Cost Accounting for The Federal Risk and Authorization Management Program (FedRAMP)

If you want to provide cloud-based services to Federal Agencies, you will need to get your service approved through the Federal Risk and Authorization Management Program (FedRAMP) managed by the FedRAMP Program Management Office.

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

DPC Issues Guidance to DoD for Lack of Verifying Contractor Compliance with Whistleblower Protection Requirements

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.

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

Cost Accounting Standard (CAS) 420 – Accounting for IR&D Costs and Bid & Proposal B&P Costs

Cost Accounting Standard (CAS) 420 outlines accounting standards for Independent Research and Development (IR&D) and Bid & Proposal (B&P) costs incurred by government contractors, ensuring consistent and transparent reporting.

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

Overview of Contract Types and What Government Contractors Need to Know

Have you ever thought about the different government contract types and how it impacts your company’s bottom line: profit? Does it really matter what type of government contract that you have? Do you know what oversight there may be required of a particular contract type? Knowing and preparing for each type of contract, prior to accepting any government contract, will directly impact your administrative cost and profitability as well as the amount of government oversight. In this article, I will discuss the contract types and how significantly different they are, and your risk associated with these contract types.

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

Rights and Obligations of Employers and Unions

We understand that it can be tough to learn that your employees are planning to unionize, despite your efforts to create a fair and safe work environment. We know that you want to do your best for your employees and your company. While labor unions have been declining over the years, there is a resurgence of union organization as many believe that unions have been instrumental in establishing employee rights and conditions. That's why it's important to understand your rights and obligations as an employer and those of a union.

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Topics: Human Resources, Government Regulations, Employers and Unions

What Should I Do Now that the Government Has Terminated My Contract?

The government can terminate a contract, in whole or in part, through special contract clauses referred to as "termination clauses." Contract termination can happen for reasons such as lack of funding, bid protests, changes in military strategy, technological advancement, federal operations, or national political agenda that change the government's needs. However, what are the different types of termination proposals and forms required? This article will sort out the maze of what needs to be done and submitted.

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

Is It Time for the FAR Council to Consider Changing How Contracts are Audited?

Current FAR Requirements

Federal Acquisition Regulations (FAR) 42.101 provides that normally, “the Defense Contract Audit Agency (DCAA) is the responsible Government audit agency.” While DCAA’s website states “DCAA provides audit and financial advisory services to DoD and other federal entities responsible for acquisition and contract administration.” DCAA only has appropriated funds to provide services to the Department of Defense (DoD). All other federal agencies must pay for DCAA services. This can make a decision related to the necessity of an audit service a budget-based decision. Today, DCAA is current on the required incurred cost audits of contractors with DoD contracts, but contractors with mostly National Aeronautics and Space Administration (NASA) contracts are years behind in their required incurred cost audits. If, as the FAR states, “DCAA is the responsible Government audit agency,” why is it not a Federal audit agency (dare we say – FCAA)? This would make things much easier for NASA and other federal agencies that need their contracts audited. However, given that this isn’t the case, DCAA is not the only option for federal agencies. Many agencies other than DoD have contracted with third-party CPA firms to get necessary audits performed.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

Cost Accounting Standard (CAS) 408 - Accounting for Costs of Compensated Person Absence

Cost Accounting Standard (CAS) 408 was put in place to provide consistency in the measurement and allocation of vacation, sick leave, holiday, and other compensated personal absences. Today, many contractors refer to all paid time off as “PTO.”

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

DoD Creates Confusion Related to Commercial Subcontracts

In November of 2023, DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to partially implement a section of the 2017 National Defense Authorization Act (NDAA) addressing the Federal Acquisition Regulations (FAR) and DFARS contract clauses impacting prime or higher-tier contractors issuing commercial subcontracts for commercial products, including commercially available off-the-shelf items, and commercial services.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Service Contract Act, Commercial Item Determination

What is Really Important to Know About FAR Part 31?

Government regulations can be complex and perhaps even confusing. For those of you experienced in Government contracts and even contract audits, you have heard of the Federal Acquisition Regulation or FAR and, FAR Part 31, Contract Cost Principles and Procedures. The scope of this part describes the applicability of the cost principles and procedures in pricing and accounting for costs on contracts, subcontracts, and modifications whenever cost analysis is needed. There is a lot there, but what’s really important? Well, I will not try to duplicate what can be at least a day course within this blog, but I will highlight three areas that are really important.

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