Maintaining Adequate Policies and Procedures for Government Contracts

Maintaining Adequate Policies and Procedures for Government Contracts - Redstone gci

On December 18, 2018 the Administrative Judge, in ASBCA No. 61583, denied the contractor’s appeal and granted the Government’s request for summary judgement related to the contractor’s claim that it was entitled to a penalty waiver because the contractor did not demonstrate that it “had adequate policies, training, controls, and review systems, and that it inadvertently incorporated the [unallowable cost]” in its incurred cost proposals. This decision serves as a reminder of the importance of maintaining adequate policies and procedures.

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Topics: Contracts & Subcontracts Administration, Government Regulations

Government “Forgive & Forget”—Not Likely Applicable to FAR 52.242-3 Penalties

Government “Forgive & Forget”—Not Likely Applicable to FAR 52.242-3 Penalties - Redstone gci

A recent ASBCA decision (No 61583) confirms that Government benevolence does not extend to penalties associated with a contractor’s final indirect cost rate proposal (FICRP) which included expressly unallowable indirect costs. In one case, the issue was unallowable legal costs incurred as a result of the US Department of Justice (DOJ) investigation of the contractor, which was triggered by information suggesting that the contractor claimed indirect salaries for an individual whose services were as the housekeeper for the owners of the company and thus unallowable as costs allowable to Government contracts. 

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Topics: Small Business Compliance, Government Regulations

Do I Need to Register My Company with the DDTC under the ITAR?

Do I Need to Register My Company with the DDTC under the ITAR? - Redstone gci

Did you know that The International Traffic in Arms Regulations affects more than just exporters? You may need to register with the Directorate of Defense Trade Controls even if you do not export.

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Topics: Government Regulations, Export & Import

Employee Stock Ownership Plans, Cost Allowability and DCAA Audit Risks (Part II)

Employee Stock Ownership Plans, Cost Allowability and DCAA Audit Risks (Part II) - Redstone gci

We have received a number of inquiries from clients related to cost allowability for Employee Stock Ownership Plans (ESOPs). In this Part II, we focus on the cost allowability rules and regulations for government contractors (Part I provided a more general description of ESOPs).

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

Employee Stock Ownership Plans (ESOP) and Government Contracting (Part I)

Employee Stock Ownership Plans (ESOP) and Government Contracting (Part I) - Redstone gci

Updated May 19, 2025

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Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)

DCMA and the Upcoming “Business Systems Tsunami”

DCMA and the Upcoming “Business Systems Tsunami” - Redstone gci

The simple English Wikipedia encyclopedia defines a Tsunami as “a series of fast moving waves in the ocean caused by powerful earthquakes or volcanic eruptions”. Arguably one can equate negative DOD Inspector General Reports to powerful earthquakes or volcanic eruptions at least to those organizations in the path of these Government oversight tidal waves. What tidal waves you may ask? Well, let’s look at two recent reports from the DOD IG very critical of DCMA; Report No. DODIG-2015-139 and Report No. DODIG-2016-001.  

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Topics: DFARS Business Systems, Government Regulations

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