Tag Archives | DFARS

Proposed DFARS Business Systems Compliance Rule – Dead on Arrival

The proposed DFARS Business Systems Compliance Rule DFARS Case 2012-D042 has been closed. It’s an interim rule that never made it to final. Surprised? Read on! The July 22, 2014 ruling was conceived in response to a Government Accountability Office Report (GAO-12-83) issued November 3, 2011, which recommended “the Secretary of Defense work with DCMA […]

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Revenue Recognition on Materials Purchases – Gross or Net?

Government Contracts often include tasks requiring the Contractor to make purchases on behalf of the Government Customer. It’s important in these circumstances to consider whether the Contractor is, in reality, acting as an Agent. That conclusion might impact how the revenue for such activity is to be reported under U.S. GAAP – gross or net. […]

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DFARS Proposal Checklist Finalized

Effective December 11, 2014, the Department of Defense (DoD) finalized the Contractor Forward Pricing Rate Proposal Adequacy Checklist amending the Defense Federal Acquisition Regulation Supplement (DFARS). The finalized checklist contains 24 involved questions that address general instructions, direct labor, indirect rates and cost of money. There has been a lot of concern in regards to […]

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Is Your Accounting System Adequate and Acceptable?

DoD first published the Business Systems Rule (BSR) as an interim rule in May 2011. The Rule provides for partial withholding of payments on CAS-covered contracts when any one of a contractor’s business systems is determined to have a significant deficiency. Certainly that could be a problem, but the real issue with the BSR came […]

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U.S. Federal Regulatory Agenda

Ever wondered what’s on the minds of the regulatory folks at the agency where you perform work?  Well now you can find out!    The Regulatory Information Service Center (RISC) gathers and publishes information on Federal regulations by Agency in its annual “Unified Agenda” located at: http://www.reginfo.gov/public/do/eAgendaMain.  The Regulatory Plan, which is published as part of […]

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