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Spring cleaning tips for government contractors

May 24, 2019 By Andrew Smith

If you are a government contractor, you should consider this to be the season to do some spring cleaning in terms of your government contract compliance programs and procedures.  Not to be an alarmist, but there are numerous areas you can review now and, if you should find some compliance deficiencies, you still have ample time to get your house in order before an agency audit or the deadline for submission of certain government reports.

Set forth below is a list of areas you may want to clean up…

Continue reading at:  Blank Rome’s Government Contracts Navigator

Filed Under: Contracting Tips Tagged With: audit, compliance, contract audit, contract compliance

DCAA guidance clarifies cost or price analysis requirements for subcontractor proposals

November 1, 2017 By Andrew Smith

The Defense Contract Audit Agency (DCAA) recently published a Memorandum for Regional Directors (MRD), titled “Audit Alert on Requirement for Prime Contractor Cost and Price Analyses,” that provides answers to frequently asked auditor questions regarding cost and price analyses to establish the reasonableness of proposed subcontract prices.

Importantly, the MRD states that DCAA auditors should proceed with subcontract proposal audits even if contractor cost or price analyses are not yet available. This should help mitigate what has been a continuing problem for prime contractors—long waits for DCAA audits of subcontractor proposals—and expedite contract price negotiations.

FAR 15.404-3(b) requires a prime contractor or subcontractor to establish the reasonableness of proposed subcontract prices and to provide supporting cost or price analyses in the proposal. In certain circumstances, a prime contractor may not be able to complete the cost or price analyses by the time it submits a proposal. In such cases, the prime contractor may include a matrix in the proposal identifying the dates by which it expects to receive subcontractor proposals. The MRD states that this type of matrix does not satisfy the requirement to submit supporting cost or price analyses in the proposal, and a DCAA auditor would mark the proposal as inadequate on grounds of incomplete cost or price analyses.

Keep reading this article at: http://www.mondaq.com/article.asp?articleid=640002

Filed Under: Contracting News Tagged With: audit, contract audit, cost and price analysis, DCAA, subcontracting

GSA seeks industry feedback on Civilian Contract Audit Services Ordering Guide

October 13, 2017 By Andrew Smith

The federal government’s Civilian Contract Audit Services Working Group, made up of representatives from more than 13 federal agencies and co-led by the General Services Administration (GSA) and the Federal Aviation Administration, is seeking industry feedback on a Civilian Contract Audit Services Ordering Guide. The Ordering Guide is the result of a cross-agency collaboration to explore options to help agencies efficiently and effectively meet their contract audit requirements.

The Ordering Guide sets forth best practices for issuing task orders against the GSA Multiple Award Schedules for professional services to fill agencies’ contract audit requirements and  includes guidance on:

  • Contract direct costs,
  • Incurred Cost Proposal for Final Overhead and/or Billing Rates,
  • Accounting System Reviews,
  • Cost Accounting Standards,
  • Forward Pricing Rate Agreements,
  • Invoice/voucher review, and
  • Others, as necessary

The guide supports the Professional Services Category initiative identified as a critical component to meeting current and future contract audit requirements, and ultimately reducing the opportunity for contract duplication.

It is important to note that the DCAA heretofore has been, and in many cases continues to be, the primary source for the conduct of contract audits for cost reimbursable contracts. However, there are circumstances (i.e., work stoppages, capacity, cognizance, etc.) that may require agencies to procure these services from commercial sources. GSA’s Professional Services Schedule addresses that need.

The draft Ordering Guide is available on FedBizOpps (FBO) under Request for Information (RFI) number 1246131. Please provide comments as instructed on FBO.  Responses in Portable Document Format (PDF) compatible format are due no later than ​5:00 PM PST, October 27, 2017.  Responses must be submitted via e-mail to ccas@gsa.gov. Proprietary information, if any, should be minimized and MUST BE CLEARLY MARKED. Please be advised that all submissions become Government property and will not be returned.

The information provided will be utilized for preliminary planning purposes by the Government to facilitate the decision making process and will not be disclosed outside of the Government. All data received that is marked or designated as corporate or proprietary information will be fully protected from release outside the Government.

For more information contact: ccas@gsa.gov

Filed Under: Contracting News Tagged With: accounting, best practices, civilian contract audits, contract audit, cost accounting standards, DCAA, GSA, GSA Schedule, MAS, multiple award schedule, ordering guide, Professional Services Schedule

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