Well, our friendly DCAA auditors are back after the Government shutdown. On December 2, 2025, Defense Contract Audit Agency (DCAA) issued a memorandum to their auditors titled, “Actions Required for Assignment Due Dates Following Furloughs.”

Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

Well, of course, The Department of Defense (DOD) can. The three most common situations where DoD requires cost data on a fixed price contract are:

Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)

Recently, we conducted research related to some incurred cost audit findings for a client and came across an Armed Services Board of Contract Appeals (ASBCA) case that highlighted key information every contractor, especially small businesses, should know. The Technology Systems, Inc. ASBCA No. 59577 reads like a soap opera. It starts with some ups and downs. There were audit findings in Fiscal Year (FY) 2001, which the contractor and the Administrative Contracting Officer (ACO) negotiated. For FY 2002 to 2006, the contractor’s indirect rates were accepted as proposed. This was followed by relationship issues during the FY 2007 audit between the Defense Contract Audit Agency (DCAA) auditor and the contractor (No surprise to most of us). Then, a period of separation occurred, from FY 2009 to 2013, when DCAA decided that proposal pricing supporting new contract awards was the priority. During this time, the contractor’s FY 2007 incurred cost audit was shelved, along with significant potential questioned costs. Then, in an act of desperation, the ACO issued a Contracting Officer’s Final Decision (COFD) based on a DCAA memorandum for the FY 2007, which questioned costs to avoid the statute of limitations running out. Ok, enough of the soap opera, let’s go through the things you need to know.

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

A little background – On April 15, 2025, Executive Order 14275, Restoring Common Sense to Federal Procurement, was issued. The intent of this order was to make revolutionary changes to the Federal Acquisition Regulations (FAR) to make the federal acquisition process more efficient and cost-effective. Section 2 states, “It is the policy of the United States to create the most agile, effective, and efficient procurement system possible. Removing undue barriers, such as unnecessary regulations, while simultaneously allowing for the expansion of the national and defense industrial bases is paramount. Accordingly, the FAR should contain only provisions required by statute or essential to sound procurement, and any FAR provisions that do not advance these objectives should be removed.”

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination

Are you interested in learning how to set up and manage labor categories in Unanet to improve project management, timekeeping, and labor cost compliance for government contractors? Labor categories are critical for organizing and tracking work performed on contracts, especially on Time & Materials (“T&M”) contracts. While cost type and fixed price billing may not require a labor category for billing purposes, they can still play an important role in project management and budgeting at the contract level. In accounting systems like Unanet, these categories classify time into roles such as Project Manager or Senior Software Developer that are tied to billing rates, simplifying T&M billing. Unanet also provides flexibility in how labor categories are derived, allowing setup at the admin/master level, project level, person level, or person-to-project assignment level. This adaptability ensures alignment with contract requirements regardless of how your business is structured.

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Unanet

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

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)

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

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)

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