Significant Proposed Changes to DFARS Business System Monitoring Requirements
On July 15, 2014, the Department of Defense (“DoD”) issued a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) on government contractor business system requirements. The comment period for the proposed change ended on September 15, 2014. The proposed rule requires that contractors begin annual self-evaluations and reporting on their accounting system, material management and accounting system (MMAS), and estimating system, for those contractors required to maintain approved systems in accordance with the DFARS business system requirements. In addition, a Certified Public Accountant (CPA) audit is required to be performed by an independent firm of the contractor’s. Read More.
Topics: Accounting Systems, Audit, Defense Contract Management Agency "DCMA", Defense Federal Acquisition Regulation Supplement "DFARS", Department of Defense "DoD", Earned Value Management System "EVMA", Estimating Systems, Government Contractors, Material Management and Accounting System "MMAS", Property Management System Evaluations, Purchasing Systems
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.
Topics: Allowable Cost and Payment, Audit, Defense Contract Audit Agency "DCAA", Defense Contract Management Agency "DCMA", Defense Federal Acquisition Regulation Supplement, Federal Acquisition Regulation "FAR", Government Contracting, Indirect Cost Rates, Memorandum for Regional Directors "MRD"