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Government Contractors

Another Delay for SAM?

System for Award Management (SAM) is a federal government database that will eventually combine the data from multiple databases or systems to provide a single portal for contractors, grantees, and federal agencies. In July 2011, eight systems were projected to be included in SAM by the end of 2014. Currently, only four systems, Central Contractor Registration (CCR), Online Representation and Certifications Application (ORCA), Excluded Parties List System (EPLS) and Federal Agency Registration (FedReg) have been combined. On July 31, 2014, the president issued an Executive Order (Order): Fair Pay and Safe Workplaces . It requires federal contractors submitting an offer for a contract of goods. Read More.

ERC President Testifies for False Claims Act

In front of the House Judiciary Subcommittee on the Constitution and Civil Justice, Ethics Resource Center’s (“ERC”; “the Center”) Patricia Harned shared her thoughts on potential amendments to the False Claims Act. During testimony , the Center’s president told Congress that certification of private sector ethics and compliance programs are beneficial in protecting taxpayers from fraud by government contractors. She further stressed that the programs should give equal focus to both ethics and compliance, which lessens the need for enforcement caused by False Claims Act violations. Referencing the ERC’s research, Harned also noted that companies with strong ethics and compliance programs take. Read More.

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Unbilled Accounts Receivable: Real or Imagined Assets?

Unbilled accounts receivable (A/R) represents recorded revenue that has not yet been billed on a contract. There can be many different reasons for having unbilled A/R recorded on the balance sheet (B/S). Government contractors with cost reimbursable contracts tend to have greater unbilled accounts that stay on the B/S longer. The most common reasons for unbilled A/R are the following: Timing differences: These can exist due to the normal timeframe of processing employee timesheets and invoices through the accounting system. These amounts should be billed as soon as possible in accordance with contractual terms. Rate variances: These can exist when. Read More.

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DCAA Issues Guidance on Dealing with Delinquent Final Indirect Cost Rate Proposals

On February 3, 2014, the Defense Contract Audit Agency (“DCAA”) issued Memorandum for Regional Directors (MRD) 14-PPD-002(R), entitled, Treatment of Delinquent Final Indirect Rate Proposals. As indicated by the title, the guidance addresses steps DCAA and the Defense Contract Management Agency (“DCMA”) will take when a contractor does not submit its final indirect cost rate proposal on time. Before discussing the MRD, some background information on submission of final indirect cost rate proposals is in order. Contrary to the belief of some DCAA auditors, contractors do not have an inherent duty to establish final indirect cost rates. Instead, contractors are. Read More.

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Four MRDs issued by DCAA in June 2014

In June, the Defense Contract Audit Agency (“DCAA”) issued four Memoranda for Regional Directors (MRDs) that can be of interest to contractors. Two of the MRDs related to conducting audits under the Defense Federal Acquisition Regulation Supplement (DFARS) business systems rule. The first is MRD 14-PAS-009(R) Audit Guidance on Reporting Business Systems Deficiencies , (June 26, 2014). The primary objective of this MRD was to provide clarifying guidance on how to report shortcomings in a business system that do not rise to the level of a significant deficiency, as defined in the relevant business systems clause. Under the various business systems clauses, a distinct definition is provided of what. Read More.

Webinar: Gain Clarity on How the Affordable Care Act will Impact Service Contract Act Contractors

This webinar discusses the impact of the Affordable Care Act (“ACA”) on employers who operate contracts under the Service Contract Act (“SCA”). John Carpenter, Leader of Cherry Bekaert’s Government Contractor Services Group, Ken Bricker, a Partner in the Government Contractor Services Group, and Kevin Quinn, a Partner in Cherry Bekaert Benefits Consulting, offer their expertise and advice.

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