On May 1, 2025, the National Institute of Health (NIH) issued NOT-OD-25-104 updating its policy to reiterate the Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. This policy change will also prohibit foreign subawards in grants and cooperative agreements effective May 1, 2025, until NIH has developed a new foreign collaboration award structure policy. NIH is hoping to issue its new policy by September 30, 2025.
Topics: Compliant Accounting Infrastructure, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
On May 8, 2025, Department of Energy (DOE) issued three new policy flashes limiting the indirect costs on DOE grants to state and local government, for non-profit organizations and for-profit companies. DOE previously limited indirect costs for colleges and universities (i.e., Institutes of Higher Education) in its April 11, 2025 policy action.
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
While import tariffs may seem unfamiliar due to historically low rates in recent decades, they have long played a significant role in U.S. economic policy-serving purposes such as revenue generation, industry support, and protectionism. Historically, high tariffs have often coincided with periods of economic and political instability, whereas lower tariffs have typically supported international engagement and economic growth. Since World War II and the creation of GATT and the WTO, the U.S. has generally maintained lower average tariff rates.
Topics: Contracts & Subcontracts Administration, Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
President Trump issued several executive orders addressing tariffs. American First Trade Policy dated January 20, 2025 and Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment dated April 9, 2025. In addition, he has also issued a 90-day pause to some countries and is planning to reduce tariffs on certain industries such as US auto tariffs (see Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States dated April 29, 2025). It is clear that tariffs are impacting the supply chain and government contractors.
Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting
The Government Accounting Office (GAO) issued a Report, Recent Guidance Could Enhance Subaward Oversight to the Senate dated March 26, 2025 (GAO-25-107315), on its review of subaward oversight based on requirements in 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Grants. While prime recipients have responsibility over subawards, federal agencies are required to ensure recipients carry out oversight responsibilities.
Topics: Compliant Accounting Infrastructure, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
One would think this is a straightforward calculation. However, nothing is that straightforward when it comes to applying the Federal Acquisition Regulations (FAR) cost principles in FAR part 31.
Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Well one of the endless numbers of administratively burdensome requirements the Federal Government places on your contracts may just be the silver bullet you need. Review your contracts and look for FAR 52.225-8, Duty-Free Entry, and DFARS 252.225-7013, Duty-Free Entry.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Federal Acquisition Regulation (FAR)
On April 11, 2025, the Department of Energy (DOE) announced a new policy action to limit indirect costs of DOE research funding to Institutes of Higher Education (IHE) to 15%. DOE projects this change to generate over $405 million in annual savings. As expected, a judge has issued a Temporary Restraining Order (TRO) on this policy. This comes on the heels of the National Institute of Health (NIH) issuing Supplemental Guidance to the 2023 NIH Grants Policy Statement: Indirect Costs dated February 7, 2025, limiting indirect costs on current and future grants to 15%. A Temporary Restraining Order (TRO) is still outstanding on the NIH policy.
Topics: Compliant Accounting Infrastructure, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)
Late yesterday, President Trump signed another Executive Order related to employment laws. This Executive Order (“Restoring Equality of Opportunity and Meritocracy”) takes aim at the use of “disparate impact liability,” which, the EO proclaims, “undermines our national values [and] also runs contrary to equal protection under the law and, therefore, violates our Constitution.”
Topics: Litigation Consulting Support, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act
President Trump has signed several Executive Orders (EO) addressing ways to improve the acquisition process through simplifying the regulations, utilizing competitive marketplace and commercially available products and services, consolidating procurements at General Services Administration (GSA), and now overhauling the Department of Defense acquisition processes.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination