expanded as each contract may present additional requirements. To help you understand the complex level of requirements we will address the major business systems and other key areas.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR), Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR), Material Management and Accounting System (MMAS), Estimating System Compliance

Introduction to Government Property for Government Contractors

We have discussed recently how DoD has an increased interest in government property, especially the property that contractor’s control and maintain. RGCI has helped clients with government property issues more in the past four years than the previous ten years combined.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Property Management

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)

Department of Defense Has a Problem with Audits (Their Own)

The Department of Defense has failed an audit - five in a row, to be exact. Federal law mandates audits for all federal agencies, and until 2017, the Department of Defense was never able to satisfy this requirement. It is a very tall task – auditing an agency that controls over half of the discretionary spending in the United States. But in 2017, DoD underwent a financial audit for the first time. They did not pass, but that was never expected. There have also been audits each year since, and while the Agency has not yet passed an audit, it has improved each time.

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Topics: DFARS Business Systems, Government Property Management

ASBCA No. 61709 – A Cautionary Tale for Subcontractors with Government Property

On June 24, 2021, the Armed Services Board of Contract Appeals (ASBCA) opinioned that Intellicheck, Inc., a subcontractor, did not have privity of contract or even an implied-in-fact contract with the Government to allow for the recovery of costs incurred by Intellicheck, Inc. to maintain and store Government property after the completion of a Task Order for the Navy. A tale as old as time, the Government lets years go by before taking action to dispose of its property being held by a subcontractor. Then finds a legal out for not paying the costs the Government caused to be incurred.

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Topics: DFARS Business Systems, Government Regulations, Government Property Management

What to Expect During a Property Management System Analysis (PMSA)

A Government Property Management System Analysis (PMSA) can be a contractor’s first experience with Defense Contract Management Agency (DCMA). This video and article explain what to expect for a Government contractor’s initial PMSA – commonly known as a Government property audit. Join Jonas Clem as he discusses the essential aspects of a contractor’s first PMSA.

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Topics: Government Property Management, Vlog

Government Property and Subcontractor Control

We get lots of questions about Government property and how it should be handled with subcontractors. Remember, and it has been said over and over, the prime contractor is responsible for just about anything subcontractors do in support of a contract. And yes, that includes Government property requirements.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Government Property Management

Government Property Disposition: What is Abandonment?

The term abandonment seems to be a hot topic within government property (GP) circles for both contractors and government procurement professionals. Many more contractors are requesting abandonment as a method of disposition. But exactly what is abandonment? When can it be used? And is it a last resort for the government?

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Topics: Contracts & Subcontracts Administration, Government Property Management