The FAR Council issued an interim rule, effective December 4, 2023, which implements the requirements of the Federal Acquisition Supply Chain Security Act (FASCSA). This included three new FAR clauses which prohibit the delivery or use of “covered articles” subject to a FASCSA order in the performance of a government contract.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting
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: Accounting System Compliance, Small Business Compliance, Government Compliance Training, DCAA Audit Support, Government Regulations
New Rule for Filing 1099s: The IRS rule TFA 23O1 reduces the electronic filing requirement from a threshold of 250 Information Returns down to 10.
Yes, you read that correctly. If you file more than 10 Information Returns after January 1, 2024, you are now required to submit those forms electronically. Employers must calculate the total number of Information Returns to determine if they meet the threshold, including 1099s, W-2s, 1098s, etc.
This means if you have a total of 4 Form 1098s and a total of 6 Form 1099-NEC, you must file electronically. All forms must be submitted to the appropriate party and through the IRS site utilizing IRIS or the “Information Returns Intake System” by the due date.
Topics: Accounting System Compliance, Government Regulations, Deltek Costpoint
My commercial company wants to increase business with the Federal Government – but not with all those requirements the Government follows when buying under FAR Part 15 rules (Contracting by Negotiation). Is that even possible? The answer is “absolutely”.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
The FACT SHEET issued by the White House on November 8, 2023 professes the four underlying initiatives “will generate more than an additional 10 billion annually in savings and cost avoidance while improving the performance of Federal contracts.” Seeing as it also states, “[l]ast year alone, the Federal Government purchased $700 billion of goods and services,” – this 1.5% saving would be a good start. So, let’s take a look at these initiatives.
Topics: Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
Contractors are required to keep their System of Award Management (SAM) registration up to date. FAR 52.204-7(b)(1) requires an offeror to be registered in the System of Award Management (SAM) when submitting an offer/quote, registered until the time of award, during performance, and through final payment. Sounds pretty easy. However, contractors are not always registering or updating their registration, resulting in ineligible awards, as noted in recent court cases (See our blog: SAM Registrations: Check Often and Never Let it Lapse!).
Topics: Contracts & Subcontracts Administration, System Award Management (SAM), Government Regulations
The Defense Contract Audit Agency (DCAA) issued a memorandum to its leadership – and ultimately its auditors in the field – addressing a revision to its audit guidance related to the audit of contractor cost impact calculations for unilateral cost accounting practice changes (23-PAC-009(R) Revised Audit Guidance on the Cost Impact Calculation for a Unilateral Cost Accounting Practice Change – dated October 3, 2023). Well, it is about time.
Topics: Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)
Most contractors that have contracts/subcontracts subject to full CAS coverage will eventually want to make a change to a cost accounting practice because there is a “better” allocation method or a change is required to remain in compliance with CAS.
Topics: Accounting System Compliance, Government Regulations, Cost Accounting Standards (CAS)
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.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Human Resources, Contractor Purchasing System Review (CPSR), Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance
Suppose your company is working on a grant or cooperative agreement or planning to submit a proposal in response to a funding opportunity announcement. In that case, the regulations that apply will be Code of Federal Regulations (CFR) Title 2 Grants and Agreements. The problem is, when you receive a grant, generally, the award agreement says to comply with 2 CFR. There are no specific clauses or wording; basically, you are responsible for reading the entire regulation to see what applies to your award. 2 CFR includes inconsistent language and terms.
Topics: Government Regulations, Cost Accounting Standards (CAS), Grants & Cooperative Agreements (2 CFR 200)