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Government Contractors

SBA Issues Proposed Rule to Allow Lower Tier Small Business Subcontractors to Qualify Toward Small Business Subcontracting Goals

On October 6th, 2015 the Small Business Administration (“SBA”) issued a proposed rule to allow “other than small” business prime contractors, with small business subcontracting plans, to receive credit for awarding subcontracts to small businesses at any tier level. Under the current regulations, credit toward small business subcontracting goals is awarded only at the first tier level. The proposed rule seeks to further the government’s overall commitment to providing Federal procurement opportunities to small business. Federal Acquisition Regulation (“FAR”) 52.219-9(l), which provides regulations governing small business subcontracting plans, states the “subcontract award data reported by prime Contractors and subcontractors shall. Read More.

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DCAA Issues Revised ICS Adequacy Checklist

The Defense Contract Audit Agency (“DCAA”) recently issued Memoranda for Regional Directors (MRD) 15-PPD-005(R), Revised Checklist for Determining Adequacy of Contractor Incurred Cost Proposal, dated August 27, 2015. This MRD provides the first update in over three years to the Incurred Cost Submission (ICS) Adequacy Checklist. The guidance provides clearer expectations on the purpose of the adequacy review and to clarify the effort required in assessing contractor proposals for adequacy. More specifically, the checklist was revamped to simplify the adequacy process so that audit teams are not spending effort performing procedures during the adequacy review that could be performed during. Read More.

DoD Issues New Rule on Cybersecurity Reporting

It is rare for the Department of Defense (“DoD”) to issue an interim rule without first issuing the proposed rule for comment. It does occasionally happen, as the DoD has in this case. Effective August 26, 2015, contractors and subcontractors are required to report cyber incidents that result in an actual or potentially adverse effect on a covered contractor information system or covered defense information residing therein, or on a contractor’s ability to provide operationally critical support. This reporting is to be done within 72 hours of discovery. The new rule comes from requirements in the National Defense Authorization Act. Read More.

Department of Defense Seeks to be Notified of New Contractor IR&D

On August 25, 2015, the Department of Defense (“DoD”) issued a white paper entitled, Enhancing the Effectiveness of Independent Research and Development. The white paper outlined a proposed requirement for contractors to notify the DoD prior to starting work under new Independent Research & Development (“IR&D”) efforts. This requirement would be effective for all new IR&D projects beginning in Fiscal Year (FY) 2017. Additionally, DoD notification would be required for contractors to claim IR&D costs as an allowable cost under Federal Acquisition Regulation (FAR) 31.205-18. The white paper, released by Frank Kendall, the Under Secretary of Defense Acquisition, Technology, and. Read More.

Executive Order Establishing Paid Sick Leave Requirements for all Federal Contractors

On September 7, 2015, President Obama instituted an Executive Order establishing paid sick leave requirements for all Federal contractors. The Order requires contractors to establish a policy for employees to earn at least seven paid sick days a year (56 hours), to include sick leave to tend to family members. Part-time employees will receive one hour of paid sick leave for every 30 hours worked. The Order allows for sick leave to be carried forward from year to year, but does not require payment for unused leave upon job separation. Contractors cannot require an employee to find a replacement when. Read More.

OMB Announces Government’s Science and Technology Priorities for FY17

Companies interested in the Federal government’s priorities for science and technology may want to check out the Office of Management and Budget July 9, 2015, Memorandum for the Heads for Executive Departments and Agencies, which provides guidance for formulating the Fiscal Year (FY) 2017 Budget Submission. Agencies are encouraged to work together on complementary activities and coordinate their budgets for maximum impact. Priorities outlined in the memo include the following: Global climate change, particularly the 2012-2021 U.S. Global Change Research Program Strategic Plan, in addition to other activities. Clean energy, in conjunction with the President’s Climate Action Plan. Renewable energy. Read More.