The FY 2026 NDAA changed how fixed price contracts are treated in Cost Accounting Standards (CAS) cost impacts, but timing remains critical. Government contractors with CAS covered awards issued before implementation may still face current clause requirements, making award dates and clause language important compliance considerations.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
Project health depends on more than customer satisfaction and technical performance. Government contractors also need healthy margins, efficient reporting, reliable billing support, and clear contract closeout documentation. Strong alignment between the project structure and the Contract Line Item Number (CLIN) structure improves reporting, visibility into key metrics such as remaining funding, billing support, and contract closeout effectiveness. These elements help support audit readiness and more efficient project management processes.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, Unanet, Organizational Change Management Consulting, Program Management & Project Cost Control
Reporting of Independent Research and Development (IR&D) projects on the Defense Technical Information Center (DTIC) portal is normally due no later than three months after the contractor’s fiscal year-end, both annually and upon project completion. However, the DTIC portal was offline from November 2025 until approximately April 20, 2026, due to cyber vulnerabilities. Despite the nearly six‑month outage, Defense Pricing, Contracting and Acquisition Policy (DPCAP) has provided contractors just over 30 days, until May 31, 2026, to enter all required IR&D information, including new projects, annual updates, and closed projects. This accelerated timeline contrasts with the DFARS allowance of up to three months after the fiscal year-end for reporting.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, Defense Procurement & Acquisition Policy (DPAP), Government Regulations, Federal Acquisition Regulation (FAR)
Incurred cost submission preparation often exposes problems that never surfaced during regular monthly accounting. A contractor can have a full year of QuickBooks data, a complete set of financial statements, and detailed job cost records, and still find that the information is not organized or consistent enough to support the annual submission process cleanly.
This is not an uncommon situation, and it matters most for contractors performing cost reimbursable work. The assumption that recorded data equals ready data is a costly misunderstanding in government contractor accounting.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Quickbooks
Issues related to the disconnect between contracts management, project management, and accounting teams have been a topic I’ve needed to address recently with many of the customers I work with. Partially caused by disconnected systems and partially by siloed teams, issues between these teams cause significant breakdowns in maintaining an acceptable profit margin, accurate reporting for incurred cost submissions and contract close-out, and ultimately, healthy cash flow for the organization.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, Unanet, Organizational Change Management Consulting, Program Management & Project Cost Control
OMB’s new guidance directs agencies to expand commercial acquisitions and justify non-commercial awards. Government contractors may see closer review of commerciality, pricing, option periods, and cost-reimbursement contracts, making support for market research and contract decisions more important.
Topics: Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting
On April 20, 2026, the Defense Contract Audit Agency (DCAA) announced yet another reorganization: a transition to 23 “hub” organizations while maintaining office locations at key defense contractor sites. This reduction reduces the 180 office (branch and suboffices) locations to 23 hubs covering only 19 of the 50 states in the continental U.S.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting
The launch of the CAPE (Consolidated Administration and Processing of Entries) system by U.S. Customs and Border Protection marks a significant opportunity for importers to recover duties previously paid under IEEPA tariffs that were later ruled invalid by the U.S. Supreme Court. By enabling consolidated refund claims and streamlining the process through the ACE portal, this program reduces administrative burden and accelerates reimbursement. For importers, especially small businesses that directly paid these tariffs, this development is highly relevant because it provides a time-sensitive pathway to reclaim costs, improve cash flow, and correct past overpayments in a changing tariff environment.
Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
DCAA recently released Version 1.04 of the ICE Model that utilizes Microsoft Power Query to prepare incurred cost proposals. For government contractors preparing annual incurred cost submissions with Microsoft Power Query, this update should be used in replacement of the previous version released. Both the April 2026 Power Query version and the May 2019 Visual Basic version remain available, but each version carries different considerations for preparation, review, and submission through the Contractor Submission Portal.
The updated Power Query version is intended to improve compatibility with contract information such as contract ceiling issues on Schedule I. The instructions have been revised to provide better clarification of information required to properly run the power query version. The original Visual Basic version remains available, but contractors using this version need to be aware of a specific restriction in the Contractor Submission Portal. Files prepared in the Visual Basic version must be saved as .xls or .xlsx before uploading to the Contractor Submission Portal. The Contractor Submission Portal will not accept .xlsm macro files.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)
On March 26, 2026, President Donald J. Trump signed an executive order (EO) titled, "Addressing DEI Discrimination by Federal Contractors." The order establishes new mandatory contract clause requirements for federal contractors and subcontractors at all tiers, creates reporting and monitoring obligations, and designates noncompliance as material under the False Claims Act (FCA). Federal agencies are required to incorporate the new clause into contracts and contract-like instruments by April 25, 2026. The EO applies to federal contracts, subcontracts, and contract-like instruments subject to the Federal Property and Administrative Services Act (40 U.S.C. § 101 et seq.).
Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting
