Posts

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 capitaledgeconsulting.com.

 

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 and visibility. Join Industry experts from Capital Edge Consulting, Inc. as they review the compliance changes and obstacles that could directly affect government contractors’ compliance programs which may impact multiple areas of the business, including:

  • Cost accounting and allocation practices
  • Determination of allowable costs
  • Estimating and pricing practices
  • Business systems documentation and internal controls
  • Purchasing and supply chain management practices
  • Contract administration and financial reporting practices

This Seminar is intended for professionals in the areas of: 

  • Accounting or Finance
  • Compliance or Internal Audit
  • Program or Contract Management
  • In-house Counsel

Following the compliance and regulatory update, will be a live demo of JAMIS Prime ERP. During this demo, you will learn more about a system designed specifically for service-based government contractors. Prime ERP is proven to help even the most complex organizations comply with the time-consuming process of a DCAA audit.

Agenda

  • Complimentary Lunch
  • Introductions
  • Compliance Overview
  • JAMIS Prime ERP Demo
  • Q&A
  • Closing Remarks

Register for one of the JAMIS Software upcoming events by clicking the links below:

This seminar is part of an ongoing Lunch & Learn series provided to you by JAMIS Software and is eligible for CPE credits. 

JAMIS Software Partners with Capital Edge Consulting to Bring Complimentary GovCon Lunch and Learn Events to the Greater Boston and New York Areas

JAMIS Software and Capital Edge Consulting partner to bring Federal Contracting lunch and learn series to the greater Boston and New York areas on May 23 and 25

The May lunch and learn series will explore current DCAA audit updates and regulatory changes directly affecting the government contracting industry. Attendees will receive a complimentary lunch, while they hear from industry experts and sit in on an educational discussion of recent legislative, regulatory and DCAA audit guidance actions affecting compliance. Upon completion of this seminar, all participants will be eligible to earn CPE credits.

Managing Director at Capital Edge Consulting, Inc., Bill Keating will be presenting at the May events in Boston and New York.

Bill’s areas of expertise include the Cost Accounting Standards (CAS), Federal Acquisition Regulations (FAR), agency supplement regulations, contractor accounting, purchasing, estimating, MMAS and EVM Business Systems, Truth in Negotiations Act, government accounting requirements, incurred cost submissions (ICS), DCAA Audits support and preparation, other regulatory non-compliance support, terminations, requests for equitable adjustment (REA), ERP systems and risk mitigation.

Seminar participants will also have an opportunity network with each other and learn more about an ERP system designed specifically for service-based government contractors and federally funded not-for-profit enterprises. JAMIS Prime ERP system is proven to help even the most complex organizations comply with the time-consuming process of a DCAA audit.

“Establishing best-of-breed business practices and processes requires a highly specialized and productive software,” said Steve Brander, VP of Sales and Business Development, JAMIS Software. “Our goal is to educate attendees on the complexities of DCAA requirements and provide them with a solution that will ensure they can conquer an audit with ease.”

JAMIS’s lunch and learn events are hosted across the country and explore a wide variety of educational topics as well as provide expert insights into the government contracting industry best practices. Additionally, these events will provide networking opportunities for attendees and a chance to talk directly with industry experts. To learn more about lunch and learn events coming to your area, visit our website at: https://jamis.com/govcon-events/

About Capital Edge Consulting

Capital Edge Consulting combines unique backgrounds and experience in consulting, public accounting, industry, DCAA and DCMA to provide clients with unmatched government contracting expertise. This breadth of specialized experience enables them to provide the exact services and level of expertise federal government contractors need to succeed. Capital Edge Consulting provides custom-tailored consulting solutions to government contractors ranging in size from startup to Fortune 100 companies in industries such as manufacturing, nuclear energy, professional services, biotech/pharmaceuticals, defense, and information technology. To learn more about Capital Edge Consulting, please visit: http://www.CapitalEdgeConsulting.com

About JAMIS Software Corporation
JAMIS Software Corporation is a leading provider of ERP software solutions designed specifically for government contractors and other project-focused organizations. JAMIS delivers comprehensive, intuitive, innovative, and cost-effective solutions for the most respected names in government contracting. Companies large and small rely on JAMIS to provide detailed visibility into all of their projects, as well as provide the foundation for DCAA and other regulatory compliance. JAMIS helps companies connect with customers, partners, and employees in entirely new ways to foster new levels of collaboration and drive profitability and growth.

To learn more about JAMIS, visit JAMIS.com

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 $1.5 trillion annually – providing tremendous opportunity for vendors in a diverse range of industries to grow their public sector sales. As Onvia’s research reveals, the fastest growing Hotspots in government contracting for 2017 include:

  • Growing school bus services
  • Providing clean water
  • Serving those with disabilities
  • Preparing sites for construction
  • Strengthening disaster services
  • Upgrading to smart lighting
  • Enabling government with IT
  • Expanding connectivity
  • Innovating education
  • Improving medical equipment

These purchasing areas are representative of the diverse sectors in which government agencies choose to invest their money. Purchasing decisions driving growth in each of this year’s segments were found to be influenced by the following common themes:

  • Efficiency: Government decision-makers are focused on saving money and improving processes
  • Safety: Public safety concerns are a key driver of demand
  • Functionality: Taxpayers and buyers are looking for more features and functionality
  • Compliance: Rules and standards are driving contracts and affecting what is purchased
  • Opportunity: Small to mid-size businesses, as well as large enterprise vendors all have a significant opportunity in government

This year’s results reveal the current mentality of government buyers,” said B2G Market Analyst Paul Irby. “It’s simply a myth that public procurement professionals are motivated to only award the lowest bidder. With a better understanding of buyer needs, motivations and purchasing habits, vendors can set their firm up to earn more revenue from government contracts.”

The 2017 Hotspots in Government Contracting Offer a Wide Range of Opportunity

This report equips readers with useful insights for each Hotspot including the context and background driving growth, year-over-year growth analysis in published bids and RFPs and analysis on which states publish the most competitive contracting opportunities.

Looking at more than 4,000 unique industry tags, the analysis uses data from Onvia’s B2GIS to reveal the 10 fastest growing areas in B2G so marketplace participants can gain a better understanding of what’s driving government buying decisions in 2017.

Request a complimentary copy of the report here.

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 efficiency and effectiveness of contractors’ purchasing practices, and compliance with applicable laws, regulations and contract requirements. According to DCMA, the CPSR Group scheduled 134 CPSRs in the government fiscal year 2015 (ending September 30) and completed 121.

Get your copy of Part One – Insights from Our Recent CPSR Experiences below!

download-button-1

Federal Contractors Now Subject to “Basic Safeguarding” Cybersecurity Requirements

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 of Standards and Technology (NIST) Special Publication (SP) 800-171, “Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations.”

Attend the Capital Edge Consulting Sponsored- Cybersecurity Summit for Government Contractors: Hot Topics, Trends and Emerging Issues September 15, 2016 at the Crown Plaza Tysons Corner in McLean, VA.  
Learn more

The new provisions cover systems that process, store, or transmit Federal contract information with fifteen basic safeguarding requirements and procedures to protect covered contractor information systems. Requirements and procedures for basic safeguarding of covered contractor information systems shall include, at a minimum, the following security controls “reflective of actions a prudent business person would employ.”  Avoiding a direct reference to any pre-existing NIST standard, the rule’s new clause, at FAR 52.204-21(b), simply mandates a contractor apply the following “minimum” controls:

  1. Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
  2. Limit information system access to the types of transactions and functions that authorized users are permitted to execute.
  3. Verify and control/limit connections to, and use of, external information systems.
  4. Control information posted or processed on publicly accessible information systems.
  5. Identify information system users, processes acting on behalf of users, or devices.
  6. Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.
  7. Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.
  8. Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
  9. Escort visitors and monitor visitor activity, maintain audit logs of physical access, and control and manage physical access devices.
  10. Monitor, control, and protect organizational communications (e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.
  11. Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.
  12. Identify, report, and correct information and information system flaws in a timely manner.
  13. Provide protection from malicious code at appropriate locations within organizational information systems.
  14. Update malicious code protection mechanisms when new releases are available.
  15. Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.

For a complete review see federalregister.gov

Nothing on this list stands out as overly excessive, however, the specifics of contractors’ reporting obligations are unclear.  In the list, number 12 directs a contractor to “identify, report, and correct information and information system flaws in a timely manner.” The term “timely manner” is not defined in the Final Rule, but should be considered if the contracting agency does not further define its timeliness expectations.  In this regard, recognize that the Final Rule does not release a contractor of any additional specific safeguarding and reporting requirements specified by Federal agencies and departments (see, e.g., DFARS 252.204-7012) or that apply to systems that contain classified information or Controlled Unclassified Information (“CUI”).

The Final Rule also directs that the new clause found at FAR 52.204-21 be flowed down to all-levels of subcontracts, and is now to be included in the list of clauses found at FAR 52.213-4 Terms and Conditions – Simplified Acquisitions, and FAR 52.244-6, Subcontracts for Commercial Items.  The flow-down, however, only applies to contracts when the subcontractor “may have Federal contract information residing in or transiting through its information system.”

While the new rule has been in the process for quite some time, it should be seen as merely a step in terms of the final word.  The Final Rule actually states that it is “just one step in a series of coordinated regulatory actions being taken or planned to strengthen protections of information systems.”  Any contractors that are affected, should align their systems to meet these fundamental requirements and they should also expect this is just the beginning and prepare process and timeline documentation.

Please note, this final rule does not apply to the acquisition of COTS items because it is unlikely that acquisitions of COTS items will involve Federal contract information residing in or transiting through the contractor information system. Excluding acquisitions of COTS items reduces the number of small entities to which the rule will apply.

Want to receive regular feeds of our Newsletters, offer topic suggestions and get regular updates?  Register for the Newsletter or follow us on social links.

LinkedIn   –  Twitter  –  Facebook

To Learn more contact us:
T: 855-CAPEDGE (855-227-3343)  I  info@capitaledgeconsulting.com

CONTACT US ON LINKEDIN

Join LinkedIn Group- ASK an EXPERT: Government Contracting 

LinkedIn-Groups

Capital Edge Consulting Obtains Astero Consulting’s Senior Talent in Government Contracts

Industry Experts Bill Keating and John Van Meter Strengthen and Expand One of the Largest Government Contracting Consulting Firms

Reston, VA, August 30, 2016 –Capital Edge Consulting, Inc., a nationwide consulting firm that specializes in helping federal government contractors solve complex business challenges, announces that Astero Consulting’s founders and senior executives, Bill Keating and John Van Meter, have combined their business with Capital Edge Consulting.

Collectively, Bill and John bring nearly seven decades of consulting experience, and previously, each was the Partner-in-Charge of KPMG’s Government Contractor Advisory Services Practice. Both gentlemen bring Government, Commercial and International advisory expertise in business sectors such as aerospace and defense, construction and engineering, and information technology products and services.

Bill and John have significant expertise in the multiple rules of government contracts, including the Federal Acquisition Regulation (FAR), Federal Agency FAR Supplements, Cost Accounting Standards (CAS), and Federal Supply Schedules. They have advised organizations on government audits, procurement and other business systems compliance, claims preparation, contract disputes and investigations. They possess extensive knowledge of cost accounting matters for government contractors, including: systems requirements definitions, indirect rate structures, annual incurred cost submissions, CAS cost impact proposals, and CAS disclosure statements. At Capital Edge Consulting, they will focus on these regulatory and compliance matters for clients seeking to enhance accounting and business practices and manage risk. The two will work out of McLean, VA and San Jose, CA, respectively.

Also joining Capital Edge from Astero is Jean Labadini, a leading expert in Contractor Purchasing System Reviews (CPSR). Jean retired after 35 years with the Defense Contract Management Agency (DCMA) – her last role was as the Director of the CPSR Group. She has also served as an Administrative Contracting Officer (ACO), a Divisional Administrative Contracting Officer (DACO), and a Systems Administrative Contracting Officer (SACO). During her time at DCMA, Jean was a certified DCMA trainer and delivered Agency training on Advance Payments, Progress Payments, Performance Based Payments, Public Vouchers, and Commercial Item Financing. Jean will provide leadership within the Procurement and CPSR Consulting Practice of Capital Edge Consulting.

“Bill, John and Jean have a successful track record of helping clients navigate the complex government contracting environment, enhance their regulatory and compliance capabilities, and improve business performance,” said Chad Braley, CEO of Capital Edge Consulting. “They bring a wealth of knowledge and experience to the team and will help to further expand our capabilities, experience, and market presence. We are proud to welcome them to Capital Edge.” 

About Capital Edge Consulting

Capital Edge Consultants combine their unique backgrounds and experience in consulting, public accounting, industry, and DCAA to provide clients with unmatched government contracting expertise. This breadth of specialized experience enables Capital Edge to provide the exact services and level of expertise federal government contractors need to succeed. Capital Edge has provided custom-tailored consulting solutions to government contractors ranging in size, from startup to Fortune 100 companies in industries such as manufacturing, nuclear energy, professional services, biotech/pharmaceuticals, defense, and software.

To learn more about Capital Edge Consulting, visit www.CapitalEdgeConsulting.com

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 the government.

Prime contractors should review now existing business system processes and capabilities to address these requirements to avoid potential compliance risks – including, for example, CPSR adequacy and past performance evaluation.

Among the changes:

  1. Requires prime contractors to make good faith efforts to utilize their proposed small business subcontractors during performance of a contract to the same degree the prime contractor relied on the small business in preparing and submitting its bid or proposal.
  2. To the extent a prime contractor is unable to make a good faith effort to utilize its small business subcontractors as described above, the prime contractor is required to explain, in writing, within 30 days of contract completion, to the contracting officer the reasons why it was unable to do so.
  3. Authorizes contracting officers to calculate subcontracting goals in terms of total contract dollars in addition to the required goals in terms of total subcontracted dollars.
  4. Provides contracting officers with the discretion to require a subcontracting plan in instances where a small business represents its size as an other than small business.
  5. Requires subcontracting plans even for modifications under the subcontracting plan threshold if said modifications would cause the contract to exceed the plan threshold.
  6. Requires prime contractors to assign North American Industry Classification System (NAICS) codes to subcontracts.
  7. Restricts prime contractors from prohibiting a subcontractor from discussing payment or utilization matters with the contracting officer.
  8. Requires prime contractors to resubmit a corrected subcontracting report within 30 days of receiving the contracting officer’s notice of report rejection.
  9. Requires prime contractors to provide the socioeconomic status of the subcontractor in the notification to unsuccessful offerors for subcontracts.
  10. Requires prime contracts with subcontracting plans on task and delivery order contracts to report order level subcontracting information after November 2017.

To Learn more contact us:
T: 855-CAPEDGE (855-227-3343)  I  info@capitaledgeconsulting.com

Want to receive regular feeds of our Newsletters, offer topic suggestions and get regular updates? Register for the Newsletter or follow us on social links.

LinkedIn   –  Twitter  –  Facebook

CONTACT US ON LINKEDIN

Join LinkedIn Group- ASK an EXPERT: Government Contracting 

LinkedIn-Groups

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 that the cost or pricing data submitted meets the cost or pricing data requirements of FAR Subpart 15.4.

The accounting system should report specific financial data to support the cost or pricing data requirements under fixed price contracts such as indirect cost rate data. An adequate accounting system subject to DCAA preferences is most relevant to cost reimbursable contracts.  Under cost reimbursable contracts, the accounting system must be adequate and approved under FAR Subpart 16.3.  Obtaining approval is a significant accomplishment in this industry and working with experts will assure the process is successful.

Capital Edge Consultants assist contractors with their government contract cost accounting systems. This includes assisting them with identifying the need for and transitioning to a DCAA compliant systems when needed.  As we discussed, in some circumstances, this is a pre-requisite to winning cost reimbursable and other types of government contracts.

We also put together some great resources for you:

This Preaward Accounting System Adequacy Checklist is used for contractors new to government contracting that have cost reimbursement contracts, or for contractors that are receiving progress payments based on cost. The checklist assesses whether the requirements for an adequate accounting system have been met. dc

Another resource is the DCAA Accounting System Requirements overview.

To Learn more contact us:
T: 855-CAPEDGE (855-227-3343)  I  info@capitaledgeconsulting.com

Want to receive regular feeds of our blogs, offer topic suggestions and get regular updates? Follow us on social links.

LinkedIn   –  Twitter  –  Facebook

To Learn more contact us:
T: 855-CAPEDGE (855-227-3343)  I  info@capitaledgeconsulting.com

CONTACT US ON LINKEDIN

Join LinkedIn Group- ASK an EXPERT: Government Contracting 

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 unclear as to whether a contractor must be registered in SAM before submitting an offer or before award.

Issue
The purpose of the rule was to clarify an inconsistency with offeror representations and certifications. Federal Acquisition Regulation (FAR) Clause 52.204-7, System for Award Management, says that an offeror is not ‘‘registered in the SAM database’’ unless the offeror has completed its online annual representations and certifications. FAR Clause 52.204-8(b) and (d), Annual Representations and Certifications, state that if FAR Clause 52.204-7 is included in the solicitation, the offeror verifies by submission of the offer that the representations and certifications in SAM are current and accurate. While the clauses instruct offerors to complete representations and certifications by registering in SAM prior to submitting offers, the policy at FAR 4.1102, System for Award Management, states that SAM registration (which includes online representations and certifications) must be completed by the time of award.

The proposed rule changes this language to “Prospective contractors shall be registered in the SAM database at the time an offer or quote is submitted in order to comply with the annual representations and certifications requirements (see FAR subpart 4.12).” The proposed rule further states that the Contracting Officer “Shall verify that the prospective contractor is registered in the SAM database…at the time of offer or quote submission.”

What the rule does not state is what will happen if the prospective contractor is either: 1) not registered in SAM, or 2) registered in SAM but does not have a current representations and certifications in SAM. Will the prospective contractor be eliminated from the solicitation process or will it be allowed to update or register in SAM to be compliant? The proposed rule does not say.

Two other issues surrounding SAM registration may also emerge. First, will the requirement of SAM registration prior to proposal submission become a new component of the Contracting Officer’s toolbox in disqualify offerors? And, second, will a Federal contractor’s competitors be able to use the SAM registration requirement as a basis of protest with the Government Accountability Office (GAO)?

How You Can Use This Information
Interested parties should submit written comments to the General Services Administration (GSA) Regulatory Secretariat Division on or before July 19, 2016 that may be considered in the formation of the final rule. Comments pertaining to FAR Case 2015-005 may be submitted online, or via mail, as follows:

  • http://www.regulations.gov: Submit comments via the Federal eRulemaking portal by searching ‘‘FAR Case 2015-005’’. Select the link ‘‘Comment Now’’ that corresponds with ‘‘FAR Case 2015-005.’’ Follow the instructions provided on the screen. Include your name, company name (if any), and ‘‘FAR Case 2015-005’’ on your attached document.
  • Comments via mail should be sent to:
    General Services Administration, Regulatory Secretariat
    Division (MVCB), ATTN: Ms. Flowers
    1800 F Street NW, 2nd Floor
    Washington, DC 20405

You should submit comments only and cite “FAR Case 2015-005” in all correspondence. Any comments received will be posted without change to http://www.regulations.gov, including any personal and/or business confidential information provided.

Originator-Robin Eggen in GovCon 360 news