Ok, finding some good is going to be a challenge. Let's start with the fact that the Defense Contract Audit Agency (DCAA) receives approximately 3,500 incurred cost proposals annually, but only audits around 500 of them. And even though DCAA is still auditing about 75% of the dollars submitted ($193B), only .3% is questioned ($760M), and only 31% of that is likely to be sustained by contracting officers. This comes from the DCAA Report to Congress for 2024.
See, we did find some good.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
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If only the Government made this an easy answer. There are some representations and certifications that you need to get from your subcontractors. However, many in both industry and the Government think the requirement for “Reps and Certs” flows down in all cases.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
I believe most prudent businesspeople would consider providing water and coffee to their employees and customers a reasonable business expense and consider it an allowable cost. Well, Defense Contract Audit Agency (DCAA) auditors are not most people and, in most cases, have little to no business experience, so they believe providing water and coffee is an unallowable cost.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Government contracts can be a great opportunity. They often come with stability, a steady income, and the chance to scale your business. But they also come with strings attached: a detailed set of rules and expectations, especially when it comes to your accounting. Unfortunately, many government contractors learn about those rules the hard way, which is after they’ve already made a mistake. In this article, we’ll walk through some of the most common accounting mistakes that can derail even experienced contractors, cost you money, or worse, jeopardize your contracts.
Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, DCAA Audit Support, Quickbooks, Government Regulations, Federal Acquisition Regulation (FAR)
Labor relations is not just an HR function; it truly is a core leadership responsibility. Suppose your team is a current union organization or considering unionization. In that case, your frontline managers have to be trained to interact with unions not just legally, but also strategically and respectfully. Having untrained managers can quickly escalate potential issues without realizing it. Here is a comprehensive guide to train managers on effective union interactions.
Topics: Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting, Employers & Unions
A while back, I wrote an article addressing the risk associated with submitting “other than certified cost or pricing data.” Nothing has changed. When you are requested to submit “data other than certified cost or pricing data,” it must be current, accurate, and complete as of the date of submission. However, you have no requirement to update the contracting officer after submission.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
What is collective bargaining? Collective bargaining is a collaborative process between employers and employees, where both sides work together to negotiate terms for a fair agreement that benefits both parties. Employees typically are represented by a union, and the goal is to ensure fairness and negotiate in good faith.
Topics: Human Resources, Government Regulations, Employers & Unions
In May of 2023, Ms. Jamie Brabston, Director and Legal Counsel at Redstone GCI, wrote an article addressing the Federal Acquisition Regulations (FAR) requirements expected of contractors receiving contracts for supplies and services from the federal government. These requirements are implemented through FAR 52.203-13, Contractor Code of Business Ethics and Conduct, which is included in contracts and subcontracts expected to exceed $6M, and the period of performance is 120 days or longer.
Topics: Contracts & Subcontracts Administration, Government Compliance Training, DFARS Business Systems, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200), Organizational Change Management Consulting
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)