COMPLIANCE UPDATE: New DCAA audit program for accounting system audits under DFARS 252.242-7006.

New DCAA audit program for accounting system audits under DFARS 252.242-7006 This new audit program appears a mix of prior accounting system subsystem audit programs (e.g., billing, labor, direct and indirect costs, etc.), the SF 1408 and the 18 specific DFARS criteria. The compensation system (one of the six subsystems) is not fully addressed in […]

Compliance Roundup – What Government Contractors Should Know – Compliance Updates to be aware of now and through 2018

Various federal agencies during the first half of 2018 have issued final and proposed rules or agency direction related to regulatory compliance requirements associated with U.S. federal government contracts. Specifically, the Department of Defense (DoD), the National Aeronautics and Space Administration (NASA), the General Services Administration (GSA), and the Office of Federal Procurement Policy (OFPP) […]

2018 Government Contract Accounting and Regulatory Update October 17-18, 2018

The Capital Edge Team invites you to the 2 for 1 Registration – 2018 Government Contract Accounting and Regulatory Update October 17-18. Register online and bring a colleague free. Reference promo code 2FOR1ARU2018.  October 17-18, 2018 The Westin Washington D.C. City Center Washington, DC $495 for two registrations!!!! *Register now and bring a colleague at no charge. Reference […]

UPDATE -Performance-Based Payments and Progress Payments (DFARS Case 2017-D019)

UPDATE to Proposed Rule by Defense Acquisition Regulations System on 09/10/2018 Performance-Based Payments and Progress Payments DFARS Case 2017-D019 Due in large part to the opposition voiced by Contractors and Industry Associations, the Department of Defense has rescinded the Department of Defense’s (DoD) supplement to the Federal Acquisition Regulation (DFARS) proposed rule that would have brought significant change […]

12 Essentials to a Successful DCMA Contractor Purchasing System Review

12 Essentials to a Successful DCMA Contractor Purchasing System Review By Stephen ‘Chase’ Kunk, J.D. – Vice President, Contracts & Procurement Chase Kunk of Capital Edge Consulting has considerable industry and consulting experience in supporting organizations through the CPSR process. His approach to purchasing system compliance has always been “one size does not fit all;” rather, […]

New System for Award Management (SAM) Registration

Important Notice Regarding New System for Award Management (SAM) Registration: The General Services Administration (GSA) has recently noted an increase in third-party fraudulent activity within SAM. GSA has launched an investigation into third-party registrations, deactivated affected SAM entity registrations, and advised the affected entities to validate their registration information in SAM, particularly their financial information […]

Common Preparation Pitfalls with the Final Indirect Cost Rate Proposal

Common Preparation Pitfalls with the Final Indirect Cost Rate Proposal Each year, Capital Edge works with numerous companies either developing, assisting with, or reviewing their final indirect cost rate proposals. The requirement to submit a final indirect cost rate proposal, more commonly referred to as the “ Incurred Cost Proposal or Incurred Cost Submission (ICS) […]

FY 2018 NDAA – House Section 874 (Engrossed)

The House version of the National Defense Authorization Act (NDAA) for fiscal year 2018 contains a provision (Section 874) to repeal contractors’ ability to utilize commercial auditors for purposes of auditing their annual incurred cost proposals.  Specifically, Section 874 of the 2018 NDAA would strike in its entirety subsection (f) of Section 820 of the […]

FY 2018 NDAA – Title VIII — Acquisition Policy, Acquisition Management, and Related Matters

December 12, 2017 President Trump signed the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2018. This signed legislation contains several notable provisions to introduce new or modify existing U.S. federal government contracting compliance requirements. Summarized below are some of the pertinent compliance requirements anticipated for change in the near term: Performance of Incurred […]

FY 2018 NDAA Change to Procurement Thresholds

On December 12, 2017, the 2018 National Defense Authorization Act (NDAA) was signed into law by President Trump. Title VIII of the NDAA contains many provisions designed to reduce burdensome regulation and improve the procurement process. Section 805, 806, and 811 would increase the Micro-Purchase Threshold (MPT) from $3,500 to $10,000, Simplified Acquisition Threshold (SAT) […]

Section 809 Panel Advisory Report – Section 2 – Contract Compliance and Audit

What was Reported? The Section 809 Advisory Panel, established under Section 809 of the National Defense Authorization Act (NDAA) for Fiscal Year 2016, issued January 31, 2018, their Volume 1 of 3 Report of the Advisory Panel on Streamlining and Codifying Acquisition Regulations (Report). The eight-section Report addresses various aspects of the Department of Defense (DoD) acquisition process […]

PSC Highlights Impact on Contractors as FY18 NDAA is Signed into Law

December 12, 2017 Arlington, V.A. (Dec. 12, 2017) – PSC today welcomed the president’s signing of the Fiscal Year 2018 National Defense Authorization Act (NDAA), which authorizes national security funding, provides policy direction, and significantly changes rules governing how contractors provide services and ensure mission success for the Department of Defense. “The FY18 NDAA has a […]

New Proposed Rule by the Veterans Affairs Department to revise or remove any policy that has been superseded by changes in the Federal Acquisition Regulation (FAR)

Revise and Streamline VA Acquisition Regulation To Adhere to Federal Acquisition Regulation Principles SUMMARY: The Department of Veterans Affairs (VA) is proposing to amend and update its VA Acquisition Regulation (VAAR). Under this initiative all parts of the regulation are being reviewed in phased increments to revise or remove any policy that has been superseded […]

GovCon Compliance Outlook: Sponsored Lunch and Learn Series

Join the Capital Edge Consulting GovCon Experts for the JAMIS Software sponsored GovCon Lunch and Learn Series. Participants will explore current regulatory updates and challenges confronting government contractors. With a new year and administration, come new opportunities as well as challenges. In the government contract regulatory compliance environment, transparency of the contracting process has gained considerable importance […]

Evaluating the Defense Contract Auditing Process

The Director of the DCAA and selected industry representatives testified April 6th in front of the House Armed Services Committee regarding the current state of the DoD contract auditing process, i.e., the DCAA.  Not surprisingly, the views of the DCAA and industry were quite opposing based on a read of the written testimony.  A high-level […]

Procurement University

Join Federal Publications Seminars and Capital Edge Consulting for a webinar series designed to enhance your knowledge over an 8-month span. Purchase FPSOnline Subscription for $595 and Procurement University is included. Participate through interaction with instructors who are experts in their field. Each session is 90 minutes. Earn CPE credits if you attend the live sessions* […]

Q1: Executive Actions and Regulatory Compliance Requirements Update

Executive Actions and Regulatory Compliance Requirements Update for Q1 2017 Craig Stetson, Managing Director, Capital Edge Consulting, Inc. The government has issued several rules (final, interim, and proposed) within the last few months, related to a variety of regulatory compliance requirements associated with U.S. federal government contracts. The Federal Acquisition Regulation Council (FAR Council) – […]

Report-10 Fastest Growing Areas in Government Contracting

Leading commerce intelligence in business-to-government (B2G) Onvia, released the third edition of its annual “10 Hotspots in Government Contracting” research ranking the fastest areas of growth in government contracting. Key Drivers: Efficiency, Safety, Functionality and Compliance Stimulate Demand Within the dynamic $2 trillion B2G marketplace, spending from state, local and education (SLED) agencies reaches around […]

CPSR 360: Part Two–Newsworthy CPSR Updates

By: Chase Kunk, Vice President, Contracts & Procurement and Michael Carter, Senior Consultant In December 2016, we released CPSR 360: Part One – Insights from Our Recent CPSR Experiences, which outlined several high-risk procurement file documentation areas we continue to see are a challenge for contractors. As expected, DCMA CPSR teams have been detecting these […]

CPSR 360: Part One of a Two-Part Series 

Part One – Insights from Our Recent CPSR Experiences Part Two (Coming Soon!) – Other Newsworthy CPSR Updates By: Chase Kunk, Vice President, Contracts & Procurement and Michael Carter, Senior Consultant The Defense Contract Management Agency’s (DCMA) Contractor Purchasing System Review (CPSR) Group continues to remain highly active in their ongoing pursuit of evaluating the […]

Contractor Purchasing System Review (CPSR) Expertise

Capital Edge Consulting CPSR experts have considerable industry and consulting experience in supporting organizations through the CPSR process. Our approach to purchasing system compliance has always been “one size does NOT fit all”; rather, make the public laws and regulatory requirements work for your business model and processes. This practical approach has become the cornerstone […]

10 Regulatory Compliance and DCAA Guidance Updates to be Aware of Now and Heading into 2017

What Government Contractors Should Know – 10 Regulatory Compliance and DCAA Guidance Updates to be Aware of Now and Heading into 2017 Craig Stetson, Managing Director, Capital Edge Consulting, Inc. The government has been busy in 2016 issuing final and proposed rules related to an array of regulatory compliance requirements associated with U.S. federal government […]

DOD Issues Final DFARS Rule on Network Penetration and Cloud Computing

WHAT: The Department of Defense (DOD) has adopted a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to require covered contractors to implement certain cybersecurity safeguards and report data breaches within 72 hours, adopting NIST SP 800-171 as the baseline for covered information system security requirements, and standardizing security requirements for cloud-based services. […]

Portion of Fair UPATE: Pay and Safe Workplaces Executive Order Blocked

As posted by: jdsupra.com/Hinshaw & Culbertson LLP 2016 On Tuesday of this week, a federal judge in Texas granted a nationwide preliminary injunction blocking the portions of President Obama’s “Fair Pay and Safe Workplaces” Executive Order. That order, signed in 2014 and scheduled to take effect on October 25, 2016, has three discrete parts, each described as […]

NASA – Processing of Public Vouchers

Interim NASA rule, effective September 14, 2016, revising request for payments under public vouchers submitted under cost reimbursement contracts (https://www.federalregister.gov/documents/2016/09/14/2016-22046/nasa-federal-acquisition-regulation-supplement-revised-voucher-submission-and-payment-process-nfs). As the DCAA is currently prohibited from performing audit services for non-DoD agencies under the provisions of the 2016 NDAA, NASA contractors are now required to submit public vouchers (electronically is preferred) directly to the […]

DPAP Guidance – Commercial Items

A recent DPAP guidance memo was issued re commercial item and price reasonableness determinations (see http://law.pubkgroup.com/wp-content/uploads/sites/6/2016/09/DPAP-Guidance-on-Commercial-Item-Determinations-and-the-Determination-of-Price-Reasonableness-for-Commercial-Items.pdf). The underlying objective of the guidance appears to focus on movement towards timely and consistent determinations made within the Agency related to same or similar purchases made throughout the Agency. This initiative of consistency is in transition, and, in the […]

Federal Contractors Now Subject to “Basic Safeguarding” Cybersecurity Requirements

As of June 15, 2016, the US Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) will require federal government contractors to apply 15 basic cybersecurity safeguarding requirements and procedures to protect their information systems. These safeguarding requirements are based on the security requirements published by the National Institute […]

DoD Launches Acquisition Regulations Advisory Panel

WASHINGTON — The Department of Defense today announced the creation of a new Advisory Panel on Streamlining and Codifying Acquisition Regulations, with the goal of finding ways to streamline the notoriously cumbersome Pentagon acquisition process. The panel, which was congressionally mandated under section 809 of the 2016 National Defense Authorization Act, will be led by Deidre […]

GSA Schedule Contracts – Transactional Data Reporting

Professional Services Schedule IMPORTANT UPDATE: GSA to Launch Transactional Data Reporting (TDR) Pilot with Refreshed Solicitations and Mass Modifications for Professional Engineering Services. Craig Stetson, Director, Capital Edge Consulting The GSA posted guidance (https://interact.gsa.gov/document/important-update-gsa-launch-transactional-data-reporting-tdr-pilot-refreshed-solicitations) related to their final rule issued in June 2016.  The newly posted guidance, with three attachments included, addresses frequently asked questions […]

Small Business Mentor-Protégé Program Expansion Updates

Small Business Mentor-Protégé Program is seeing expansion with additional classes of small businesses eligible to participate in the program. The 8(a) Business Development (8(a) BD Mentor-Protégé Program is designed to enable successful firms provide various forms of business development assistance to 8(a) BD Program Participants. The goal of the 8(a) BD Mentor-Protégé Program is to enhance […]

Final Rule – Small Business Subcontracting Plans Effective November 1

Small Business Subcontracting Improvements on the way. Craig Stetson, Director, Capital Edge Consulting Final rule issued by the DoD, GSA and NASA July 14, 2016 to amend the FAR to add various improvements related to small business subcontracting (https://www.federalregister.gov/articles/2016/07/14/2016-16245/federal-acquisition-regulation-small-business-subcontracting-improvements).  These statutory amendments will affect prime contractor responsibilities on how they deal with subcontractors and report to […]

Government Contract Cost Accounting System Resource

Government Contract Cost Accounting System-Adequacy and DCAA Compliance A pre-requisite to government contracting, particularly to a negotiated contracts is demonstrating an adequate cost accounting system. The need for a compliant accounting system depends on the contractor’s contract types and other contract-specific circumstances.  For example, a negotiated fixed price contract does not require an adequate accounting system, only […]

When should a Federal Contractor be Registered in SAM.gov?

On May 20, 2016, the Government issued a proposed rule in the Federal Register requiring contractors to be registered in its System for Award Management (SAM) database (https://uscontractorregistration.com). Registration in SAM, including current representations and certifications, would be required prior to submission of an offer to the Government. The current regulations were viewed as being […]

Webinar and Podcast- Keys to Successfully Answering the DCAA Knock at the Door!

In the current government contract regulatory compliance environment, transparency of the contracting process has gained considerable importance and visibility. This transparency directly affects government contractors’ compliance programs and impacts multiple areas of the business, including: Cost accounting, allowability, and allocation practices; Estimating and pricing practices; Business systems documentation and internal controls Accounting Purchasing Estimating Earned […]

June 30th deadline is approaching-  Is your Incurred Cost submission Complete?

Government contractors take note!  For those government contractors who run on a calendar fiscal year, your contracting officer (CO) will be expecting your organization’s incurred costs submission (ICS)  by the  June 30th deadline. Contractors with cost reimbursable and time & material (“T&M”) contracts should start focusing on the submission of their incurred cost proposals, also known […]

Blended Rates – Accounting Treatment Option for Employee Compensation Costs under Flexibly Priced Government Contracts

Craig Stetson, Director, Capital Edge Consulting The Bipartisan Budget Act of 2013, dated April 7, 2014 implemented a compensation limit of $487,000 applicable to new contracts awarded by all federal agencies on or after June 24, 2014 and subject to Federal Acquisition Regulation (FAR) Subpart 31.2.   The $487,000 limit is applicable to all contractor employees […]

Keys to Successfully Answering the DCAA Knock at the Door!

Keys to Successfully Answering the DCAA Knock at the Door! by Craig Stetson, CPA, CGMA, MBA, Director and Terry Carlson, MBA, Managing Director Introduction In the current government contract regulatory compliance environment, transparency of the contracting process has gained considerable importance and visibility. This transparency directly affects government contractors’ compliance programs and impacts multiple areas […]

New contracting rule targets confidentiality agreements with Federal Acquisition Regulation (FAR) ammendment

The federal government to crack down on contractor confidentiality agreements with a proposed amendment to the Federal Acquisition Regulation (FAR). DoD, GSA, and NASA are proposing to amend the Federal Acquisition Regulation (FAR) to implement a section of the Consolidated and Further Continuing Appropriations Act, 2015, that prohibits the use of funds, appropriated or otherwise […]

Proposed Rule – Payments to Small Business Subcontractors

Proposed DoD, NASA and GSA Rule – Payments to Small Business Subcontractors Issued A proposed DoD, NASA and GSA rule ( https://www.federalregister.gov/articles/2016/01/20/2016-00950/federal-acquisition-regulations-far-case-2014-004-payment-of-subcontractors) was issued January 20th requiring prime contractors to notify in writing the contracting officer when payments are made late (greater than 90 days) or at reduced amounts to small business subcontractors. The proposed rule also covers […]

GOVERNMENT CONTRACTOR BUSINESS SYSTEMS WEBINAR SERIES

Join Capital Edge Consulting with Federal Publications Seminars for the Government Contractor Business Systems 7-Part Webinar Series The Department of Defense (DoD) issued a rule in 2012 that requires contractors to have up to 6 adequate business systems in order to comply with government contract reviews and audits.  This webinar series provides an overview and […]

DoD Provides Government Contractors Grace Period

Department of Defense Provides Government Contractors Grace Period for Compliance with Key Cybersecurity Requirements By: Alexander W. Major with The National Law Review In response to industry concerns and comments, on December 30, 2015, the Department of Defense issued a new interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) cybersecurity rules promulgated in […]

Upcoming final FAR Rules – DoD, GSA, NASA

By Craig Stetson CPA, CGMA The FAR Council Semiannual Regulatory Agenda has been released.  This agenda identifies existing interim rules subject to final over the upcoming few months. Among the pending final rules is an adjustment to the cap related to allowable contractor employee compensation costs.  The final rule, slated for 1/00/16, will adjust the current $487,000 […]

Obama signs defense bill, approves buildup expenses

Guam Del. Madeleine Bordallo on Thursday announced President Barack Obama had signed the National Defense Authorization Act for Fiscal 2016, saying in a statement that the law’s investments to the military buildup and local infrastructure “are important milestones.” The law approves the following expenditures — nearly $272.3 million on military construction projects in Guam, and […]

Guam gets $400M in budget

Guam will receive some $400 million in Department of Defense funds this fiscal year for civilian and military projects directly related to the buildup, according to Guam Delegate Madeleine Bordallo. The National Defense Authorization Act for Fiscal Year 2016, which includes the appropriations, was signed yesterday by President Barack Obama. The island government will realize […]

Contract Awards for Guam

NAVY AIC International Inc.,* Hagatna, Guam (N40192-16-D-2700); APC Construction LLC,* New Orleans, Louisiana (N40192-16-D-2701);  Fargo Pacific Inc.,* Hagatna, Guam (N40192-16-D-2702); Keum Yang Corp.,* Tamuning, Guam (N40192-16-D-2703); Reliable Builders Inc.,* Tamuning, Guam (N40192-16-D-2704); Techni-Con Inc.,* Tamuning, Guam (N40192-16-D-2705); and Tikigaq Construction LLC,* Wasilla, Alaska (N40192-16-D-2706), are each being awarded an indefinite-delivery/indefinite-quantity, multiple award, design-build construction contract […]

Preparing for an Incurred Cost Submission – On Demand

The Incurred Cost Submission is daunting and can be very confusing for contractors because of its complexity and the number of schedules and forms. Not only that, there are sensitive audit issues as well as a host of other issues such as executive compensation and rate calculations that impact your submission. Presented by Chad Braley […]

DCAA Audit Services – Non-Defense Agencies

Buried deep in the current version of the NDAA (Act) for fiscal year 2016 is a provision (Sec. 893. Improved Auditing of Contracts) that will prohibit the DCAA from providing audit services to non-defense agencies.  This prohibition is effective upon enactment of the Act and will remain in effect until the Secretary of Defense certifies that […]

DEMYSTIFYING THE CPSR PODCAST

Chase Kunk has considerable industry and consulting experience in supporting organizations through the CPSR process. His approach to purchasing system compliance has always been “one size does not fit all;” rather, make the public laws and regulatory requirements work for your business model and processes.  This practical approach has become the cornerstone of his reputation […]

12 Essentials to a Successful DCMA Contractor Purchasing System Review

Chase Kunk of Capital Edge Consulting has considerable industry and consulting experience in supporting organizations through the CPSR process. His approach to purchasing system compliance has always been “one size does not fit all;” rather, make the public laws and regulatory requirements work for your business model and processes. This practical approach has become the […]

DCAA Office of Inspector General Reporting

By Craig Stetson CPA, CGMA A Notice was filed in the Federal Register last week (see,http://www.gpo.gov/fdsys/pkg/FR-2015-10-27/pdf/2015-27231.pdf) re a proposed DCAA action to establish a new system of records related to their OIG.  I was looking around recently for any source to gain some visibility of the DCAA OIG’s activities and reporting over the last year.  The OIG was formed […]

Good Times for ANCs

Bloomberg BNA reported last week that ANCs (Alaska Native Corporations) received $7.3B in federal contract awards in FY 2014 (of this amount, $4.5B was DoD). This total amount is up from $5.8 in the prior year. This is impressive considering a $20M 8(a) sole-source award threshold was imposed in 2009 due to provisions of the […]

GovCon Expert Spotlight – featuring Stephen ‘Chase’ Kunk and CPSR

Stephen ‘Chase’ Kunk, J.D. Vice President, Contracts & Procurement/Senior Manager Stephen “Chase” Kunk is Capital Edge Consulting, Inc.’s Capital Edge Consulting’s Vice President, Contracts, Procurement and CPSR Consulting Practice lead and Managing Director. Chase specializes in U.S. Government contract and subcontract negotiations, administration, management and purchasing system compliance. His expertise stems from his legal education, […]

Owner of Closely-held Contractor Has No Privity Of Contract With Govt, Fed. Circ. 2015-5091, Dourandish v. U.S.

Owner of Closely-held Contractor Has No Privity Of Contract With Govt, Fed. Circ. 2015-5091, Dourandish v. U.S.  – from PubKLaw The Federal Circuit upheld the dismissal of a lawsuit over unpaid executive compensation costs on an Air Force research contract, rejecting the company owner’s arguments that he was should have standing to sue as a […]

Contractors’ Purchasing Systems Reviews (CPSR) Instructor-Led Virtual Training Series

Thursdays, 11:00 am – 1:00 pm (ET) for 5 Weeks Upon completion of this course, the participant should have adequate knowledge of the background and requirements related to the CPSR.  Further, the participant should have basic understanding of policies, procedures and practices required to comply with the requirements.  We will highlight recent developments in the CPSR environment […]

DCAA MRD – Risk Assessment and Contractor Corrective Actions

A recently issued MRD / Audit Alert (http://www.dcaa.mil/mmr/15-PAS-009.pdf) directs the DCAA to consider as part of their audit planning and contractor risk assessment process corrective actions implemented by the contractor related to prior audit findings. This requirement to consider corrective actions undertaken by the contractor should not be used only for audit planning purposes which would limit […]

Contractors’ Purchasing System Reviews (CPSR) Virtual Class

Join Industry Experts Stephen “Chase” Kunk and Anthony Kim in this Virtual series covering Contractors’ Purchasing System Reviews (CPSR). Upon completion of this course, the participant should have adequate knowledge of the background and requirements related to the CPSR.  Further, the participant should have a basic understanding of policies, procedures and practices required to comply […]

Acquisition Thresholds – Inflationary Adjustments

Reminder that various thresholds will change Thursday (October 1).  These changes are the result of a DoD, NASA and GSA final rule issued in July.  Changes include: •  The micro-purchase base threshold of $3,000 (FAR 2.101) is increased to $3,500. •  The cost or pricing data threshold (FAR 15.403-4) and the statutorily equivalent Cost Accounting Standard […]

DCAA’s View on Expressly Unallowable Cost Audit Guidance

Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting PubKLaw recently met the DCAA Deputy General Counsel and discussed the DCAA’s December and January MRD audit guidance re expressly unallowable costs.  The DCAA comments are a prelude to the upcoming Annual Government Contracts Review and address the objective of […]

Guam Military Build-Up

Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting The final Supplemental Environmental Impact Statement (SEIS) was issued this week and should allow for the final signing of the Record of Decision by the end of August.  This appears to be the final step to release the hold and trigger full project implementation.  […]

DCAA – Incurred Cost Proposal Adequacy

Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting The DCAA released recently a revised Incurred Cost Proposal Adequacy Checklist (Version 3.0), effective immediately.  http://www.dcaa.mil/Guide_for_Determining_Adequacy_of_Contractor_Incurred_Cost_Proposal.pdf I have not compared side-by-side the former and revised versions; however, according to the corresponding MRD issued August 27, 2015, the main changes in […]

DoD IG Fraud Indicators

Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting The DoD IG recently revised its website and posted new fraud indicators related to Forward Price Proposal and Postaward audits (see, http://www.dodig.mil/resources/fraud/resources2.html).  The new guidance identifies 9 indicators associated with Forward Price Proposal and 11 Postaward (defective pricing) audits. These indicators, […]

Small Business Subcontracts – Comments to Proposed Rule

By Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting In response to the June 10th proposed rule to amend the FAR (https://www.federalregister.gov/articles/2015/06/10/2015-14055/federal-acquisition-regulation-small-business-subcontracting-improvements), the ABA Section of Public Contract Law provided comments to the GSA earlier this week (http://pub.bna.com/ptcj/ABA_PCLS_Comments.pdf).  Several of the comments were aimed at easing or clarifying the requirements […]

GSA CALC & Price Analysis

By Chase Kunk Director, Capital Edge Consulting GSA’s release of the shiny Contract-Awarded Labor Category (CALC) tool in May garnered some excitement within the Government and Industry. The “About this tool” even mentions contracting officers’ use for price analysis purposes. However, procurement professionals are reminded of DPAP class deviation from March 2014 when employing the […]

DCAA Annual Report to Congress

By Craig Stetson CPA, CGMA Director, Capital Edge Consulting Summary and Analysis The Defense Contract Audit Agency (DCAA) issued its fourth Annual Report to Congress in May 2015. The Report illustrates slight improvements in audit timeliness and turnaround as well as regulatory constraints or limitations faced by the DCAA that, in their view, hinders performance. The […]

DoD Memo regarding Proper use of GSA Schedules

By Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice A recently issued DPAP memo reiterates the requirement that COs perform adequate price reasonableness analyses when placing orders off GSA Schedules. This memo was released as government purchases, GSA Schedule or otherwise, typically increase significantly during the last quarter of the government fiscal year.  An underlying […]

Proposed DFARS Rule – Price Reasonableness and Commercial Items

By Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice A proposed rule to amend the DFARS was issued today to provide further guidance when performing price reasonableness analyses related to the purchase of commercial items.  This proposed rule is the outcome of the NDAA for fiscal year 2013.  https://www.federalregister.gov/articles/2015/08/03/2015-18938/defense-federal-acquisition-regulation-supplement-evaluating-price-reasonableness-for-commercial Specific proposed amendments […]

Incurred Cost Submission (ICS) – Training Update

Chad Braley just finished – A Practical Guide to the Incurred Cost Submission (ICS) at Federal Publications Seminars’ Hilton Head Government Contracts Week. If you missed it- NEW in 2015 – Federal Publications is adding an extra day in order for participants to actually fill out an ICS form. A Practical Guide to the Incurred […]

Adjustments – Acquisition Thresholds

By Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice A final DoD, GSA and NASA rule was issued last week revising several provisions of the FAR to implement inflationary adjustments to various acquisition-related thresholds.  Frequently used thresholds are summarized below. Most notably included is an upward adjustment of $50,000 related to submission of […]

Federal Publications Seminars and Capital Edge Consulting Announce 2-Day Event in Alaska for Government Contractors

Eagan, MN and Tysons Corner, VA – June 30, 2015- Capital Edge Consulting and Federal Publications Seminars® (FPS) are pleased to announce a 2-day training event, “Government Contracting: The Changing Landscape of Compliance,” for individuals and organizations doing business with the federal government. The course, designed to help government contracting professionals stay abreast of and […]

Proposed FAR Rule – Small Business Subcontracts

by Craig Stetson CPA, CGMA, Director Government Contract Regulatory Compliance Practice A proposed FAR rule, issued today and effective to DoD, GSA and NASA, addresses several potential revisions aimed at improving small business subcontracting opportunities.  Many of the proposed changes relate to the prime’s  subcontracting goals and plans. https://www.federalregister.gov/articles/2015/06/10/2015-14055/federal-acquisition-regulation-small-business-subcontracting-improvements The proposed rule would implement several […]

DCAA AUDIT HOT TOPICS ON-DEMAND

This complimentary webinar hosted by Federal Publications  provided an update and overview of current “Hot Topics” related to contracting with the federal government and interacting with the Defense Contract Audit Agency (DCAA). The webinar was intended for professionals in the areas of accounting, compliance, finance, and program or contract management. Presented by Chad Braley of Capital […]

DCAA Annual Report to Congress – 2014

By Craig Stetson The DCAA 2014 Report to Congress is available (http://www.dcaa.mil/DCAA_FY2014_Report_to_Congress.pdf). A few of the highlights: 1.  Net savings (not defined, but presumably dollars sustained by the CO) resulting from total audited dollars was $4.5B.  This represents about 2.5% of total audited dollars ($182.6B).  Total questioned costs related to the audited $182.6B were not specifically noted […]

Preparing the Incurred Cost Submission Seminar Half Price!

Preparing the Incurred Cost Submission Seminar Half Price! For discount-use registration code: JuneSpecial – Register now- http://ow.ly/NBDxq Incurred Cost Submission – ICS Seminar Summary Doing business with the US Government is always challenging and the many onerous accounting requirements only make it more difficult. The purpose of this class is to help add clarity to Incurred […]

CPSR: WHAT YOU NEED TO HAVE IN PLACE TO PASS A PURCHASING SYSTEM REVIEW

Join industry expert Chase Kunk for an overview on Contractor Purchasing System Reviews, including system elements that must be in place to successfully pass a purchasing system review. An approved purchasing system can also result in higher proposal evaluations resulting in more contract awards. Therefore, a contractor triggering the threshold for a purchasing system review […]

FY 2016 NDAA Language and DCAA

By Craig Stetson The House Armed Services Committee’s May 2015 report on the NDAA for fiscal year 2016 includes language addressing DCAA performance and audit backlog (page 200 of the attached). Specifically, the report’s language under Title VIII and the subheading Improving the Efficiency of the Defense Contract Audit Agency, directs the Secretary of Defense “to take […]

DoD IG – Report on Commercial Items and Price Reasonableness

By Craig Stetson This likely will add to the current controversy re commercial item determinations and related price reasonableness.  The government and contractors are supposed to procure commercial items to the maximum extent practicable pursuant to FAR Part 12 requirements.  However, obtaining the commercial item determination may be a challenge based on recent decisions.  Also, […]

DCAA’s New Aggressive Approach to Incurred Cost Submissions 

CAPITAL EDGE CONSULTING NEWSLETTER – EARLY SPRING 2015  Subscribe to Capital Edge Consulting Newsletters-Click Below to sign up! The DCAA’s New Aggressive Approach to Overdue Incurred Cost Submission (ICS) by-Norman McCord, CPA, MSA Director, Capital Edge Consulting In a recent Capital Edge “Ask an Expert” series, we noted that the Defense Contract Audit Agency (DCAA) recently issued […]

Convenience Terminations

By Craig Stetson There is a lot wrong with this – common items, loss contract and lack of supporting data.  Notwithstanding the amount of claimed costs (small in this case), the contractor has the burden to support costs (entitlement and quantum) when submitting termination for convenience settlement proposals.  See FAR Part 49. ************************************* ASBCA, 15-1 […]

GOVERNMENT CONTRACTING UPDATE – ANCHORAGE, ALASKA

Join us in Anchorage, Alaska for this Federal Publications half-day seminar to learn about recent legislation and rules impacting government contracting. This seminar will provide an update and overview of current “Hot Topics” related to contracting with the federal government and interacting with the Defense Contract Audit Agency (DCAA). If you are an Alaska Native Corporation, […]

Business Systems Audits – When the other shoe drops…

Capital Edge Consulting – Late Winter Newsletter Norman McCord, CPA, MSA Director, Capital Edge Consulting Sign up for the CEC Newsletter Series Background and Status The Department of Defense recently withdrew its proposed amendments to the Business Systems rules related to Estimating, Accounting and Material Management and Accounting Systems.  The proposed amendments would have required […]

Executive Seminar: Industry Insight – Government Contract Compliance Issues and Challenges

Chad Braley to be Speaker at Executive Seminar – Industry Insight – Government Contract Compliance Issues and Challenges April 28th . Please join BDO USA, LLP  for an opportunity to hear from Congresswoman Barbara Comstock (R-VA) as well as other leading industry executives about a range of issues, including the current DCAA/DCMA environment, compliance matters, […]

Recovery of Costs under Terminated Contracts

By Craig Stetson I do not see why there was a dispute to begin with. The terminated contract was converted from default to convenience. The contractor submitted the settlement proposal claiming costs attributable to all work, in accordance with Part 49 guidance. Appears the TCO denied the settlement request as all parts were not accepted […]

Commercial Item Determinations

Recently issued DoD memorandum on guidance related to commercial item determinations (FAR Part 12) and price reasonableness analyses. A revised DoD Commercial Item Handbook is on the way and will include more detailed guidance and examples to assist with making commerciality decisions. Also, under this new guidance memorandum, contracting officers are encouraged to make the […]

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