CAS Board Discussions – Edition 11
In this week’s Capital Edge Tip Line, CEO Chad Braley dives deeper into the ongoing CAS Board Discussions and the areas that Capital Edge has followed and commented on during the open public period.
What’s happening? CAS Board Discussions are underway and we're here to provide updates based upon what we've followed and commented on during the open public period.
What's being discussed?
What this means for you:If these proposed CAS updates move forward, they could ease the compliance load for many contractors while keeping meaningful oversight in place. Discussions are underway and we’ll continue to monitor developments and keep you informed.
Stay Ahead with Capital Edge
Whether you're trying to keep up with the ever-changing government contracting landscape or need help navigating the costs of non-compliance, Capital Edge is here to help and respond.
Have Questions?
Contact us today to discuss how you can position your organization to stay ahead.
FAR Overhaul Update: FAR Part 31 Main Takeaways – Edition 10
In this week’s Capital Edge Tip Line, CEO Chad Braley dives deeper into the Revolutionary FAR Overhaul (RFO) and what you need to know about the changes to FAR Part 31.
What’s happening? We've been anticipating updates from the Revolutionary FAR Overhaul (RFO) and are starting to get answers.
What's changed?
What this means for you: This round of FAR updates didn’t eliminate complexity or streamline compliance. It just brought language up to date with current practices. Expect more buying guides, more trickle-down guidance, and if you're in compliance or contracts, plenty of job security.
Stay Ahead with Capital Edge
Whether you're trying to keep up with the ever-changing government contracting landscape or need help navigating the costs of non-compliance, Capital Edge is here to help and respond.
Have Questions? Need Help?
Contact us today to discuss how you can position your organization to stay ahead.
DCAA Sustainment Rates, Audit Timelines & OTA Government Contracts - Edition 9B
With DCAA's FY2024 data now in focus, contractors are getting clearer insights into what sticks in an audit—and what doesn’t. In this week’s Capital Edge Tip Line, CEO Chad Braley breaks down the agency’s audit sustainment rates, completion timelines, and growing oversight into OTA government contracts. He also highlights where audit activity is rising in other agencies, including HHS.
???? What’s happening? Nearly 49% of DCAA audit exceptions were sustained by contracting officers across all categories in FY2024.
???? Breakdown by audit type:
???? What it means for you:
???? Action Item: Treat every audit finding seriously. Even if the audit occurred years ago, current sustainment decisions may still apply.
???? What’s happening? Audit cycle times remain long, particularly for complex systems reviews.
???? Average durations:
???? Chad’s take: A low-risk letter from DCAA does not equal a clean bill of compliance. Many contractors assume approval when they’ve only passed the adequacy checklist.
???? Action Item: Prepare for extensive durations. Keep your documentation current, even if your last contact from DCAA was a simple memo.
???? What’s happening? DCAA evaluated over $550 million in OTA costs in FY2024, despite their FAR-exempt status.
???? What it means for you:
???? Action Item: Don’t rely on OTA exemptions. Structure records and reporting as if the agreement will be audited.
???? What’s happening? Other agencies like HHS are leaning on third-party auditors to scrutinize historic contract activity.
???? Example: HHS recently initiated audits on a 2020 CAS change with a $75,000 cost impact—years after the fact.
???? Action Item: Be proactive in documenting cost changes and rate adjustments, even if years have passed. Third-party audits are expanding.
Stay Ahead with Capital Edge
Whether you're preparing for a business systems review or need help navigating OTA government contracts, Capital Edge is your trusted compliance partner.
???? Have Questions? Need Help?
Connect with Capital Edge Consulting for proven audit strategies.
???? Contact us today to discuss your strategy for staying tariff-ready.
Stay informed. Stay compliant. Stay ahead.
DCAA’s newly released FY24 Report to Congress offers a rare window into the agency’s audit activity, exception rates, and cost savings metrics. In this week’s Capital Edge Tip Line, CEO Chad Braley unpacks the highlights, questions the numbers behind the “return on investment” claims, and shares what it all means for contractors going forward.
???? What’s happening? DCAA examined nearly $600 billion in contract costs, the most in five years, while claiming $5.1 billion in net taxpayer savings and a $7.20 return on every audit dollar.
???? What it means for you:
???? Action item: Forward pricing submissions remain high-risk for audit. Consider strengthening supporting documentation before submission.
???? What’s happening? DCAA identified $5.9 billion in audit exceptions—about 2.7% of the total costs reviewed.
???? Breakdown by type:
???? Action item: Prioritize internal reviews for forward pricing and terminations. Even with lower scrutiny, ensure incurred cost submissions are clean and defensible.
???? What’s happening? DCAA now includes “monetized estimates” of cost savings from business system and CAS audits—even when no direct dollar findings are issued.
???? What it means for you:
???? Chad’s take: "We’ve seen system reviews identify material weaknesses without any financial findings. It’s unclear how DCAA is projecting cost savings from these reviews.”
???? Action item: Don’t just watch for audits, watch how agencies justify value. Audit scrutiny may not follow volume alone.
Stay Ahead with Capital Edge
DCAA’s evolving focus, audit thresholds, and performance metrics directly impact how contractors prepare for oversight.
???? Have Questions? Need Help?
Reach out to Capital Edge Consulting to ensure your audit strategy aligns with DCAA expectations.
???? Contact us today to discuss your strategy for staying tariff-ready.
Stay informed. Stay compliant. Stay ahead.
With growing uncertainty around new tariffs, contractors are wondering how to handle potential price shifts and regulatory protections. In this week’s Capital Edge Tip Line, CEO Chad Braley offers practical insights into how federal contractors can prepare, propose, and protect themselves when duties are imposed mid-contract.
???? What’s happening? While “tariffs” aren’t mentioned directly in key regulations, terms like “duties” are and they matter. Relevant clauses include:
???? What it means for you:
???? Action item: Review your active contracts and proposal templates to ensure you are accounting for potential duties. Be proactive about exemptions and document cost reasoning clearly
???? What’s happening? With tariff rules evolving, contractors must consider how to price and structure bids, especially those in pre-award stages.
???? What it means for you:
???? Action item: Evaluate where your goods and services are sourced and understand which materials may be affected. Build pricing flexibility into proposals where feasible.
???? Chad doesn’t expect tariffs to be as catastrophic for government contractors as some fear. With the right preparation and contract structure, organizations can protect themselves and minimize exposure.
???? Claims and REAs (Requests for Equitable Adjustments) are likely to increase, but so is the opportunity to manage risk effectively.
Stay Ahead with Capital Edge
Whether you're managing live contracts or preparing new bids, Capital Edge can help you align your cost strategy with regulatory protections.
???? Have Questions? Need Help?
Reach out to Capital Edge Consulting to talk through your specific contracting concerns.
???? Contact us today to discuss your strategy for staying tariff-ready.
Stay informed. Stay compliant. Stay ahead.
From tariff volatility to sweeping federal procurement reforms, this week’s Capital Edge Tip Line dives into urgent updates that could affect how your contracts are priced, managed, and reimbursed. CEO Chad Braley breaks down how contractors should respond to shifting agency expectations and regulatory guidance.
???? What’s happening? The Department of Energy released new memorandums limiting indirect costs recoverable by:
???? What it means for you:
???? Action Item: Reevaluate indirect rate structures, especially if you’re pursuing active DOE funding opportunities. Watch NOFO language closely for cost recovery terms.
???? What’s happening? A wave of Contracting Officer Final Decisions (COFDs) is hitting contractors without prior audit warnings, often citing non-compliance, CAS violations, or questioned costs.
???? What it means for you:
???? Action Item: Prepare for increased enforcement. Shore up DCAA audit documentation, evaluate potential exposure areas, and engage early on audit or rate disputes.
???? What’s happening? The revolutionary rewrite of the Federal Acquisition Regulation has begun, with updates issued for:
???? What it means for you:
???? Action Item: Track ongoing FAR consolidation updates and prepare for further FAR changes. Monitor whether your agency introduces supplements or deviations.
Whether you're navigating funding caps, audit risks, or regulatory overhauls, Capital Edge Consulting provides the strategic guidance you need.
???? Have Questions? Need Help?
If these developments could affect your business, don’t wait, reach out for support tailored to your compliance and contracting needs.
???? Contact us today to discuss your specific challenges and compliance needs.
From tariff volatility to sweeping federal procurement reforms, this week’s Capital Edge Tip Line dives into urgent updates that could affect how your contracts are priced, managed, and reimbursed. CEO Chad Braley breaks down how contractors should respond to shifting agency expectations and regulatory guidance.
???? What’s happening? Contractors are facing uncertainty as new tariff percentages are debated and implemented. While rates may shift, the focus is on how contracts handle these costs.
???? What it means for you:
???? Action item: Immediately assess relevant contract clauses and prepare internal guidance on how to account for tariffs during budgeting and cost disclosure.
???? What’s happening? A recent Executive Order mandates agencies to justify any ongoing or planned purchases of non-commercial goods and services.
???? What it means for you:
???? Action item: Contractors should evaluate their current offerings and explore repositioning them as commercial solutions where possible. Monitor solicitations for updated compliance requirements.
???? What’s happening? The Department of Energy is undergoing significant personnel losses. Over 2,700 staff have opted into voluntary separation programs, with further reductions expected.
???? What it means for you:
???? Action item: Engage your DOE points of contact frequently. Prepare invoices proactively and clarify funding timelines to avoid disruptions.
Whether you're navigating tariffs, agency mandates, or payment delays, Capital Edge is here to help you mitigate risk and maintain compliance.
???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.
???? Contact us today to discuss your specific challenges and compliance needs.
From executive orders reshaping defense acquisitions to sweeping changes in research grant funding and regulatory rewrites, this week’s Capital Edge Tip Line delivers must-know updates for Government contractors and research institutions. CEO Chad Braley dives into how these developments may impact your compliance strategy and cost structure moving forward.
???? What’s happening? A new Executive Order initiates sweeping defense acquisition reform, directing the Department of Defense (DoD) to prioritize commercial acquisition strategies and streamline internal procurement processes.
???? What it means for you:
???? Action Item: Evaluate your DoD programs for compliance with performance benchmarks and be prepared for increased scrutiny of cost, timeline, and strategic value.
???? What’s happening? The Department of Energy (DOE) has issued new policy guidance capping indirect costs for grants to research institutions and universities at 15%—mirroring NIH’s controversial playbook.
???? What it means for you:
???? Action Item: Assess current grant-funded projects for exposure to this cap and explore options for reclassifying certain expenses as direct costs. Be proactive in preparing legal and financial strategies.
???? What’s happening?
The Federal Acquisition Regulation (FAR) is undergoing a major transformation, with non-statutory content being removed and repurposed into “buying guides.”
???? What it means for you:
???? Action Item: Begin evaluating current contract practices against statutory requirements. Track future buying guide releases and plan for increased variability in how guidance is applied.
The pace of change in federal contracting has never been faster. The Capital Edge Tip Line is your trusted source for expert guidance on compliance, audit readiness, and regulatory transformation.
???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.
???? Contact us today to discuss your specific challenges and compliance needs.
Federal contracting is experiencing a seismic shift with the rewrite of the Federal Acquisition Regulation (FAR), agency restructures, and widespread layoffs that could disrupt programs and timelines. In this week’s Capital Edge Tip Line, CEO Chad Braley delivers a fast-paced breakdown of the latest developments, from the 40th anniversary of the FAR to looming compliance and audit implications across HHS, DCAA, and NIH.
????What’s happening? April 1 marked the 40th anniversary of the Federal Acquisition Regulation. Now, a major rewrite is underway.
???? What it means for you:
Action Items: Contractors should prepare for evolving compliance requirements by reviewing current FAR sections and tracking FAR Council updates.
???? What’s happening? The Defense Contract Audit Agency is undergoing significant restructuring.
???? What it means for you:
???? Action item: Audit preparedness is more critical than ever. Ensure audit trails and documentation are up-to-date and compliant with current expectations.
???? What’s happening? Mass layoffs at Health and Human Services have eliminated entire program offices, leaving contractors with active contracts but no points of contact.
???? What it means for you:
???? Action item: Immediately identify all HHS contracts and assess who your current contacts are. Prepare to act quickly on terminations or restructuring guidance.
???? What’s happening? Litigation continues around NIH’s attempt to cap indirect rates on research grants.
???? What it means for you:
???? Action item: Stay in close contact with legal and grant management teams to monitor the case. Prepare budgets for both capped and uncapped scenarios.
Stay Ahead with Capital Edge The pace of change in federal contracting has never been faster. The Capital Edge Tip Line is your trusted source for expert guidance on compliance, audit readiness, and regulatory transformation.
???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.
???? Contact us today to discuss your specific challenges and compliance needs.
Federal compliance continues to evolve, with significant updates impacting government contractors across multiple fronts. In this week’s Capital Edge Tip Line, Chad Braley, CEO of Capital Edge Consulting, shares expert analysis on the latest DCAA audit program updates, GSA’s procurement consolidation, and new USAID compliance guidance. Whether you're in compliance, finance, or contract management, these insights are essential for staying ahead.
In Edition 2, Chad, delves into critical developments, including:
???? What’s happening? DCAA has quietly released or revised over 30 audit programs, impacting home office allocations, professional consultant costs, estimating systems, and accounting systems.
What it means for you:
???? Action item: Contractors should assess which audit programs apply to their operations and confirm internal controls and documentation meet the updated standards.
???? What’s happening? GSA is set to consolidate over $400 billion in acquisition services, dramatically increasing its procurement footprint.
What it means for you:
???? Action item: Monitor GSA procurement updates and engage early with contracting officers to stay ahead of changes in contract administration.
???? What’s happening? USAID issued updated guidance allowing grant recipients to begin invoicing for costs related to stop work orders. While initially targeting grants, the guidance will likely extend to contractors.
What it means for you:
???? Action item: Prioritize assembling and submitting invoices for stop work order costs. Seek advisory support to ensure completeness and compliance.
Stay Ahead with Capital Edge The regulatory environment is shifting quickly, and staying proactive is essential. The Capital Edge Tip Line delivers real-time updates and expert perspectives to help you stay compliant and competitive.
???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.
???? Contact us today to discuss your specific challenges and compliance needs.