Using Salary Surveys to Establish Allowable Compensation
This webinar discusses the basics of what government contractors need to know about salary surveys and allowable compensation. Ken Bricker , a Partner in Cherry Bekaert’s Government Contractor Services Group , offers his expertise and advice on the following: Salary surveys used by the Defense Contract Audit Agency (“DCAA”); Litigation resulting from DCAA’s use of multiple salary surveys and findings of the Court; New compensation cap rules; and Finding a survey and using it correctly.
Recent Changes to DCAA Guidance on Expressly Unallowable Costs
Dealing with expressly unallowable costs can be a nightmare for any contractor. Between vague audit results from auditors to unexpected Form 1 issuances, mitigating the effects of Defense Contract Audit Agency (“DCAA”) identified expressly unallowable costs can be like navigating through an obstacle course blind. To bring clarity and consistency to auditor identification of expressly unallowable costs, the DCAA has recently issued two new memorandums on what it considers to be an expressly unallowable cost in accordance with the Federal Acquisition Regulation (“FAR”) and Defense Acquisition Regulations System (“DFARS”), and how to identify and cite those expressly unallowable costs during. Read More.
Incurred Cost Submissions: When Adequacy Means Success
Contracting with the government is one of the few situations where the word “adequate” results in a sigh of relief. Having Business Systems or an Incurred Cost Submission (ICS) deemed “adequate” often times means that you were successful in justifying (or in some cases defending) your methodologies and practices. While the Defense Contract Audit Agency (“DCAA”) has a sizeable backlog of ICSs, they have not hesitated to reject an ICS, often with multiple pages of reasons why. For the next several months, most government contractors’ inboxes will overflow with blogs, articles and discussions of Incurred Cost Submissions, the Allowable Cost. Read More.
Self-Certification Option for WOSB Eliminated
In November 2014, the Government Accountability Office (“GAO”) released a report entitled Women-Owned Small Business Program: Certifier Oversight and Additional Eligibility Controls Are Needed (Published October 18, 2014. Released November 7, 2014). The report showed that due to a lack of oversight and accountability on the part of the Small Business Administration (“SBA”), more than 40 percent of businesses who were awarded contracts in 2012 and 2013 under Women-Owned Small Business (WOSB) or Economically Disadvantaged Women-Owned Small Business (EDWOSB) status were in fact ineligible for WOSB or EDWOSB certification. SBA used to allow business owners to choose between paying a. Read More.
DoD Inspector General Sustains Hotline Complaint that DCAA did not Comply with GAGAS
In the past few years, the Department of Defense’s (“DoD”) Inspector General (IG) has conducted several reviews of the Defense Contract Audit Agency’s (“DCAA”) compliance with Generally Accepted Government Auditing Standards (GAGAS). According to a recent report, DODIG-2015-061, dated December 23, 2014, the IG sustained a hotline complaint alleging that DCAA: failed to comply with GAGAS when the auditor concluded that the contractor did not adequately support its claimed subcontract costs; and inappropriately applied a 20 percent decrement as a basis for questioning subcontract costs. Based on a statistical sample of 70 subcontract invoices, DCAA concluded the contractor could not. Read More.
Is the Federal Government Moving to a New Contracting Model?
In its continued effort to save the government (read: we the taxpayers) money, the General Services Administration (“GSA”) has implemented its Prices Paid Tool, which is available for all federal government agencies to use, as a part of the Federal Strategic Sourcing Initiative. This tool, developed with the Office of Management and Budget (“OMB”), is GSA’s effort to provide greater visibility on the prices paid by government agencies for commonly purchased goods and services bought through GSA Schedules. The pilot phase is currently focused on office supplies, domestic delivery services and Federal Acquisition Service (FAS) Alliant and Alliant Small Business. Read More.