How Many Contractors Does It Take to Run the Government?
By: John Ford , Senior Consultant, Government Contractor Services Group For many years, there has been a debate as to how many contractors are performing work for the government. This issue has two components: (1) the number of entities holding contracts; and (2) the number of individuals who are actually performing those contracts. While the former is fairly easy to determine, the latter is more problematic. This article will discuss two of the tools available to the government to make this determination. These tools also help the government to know how much these employees are costing the government. The first tool, required. Read More.
Topics: Contractor Manpower Reporting Application "eCMRA", Contractor Performance Assessment Reports System “CPARS”, Defense Federal Acquisition Regulation Supplement "DFARS", Department of Defense "DoD", Federal Acquisition Regulation "FAR", Government Contractors, Service Contract Act "SCA", System for Award Management "SAM"
The “How-To” for Defining Profit or Fee in DoD Price Proposals
A common question many contractors may find themselves asking: “How are we going to determine and bid profit/fee percentages to be applied in a proposal?” As always, each individual contractor has the right to determine the amount of applied profit/fee they want to bid for each contract. Dependent upon work scope, products/services offered, and even contract type, the risk is different and the competition providing proposals to the end users can vary greatly without going over statutory limitations. Contractors can utilize the Defense Federal Acquisition Regulation Supplement (“DFARS”) Weighted Guidelines approach as a tool in determining their profit negotiation position,. Read More.
DoD’s Final Rule on Counterfeit Electronic Parts Safe Harbor
On August 2, 2016, the Department of Defense (“DoD”) issued its final rule on Detection and Avoidance of Counterfeit Electronic Parts—Further Implementation. The rule amends the Defense Federal Acquisition Regulation Supplement by laying a safe harbor related to counterfeit and suspect counterfeit electronic parts. The safe harbor has three parts: The contractor must establish and maintain a system to detect and avoid counterfeit and suspect counterfeit electronic parts. The contractor must obtain review and approval of its system from DoD. The counterfeit or counterfeit suspect electronic parts must have been provided to the contractor as government property, or the contractor. Read More.
DoD Proposes Changes to Cost or Pricing Data Rules for Small Businesses
On August 30, the Department of Defense (“DoD”) issued a proposed rule to implement a section of the National Defense Authorization Act for fiscal year 2016 that provides exceptions from the certified cost and pricing data requirements, and from the records examination requirement for certain awards to small businesses or nontraditional defense contractors. The proposed rule would amend the Defense Federal Acquisition Regulation Supplement (“DFARS”) to provide an exception from cost or pricing data for contracts, subcontracts, or modifications of contracts or subcontracts valued at less than $7.5 million. This exception would be applicable to small businesses or “nontraditional” defense contractors,. Read More.
Topics: Cost Accounting Standards "CAS", Cost Data, Defense Federal Acquisition Regulation Supplement "DFARS", Department of Defense "DoD", National Defense Authorization Act "NDAA", Pricing Data, small business
Department of Defense Continues to Tinker with the Allowability of IR&D
Beginning in 2011, the Department of Defense (“DoD”) began making changes to the supplemental cost principle on Independent Research and Development (IR&D) found at the Defense Federal Acquisition Supplement (DFARS) 231.205-18. These changes have not affected the definition of IR&D found at Federal Acquisition Regulation 31.205-18. Instead, they have addressed what certain contractors must do in order for their IR&D costs to be allowable on government contracts. The latest proposed change in the allowability requirements set forth in the DFARS was published in the Federal Register on February 16, 2016 . The proposed change reformats the existing DFARS 231.205-18(c)(iii)(C) and adds a new requirement that reads: For IR&D projects. Read More.
Topics: Allowability, Defense Contract Audit Agency "DCAA", Defense Federal Acquisition Regulation Supplement "DFARS", Defense Technical Information Center "DTIC", Department of Defense "DoD", Federal Register, Independent Research and Development "IR&D"
Payment of Interim Vouchers under Cost Reimbursement Contracts
In the mid-1990’s, the Department of Defense (“DoD”) instituted a new policy of permitting contractors who met certain criteria to submit interim vouchers under cost reimbursement contracts directly to the Defense Finance and Accounting Service (DFAS) payment office. Under this policy, known as direct billing, the Defense Contract Audit Agency (“DCAA”) did not review these vouchers before they were sent to DFAS. By eliminating the DCAA review, contractors were able to be reimbursed much quicker for costs they had incurred in performing these contracts. However, in 2012, DoD changed this policy and eliminated the direct billing procedure. As currently written,. Read More.
Topics: Cost Reimbursement Contracts, Defense Contract Audit Agency "DCAA", Defense Federal Acquisition Regulation Supplement "DFARS", Defense Finance and Accounting Service "DFAS", Department of Defense "DoD", Memoranda for Regional Directors "MRDs"