Tag Archives | DoD

Low Priced Technically Acceptable (LPTA) Source Selections and Firm Fixed Price (FFP) Contracts in Jeopardy? Or has the DoD Procurement Pendulum Swung?

If you are not a fan of LPTA solicitations or FFP contracts, then there is good news for you! On March 4th of this year, Frank Kendall, the DoD Under Secretary of Defense for Acquisition, Technology and Logistics, issued a memo to the procurement and contracting offices of the DoD stating that LPTA “…has a…limited […]

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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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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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Apathy and the Business Systems Rule

DOD proposed a major change to the Business Systems Rule (and GovCon compliance in general) and it has received very little industry attention. A proposed change to the Defense FAR supplement published in the Federal Register on July 15th would make some government contractors responsible for audits of their own accounting, estimating and material management […]

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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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A New Twist on the Business Systems Rule

DOD has relieved DCAA of yet another of its responsibilities and put the burden squarely on government contractors. A proposed change to the Defense FAR supplement published in the Federal Register July 15th, would make government contractors responsible for audits of their own accounting, estimating and material accounting systems, including engaging and paying a CPA […]

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DOE Jumps on the Business System Bandwagon

Late last year DOE became the first civilian agency to follow in DOD’s footsteps and adopt formal criteria for adequacy of contractor business systems. Like DOD’s, the new DOE regulations allow contracting officers to withhold a portion of contractor payments for system deficiencies, but the real impact will be in winning new work. Click here […]

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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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To WARN or not to WARN; NOT!

Apparently both the White House and DoD believe that you don’t have to WARN your employees according to memos issued on Friday.  Plus, any additional costs a contractor incurs due to Sequestration for Mass Layoffs, Plant closings, etc. will be “allowable” in its termination claim.    See Federal News Radio Artilce:     http://www.federalnewsradio.com/1007/3058915/Agencies-could-be-liable-for-certain-costs-under-sequestration   And attached […]

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