DoD Class Deviation Issued On Use of Fixed-Price Contracts

SUMMARY: Award of cost-reimbursement contracts exceeding $50M now requires the head of contracting activity approval. Further, this threshold decreases to $25M applicable to contracts awarded on or after October 1, 2019. We would expect further guidance on the implementation as related to options, mods, IDIQ TOs / DOs, etc.

SUBJECT: Class Deviation-Use of Fixed-Price Contracts Effective immediately. contracting officers shall first consider the use of fixed-price contracts. including fixed-price incentive contracts. in the determination of contract type and shall not award the following cost-type contracts unless the contract is approved by the head of the contracting activity:

• Cost-reimbursement contracts in excess of $50 million to be awarded after October I. 2018, and before October l, 2019. • Cost-reimbursement contracts in excess of $25 million to be awarded on or after
October l. 2019.

DETAILS: This class deviation implements section 829 of the National Defense Authorization Act for Fiscal Year 2017 (Pub. L. 114-328). which directs establishment of a preference for fixed­price contracts, including fixed-price incentive contracts. in the determination of contract type and establishes the requirement for higher-level approval for certain cost-type contracts. The Under Secretary of Defense for Acquisition and Sustainment has determined that the use of cost-type contracts is approved for research and development valued in excess of $25
million. if the contracting officer executes a written determination that the level of program risk does not permit realistic pricing and it is not possible to provide an equitable and sensible allocation of program risk between the Government and the contractor. 

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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) have all issued specific Agency rules pertaining to performance and compliance under government contracts.

Download your copy of Compliance Roundup below



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 promo code 2FOR1ARU2018. 

A professional seminar on government contractor finance management, contracting accounting and audit issue year in review and outlook.

This 1.5-day conference will address the emerging issues related to government contract finance, accounting, compliance, and regulations.  You will have the opportunity to hear from leading financial executives, Defense Contract Audit Agency representatives, Defense Contract Management Agency representatives, practicing attorneys and consultants. Topics will include:

  • Cost, accounting, pricing, estimate audit and regulatory issues
  • Update on Section 809 Panel related to CAS
  • Cybersecurity regulations – current state and how companies address the compliance strategies
  • M&A and due diligence
  • Government contract ERP issues
  • Legal issues and case law updates (CAS, cost allowability, statute of limitation, and more)
  • DCMA review update
  • Third party audits
  • Federal Supply Schedule (GSA Schedule) update
  • DCAA Matters (presented by representatives from DCAA HQ)
  • and much more.

Who Should Attend?
This seminar is intended for professionals from large, medium and small government contractors, financial and consulting organizations, federal agencies and non-profits:

  • CFOs/CEOs/Presidents
  • VPs of Finance, Accounting, Compliance
  • Directors of Finance, Compliance, Business
  • Development, Procurement & Acquisitions
  • Financial Analysts & Accounting Professionals
  • Legal Professionals

The 2018 Government Contract Accounting and Regulatory Update is co-chaired and sponsored by Capital Edge Consulting.

Capital Edge consultants combine their unique backgrounds and experience in consulting, public accounting, industry, and DCAA to provide you with unmatched government contracting expertise. Learn more at


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 to the progress payments and performance-based payments process for DoD contractors. As proposed, the new rule would have significantly reduced interim payments from 80 percent of incurred cost to 50 percent.
Earlier this week, Deputy Secretary of Defense Patrick M. Shanahan released a statement that the “proposed amendments to the Defense Federal Acquisition Regulation Supplement (DFARS) were prematurely released, absent full coordination. As a result, the Department will rescind the proposed amendments. In coordination with industry, the Department will create a revised rule to implement section 831 of the FY2017 NDAA.”

The DoD has now committed to work with industry to implement the recommendations contained within Section 831 of the FY2017 National Defense Authorization Act (NDAA) which called for a preference for performance-based payments and imply a desire to move away from progress payments. As stated within the NDAA, Performance-based payments are “not conditioned upon costs incurred in contract performance but on the achievement of performance outcome.” It is clear that a change to progress and performance-based payments is coming, but hopefully ,the DOD can team with Industry to make changes that will work for all parties and avoid the significant impact to cash flow that would have resulted from the original proposed rule.

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, make the public laws and regulatory requirements work for your business model and processes. This practical approach has become the cornerstone of his reputation and yields positive results for contractors.

With the benefit of his experience, he has identified 12 purchasing system essentials that every company must consider as they evaluate their system and prepare for their next CPSR. 

Got your copy of 12 Essentials to a Successful DCMA Contractor Purchasing System Review




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 and points of contact.

While only a limited number of entities registered in SAM are suspected of being impacted, all contractors must submit a notarized letter appointing the authorized Entity Administrator before the company’s registration will be activated. This requirement now applies to both new and existing registered entities. The SAM website provides FAQs to learn more about this process change on its website. Sample letter templates have been provided on the SAMs website:

GSA recommends a thorough review of all registered Electronic Fund Transfer (EFT) in SAM. Any entity that suspectsfraudulent bank activity should contact the Federal Service Deskat:

If you have any questions or need any support with this matter, please feel free to contact Capital Edge for assistance.

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) is contained in FAR clause 52.216-7(d)(2)(i) – Allowable Cost and Payment, which states, “The contractor shall submit an adequate final indirect cost rate proposal to the contracting officer (or cognizant federal agency official) and auditor within the 6-month period following the expiration of each of its fiscal years.” Are you ready? Capital Edge has identified the major preparation pitfalls contractors face when developing their annual Incurred Cost Submission (ICS).

Get your copy of Common Preparation Pitfalls with the Final Indirect Cost Rate Proposal- Download below!


Getting a late start.  Depending on the size of the organization, incurred cost submissions may take a long time to prepare. If the submission is drafted in-house, the finance or accounting staff responsible with preparation have other daily and monthly responsibilities which require their attention in addition to this submission. Plan ahead and get an early start! Extra preparation time means more time to research issues or resolve challenges which may arise. Remember, the ICS requires input from various groups within an organization and is not a “pure” accounting and finance responsibility.

Using a format which does not reflect the FAR requirements or auditor expectations.  FAR 52.216-7(d)(2)(iii) specifically identifies all the information required. In addition, DCAA regularly updates their Incurred Cost Electronic (ICE) Model, as well as the Adequacy Checklist, and these items should be reviewed as part of the preparation process to ensure the submission will meet auditor expectations. Keep in mind that utilizing the “ICE” model is not required, but the content of the individual schedules are required by 52.216-7. The ICE model has a number of limitations related to the number of intermediate and final overhead pools that the model can support, so it is imperative that you understand whether your business may be too complex for ICE. We don’t like the model, but it may work well for you.

Not having current and accurate contract briefs.  Contract briefs identify items such as contract type, indirect rate caps, funding ceilings, or other contractual limitations that need to be accounted for in the submission. Briefs should be updated as contract modifications are issued which change funding, add CLINs, modify contract terms and conditions, etc.

Inaccurate identification of contract types.  Many contractors struggle with having full, accurate, and complete contract lists with accurate contract types. Contracts may be entered into the accounting system and identified with a contract type other than what the contract specifies due to accounting system limitations or unique contract requirements. Not having an accurate identification of contract type for each contract or task can cause numerous challenges when preparing the ICS, including the misidentification of contracts in the actual submission.

Incorrect contract billings.  Contractors sometimes realize that a contract or task has been billed incorrectly. For example, when a cost-reimbursable contract is billed as a time-and-material contract, or cost reimbursement CLINs within FFP contracts are not appropriately identified. These types of errors cause major headaches when preparing the ICS and can lead to large over/under billings and/or additional audits. Properly identifying the contract type in a contract billing brief, contracts list, and the accounting system is essential. Most important, getting an early start provides adequate time to resolve these issues rather than trying to make these decisions at the last minute.

Identifying and removing unallowable costs.  Unallowable costs need to be excluded from claimed costs in the ICS and that is, in fact, the intent of the certification ensuring you have excluded all expressly unallowable costs. Explanatory notes should be utilized to reference the specific FAR clause which is applicable (31.205 – Selected Costs) and special care should be given to review accounts considered high-risk for inclusion of expressly unallowable costs that would be subject to Penalties under the provisions of FAR 42.709 Penalties for Unallowable Cost.

Involving key players too late in the process.  To provide timely information required for submission, it is important to involve key players early in the preparation process. For example, contracts/subcontracts personnel are routinely tasked with providing information on subcontract agreements very late in the preparation process, which oftentimes leaves contractors scrambling to finalize the proposal.

Performing a thorough review.  Each ICS should receive a thorough review ideally by individuals not directly involved in the detailed preparation. This review should include checking all formulas, links, ensuring the costs captured reconcile to the trial balance, and that the final submission complies with DCAA’s adequacy checklist.

Maintaining supporting documentation and work papers.  Preparation of the Incurred Cost Submission often requires input from various personnel across a wide range of functional areas. Employee turnover and the lapse of time between submission and audit can often lead to gaps in information and historical knowledge required to support claimed costs during an audit. Whenever possible, we recommend creating a repository for work papers and supporting documentation to memorialize knowledge gained during preparation of the submission and to assist in meeting the requirements of FAR 31.201-2(d) Determining Allowability.

For many contractors, the deadline for the next Incurred Cost Proposal is June 30th. We recommend getting started soon, to be sure that you have adequate time to prepare the submission. Capital Edge has a wealth of resources available to support contractors with preparation and review of their ICS. Whether your organization is large, small, or somewhere in between, we can help take the stress out of this requirement.

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 and offers several conclusions and recommendations identifying opportunities for improvement across the overall acquisition spectrum.

The focus of this paper is Section 2 – Contract Compliance and Audit. Summarized below are six selected recommendations of the total 11 recommendations identified in Section 2 of the Report. The 11 recommendations pertain to current regulatory requirements and associated business practices of the Defense Contract Audit Agency (DCAA) and Defense Contract Management Agency (DCMA) relative to current contract audit, oversight and administration activities.

Several of the findings and recommendations included in the overall 11 have been previously identified through prior fiscal years’ NDAAs and/or the DoD rule-making process and the subject of public comments, discussions, or opinions. We have selected for discussion here six of the 11 recommendations that present somewhat of a new look and offer a different perspective to effect potential improvements to the DoD acquisition process compared to other initiatives previously vetted in prior NDAAs and/or DoD rules referenced above.

– DCAA’s Annual Report to Congress (Recommendation 6) – The Report criticizes the content and metrics that the DCAA reports annually to Congress. The Report states “Congress’s reporting requirement for DCAA lacks critical metrics to adequately measure DCAA’s performance.”

Substantive findings and recommendations noted in the Report include:

  • Reduction of, as the primary emphasis, reporting of DCAA’s questioned costs, sustained costs, and return on investment as it is misleading when not reported in conjunction with other performance metrics;
  • Utilization of a balanced scorecard approach to report other aspects of DCAA’s performance, including, among other things, i) on-time performance, ii) reasons for the differences between questioned and sustained costs, iii) survey results of buying commands’ and the DCMA’s views on the timeliness, quality and effectiveness of DCAA audits performed, and iv) costs to perform audits compared to sustained costs; and
  • Amendment, by the Legislative Branch, of 10 U.S.C. §2313a requiring the DCAA to report additional key metrics.

– Statutory Time Limits for DCAA Activities (Recommendation 8) – The Report criticizes the overall timeliness of the DCAA audit activities performed and notes various activities take too long and are initiated too late. Timely receipt of audits under statutorily mandated deadlines will improve the DoD’s effectiveness of various oversight activities. The Report states, “DCAA’s work is untimely, which causes delays in contract awards, as well as other negative effects on the contract life cycle, through andincluding contract closeout.”

Substantive findings and recommendations noted in the Report include:

  • Existence of requirements for independent public accountants to submit final audit reports within required timeframes – including both audits of i) private entities under Securities Exchange Commission deadlines and ii) public agencies under Chief Financial Officers Act of 1990 deadlines;
  • Existence of requirements for contractors to submit various reports and documents to the DCAA and DCMA within required statutory timeframes;
  • Identification of 11 specific DCAA oversight activities, three on-demand and eight predictable, for which statutory deadlines should be established;
  • Establishment of these deadlines by October 1, 2019; however, the DCMA and DCAA are encouraged to establish dates sooner;
  • Extension of established dates is permissible by contracting officers within a narrow group of three categories – if the extension is due to the contractor requested or delayed category, the extension cannot be granted without the contractor’s express knowledge; and
  • Amendment, by the Legislative Branch, of 10 U.S.C. §2313b(g) to include required reporting deadlines related to the 11 specific oversight activities referenced above.

– DCAA’s use of Independent Public Accounting (IPA) Firms to meet Time Limits (Recommendation 9) – The Report asserts the DCAA cannot eliminate its backlog of incurred cost proposal audits and meet its other oversight and reporting responsibilities without use of additional resources. The Report states, “DCAA needs additional resources to get and stay current with its oversight responsibilities.”

Substantive findings and recommendations noted in the Report include:

  • Establish use of IPAs by the DCAA to eliminate the incurred cost proposal audit backlog and allow continued support of other oversight and financial services activities;
  • Request increases in appropriated funding by the DCAA to Congress to allow for the DCAA to contract with IPAs;
  • Maintain availability of increased funding to the DCAA on a yearly basis, over a five-year period and starting in fiscal year 2019;
  • Establish authority of contracting officers to request from the DCAA services of IPAs to meet contracting officers’ needs;
  • Provision, by the Legislative Branch, of additional appropriated funding beyond the current DCAA budget to allow the DCAA to retain IPAs; and
  • Modification by the Executive Branch, of DoD Directive 5105.36 to enable the DCAA’s use of IPAs.

– Replace Accounting System Administration Adequacy Criteria (DFARS 252.242-7006 with an Internal Control Audit (Recommendation 10) – The Report asserts use of the existing 18 adequacy criteria contained in DFARS 252.242-7006 for purposes of assessing the adequacy and effectiveness of contractors’ accounting systems is inadequate. Rather, as prescribed in Section 893 of the NDAA for fiscal year 2017, the DoD should accept contractors’ third-party auditor internal control audits performed using the Sarbanes-Oxley (SOX) integrated framework approach as the baseline. The Report states, “The DoD is not obtaining timely assurance that internal controls for defense contractors’ accounting systems are properly designed and functioning. Ensuring effective internal controls is one of the most efficient ways to protect the government’s interest, reduce risk, and improve performance.

Substantive findings and recommendations noted in the Report include:

  • Recognition that the accounting system is the most critical business system to ensure the government’s interests are protected;
  • Use by third-party auditors the SOX integrated audit framework as a baseline to measure contractors’ adequacy and effectiveness of internal controls to meet government contract audit objectives;
  • Revision by third-party auditors the SOX framework to address specific and unique accounting system internal control objectives and establish an internal control audit program based on objective and measurable criteria;
  • Replacement of the DFARS 18 adequacy criteria with the revised internal control audit program and conduct audits with use of third-party auditors, and
  • Revision by the Executive Branch, of DFARS 252.242-7006 to allow use of contractor performed internal audits.

– Incentivize Contractor Compliance through Robust Risk Assessment (Recommendation 14) – The Report suggests the DCAA could be more efficient with performance of their overall audit and oversight responsibilities with utilization of a more robust risk assessment program pertaining to their overall audit and workload planning. The Report states, “DCAA uses a simple risk assessment to prioritize workload. Because DCAA bears all oversight responsibilities regarding contractor costs and related business systems, DCAA needs a more robust risk assessment approach.

Substantive findings and recommendations noted in the Report include:

  • Implementation by the DCAA of a more holistic risk-based assessment approach based on assignment of numeric weightings to specific fact-based risk considerations;
  • Addition by the DCAA of ten potential additional factors (beyond auditable dollar-volume (ADV) for consideration and analysis when performing contractor risk assessments, including, among other things, i) complexity of cost accounting structure, ii) government participation in indirect expense pools, iii) status of business systems, and iv) compliance with applicable Cost Accounting Standards requirements;
  • Potential re-designation of contractors, based on the results of the numeric weightings developed from the criteria above, into high, medium and low-risk categories different than previously designated categories based on the current ADV focused approach, and
  • Definitive recommendation by the Section 809 Panel regarding the potential ten additional risk assessment factors prior to its January 2019 sunset.

– Clarify Definition of an Adequate Incurred Cost Proposal (Recommendation 15) – The Report criticizes the DCAA’s audit of direct costs as a required procedure in conjunction with the overall audit of contractors’ final indirect cost rate proposals (also frequently known as final incurred cost proposals or incurred cost submissions). The Report asserts all the schedules currently ‘required’ and included in these proposals have no bearing on meeting the sole purpose of these proposals, which is, establishment of final indirect expense rates in accordance with FAR 42.702. The Report states “Many of the required elements of an adequate final indirect cost rate proposal have no bearing on calculating, understanding, auditing, and negotiating final indirect cost rates. This collection of unnecessary data has contributed to DCAA losing its focus on the purpose and scope of contractors’ final indirect cost rate proposal and has created unnecessary work for contractors, DCAA, and especially contracting officers.

Substantive findings and recommendations noted in the Report include:

  • Clarify in the FAR that an incurred cost proposal is the same as a final indirect cost rate proposal;
  • Perform by DCAA audits of final indirect cost rate proposals in accordance with the intent of the FAR, and, exclude as a required procedure the audit of direct costs;
  • Redefinition by DCAA which schedules are required for submission in the final indirect cost rate proposal, and, designate as optional those schedules that do not relate to establishment of final indirect expense rates; and
  • Definition, by the Executive Branch, within FAR 52.216-7 that incurred cost proposal is synonymous with final indirect cost rate proposal and designate schedules I-M and O as optional.

What does this Mean?

The six recommendations discussed above make sense and offer practical and reasonable approaches to accomplishing the overall objective of the Section 809 Panel, i.e., streamline the DoD acquisition regulatory process and move to a more effective and efficient framework. Further, use of industry leading and long-established commercial business practices makes good sense.

Unfortunately, there is a twofold reality. First, as many of the recommendations can only be accomplished as a result of statutory or regulatory change, the corresponding timeline(s) associated with the legal or regulatory processes to allow implementation of these recommendations are likely, a way down the road. Second, some of the recommendations may be received as somewhat controversial and attract resistance; see, for example, recommendations 6, 8, 9, and 15. Recommendation 9 is likely the most controversial as the DCAA, based on recent public discussions and comments and congressional testimony (April 2017), clearly object to the use of IPAs for incurred cost audit purposes, let alone engaging the IPAs directly as recommendation 9 suggests.

Implementation of the above recommendations would be a welcomed change to the current government contracting state however, contractors should realize any real or substantive change will likely not be seen in the near term.


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 number of significant implications for federal government service contractors. PSC is pleased that the president signed this important bill into law,” said PSC President and CEO David J. Berteau. “PSC worked diligently throughout the year to offer recommendations to the House and Senate Armed Services Committees and conferees on this bill. While some of the acquisition provisions give us concern, there are many positive aspects of the bill that will improve acquisition outcomes and aid PSC member companies in their work to meet mission needs.”

Three key acquisition and technology-related provisions are among the many notable ones that will bring significant changes for the government and the contractor community:

Modernizing IT: Sections 1076 through 1078 include the Modernizing Government Technology Act. This provision will facilitate making critical investments in the government’s IT infrastructure to limit vulnerabilities and increase security. PSC has strongly supported enactment of the MGT Act;

Promoting Better Information Sharing Between Government and Industry: Section 818 enhances post-award debriefing rights by providing contractors with additional information after a source selection—creating a more meaningful dialogue between the government and offerors and reducing protests being filed as a way to get better award information;

Leveraging Industry to Help Reduce the Audit Backlog: Section 803 permits independent, third-party auditors to help the Defense Contract Audit Agency reduce the incurred-cost backlog and mitigate the negative impact that the backlog has on the government and government contractors.

“Legislation is just the first step. PSC looks forward to engaging with the Department of Defense and the White House during the implementation and execution of these new authorities, as well as working on the impact of other provisions that will make structural changes to the Department,” Berteau continued. Those noteworthy organization provisions include section 901, which will impact the Defense Department’s pending break up of Acquisition, Technology and Logistics, and Section 910, which defines the roles and responsibilities of the Chief Management Officer—two offices with jurisdiction over how the government acquires, manages, and utilizes services.

The House passed the final conference report on Tues., Nov. 14 by a 356-70 vote, and the Senate passed it by a voice vote on Nov. 16. The legislation was signed by the President today.


Click here to view the PDF version of this release

Media Contact:
Ashlei Stevens
Director, Media Relations

About PSC: PSC is the voice of the government technology and professional services industry. PSC’s member companies represent small, medium and large businesses that provide federal agencies with services of all kinds, including information technology, engineering, logistics, facilities management, operations and maintenance, consulting, international development, scientific, social, environmental services, and more. Together, the trade association’s members employ hundreds of thousands of Americans in all 50 states. Follow PSC on Twitter @PSCSpeaks. To learn more, visit

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


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 by changes in the Federal Acquisition Regulation (FAR), to remove any procedural guidance that is internal to the VA, and to incorporate any new regulations or policies

Acquisition regulations become outdated over time and require updating to incorporate additional policies, solicitation provisions, or contract clauses that implement and supplement the FAR to satisfy VA mission needs, and to incorporate changes in dollar and approval thresholds, definitions, and VA position titles and offices. This Proposed Rule will correct inconsistencies, remove redundant and duplicate material already covered by the FAR, delete outdated material or information, and appropriately renumber VAAR text, clauses and provisions where required to comport with FAR format, numbering and arrangement.

This Proposed Rule will streamline the VAAR to implement and supplement the FAR only when required, and remove internal agency guidance as noted above in keeping with the FAR principles concerning agency acquisition regulations.


Comments must be received on or before July 17, 2017 to be considered in the formulation of the final rule.


Written comments may be submitted through; by mail or hand-delivery to Director, Regulation Policy and Management (00REG), Department of Veterans Affairs, 810 Vermont Avenue NW., Room 1068, Washington, DC 20420; or by fax to (202) 273-9026. Comments should indicate that they are submitted in response to “RIN 2900-AP50—Revise and Streamline VA Acquisition Regulation to Adhere to Federal Acquisition Regulation Principles (VAAR Case 2014-V001—parts 801, 802, 803, 812, 814, 822, and 852).” Copies of comments received will be available for public inspection in the Office of Regulation Policy and Management, Room 1068, between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday (except holidays). Please call (202) 461-4902 for an appointment. This is not a toll-free number. In addition, during the comment period, comments may be viewed online through the Federal Docket Management System (FDMS) at

Read full report online