The Auditor Strikes Back: Always a Bonus of Contention
As we reported in October, the Defense Contract Audit Agency (“DCAA”) Contract Audit Manual (“CAM”) was recently updated. One of the 13 areas of cost updated related to bonus and incentive compensation costs. This topic is covered in Chapter 7 of both the previous version and new version of the CAM. Bonuses and incentive compensation can mean many things including cash, stock, stock options, stock appreciation rights, phantom stock plans, and/or a combination of the aforementioned forms. Bonus and incentive compensation can also be paid in the short/current term or in the future/long term. These plans can differ greatly between contractors and. Read More.
Topics: Allowability, Bonuses and Incentive Compensation, Contract Audit Manual "CAM", DCAA, DCAA Contract Audit Manual, Defense Contract Audit Agency "DCAA", Deferred Compensation Other Than Pensions, Federal Acquisition Regulation "FAR"
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"
ASBCA Holds that Leases are not Necessarily Subject to CAS 404
In Exelis, Inc., ASBCA No. 60131 (29 Aug. 2016), the Armed Services Board of Contract Appeals (“ASBCA”) held that a concern whether a building lease was a capital lease or an operating lease is not subject to Cost Accounting Standards (“CAS”) 404. In 2007, the Defense Contract Audit Agency (“DCAA”) released its audit of Exelis’ 2004 final indirect cost rates. DCAA questioned Exelis’ lease costs, finding that the building lease was a capital lease instead of an operating lease as claimed by Exelis and that Exelis could only include building depreciation in its indirect cost pool rather than the entire. Read More.
Topics: Armed Services Board of Contract Appeals "ASBCA", Cost Accounting Standards "CAS", Defense Contract Audit Agency "DCAA", Defense Contract Management Agency "DCMA", Federal Acquisition Regulation "FAR", GAAP, Indirect Cost Rates, leases
GAO Denies Bid Protest
The Government Accountability Office (“GAO”) has denied a bid protest challenging the agency’s evaluation of the protester’s proposal as unacceptable because the protester did not demonstrate that it had an accounting system that had been approved by the Defense Contract Audit Agency (“DCAA”). The National Security Agency (“NSA”) issued a small business set aside Request for Proposal for business, engineering, information technology, operations, and training support services. One of the evaluation subfactors was that offerors have an accounting system “that has been deemed acceptable for award by a [Defense Contract Audit Agency (DCAA)] audit at the time of proposal submission. Read More.
Proposed Rule: Opening the Dialogue for Government and Industry to Play Friendly
On November 29, 2016, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration proposed an amendment to the Federal Acquisition Regulation (“FAR”). The purpose of this amendment is to clear misconceptions regarding the responsibilities of communication between government and industry during the acquisition process. By adding more explicit language to the FAR, the agencies involved hope to create more effective communication between government and industry. So what is the potential impact on regulation? FAR part 1.102-2 dictates the “performance standards” placed on private industry in the acquisition process. This rule proposes to amend FAR 1.102-2(a)(4) of. Read More.
Episode 1: Manufacturing and Production Engineering Costs vs. Independent Research & Development Costs
For companies that incur manufacturing, production line, engineering or product development costs, determining the true nature of the cost can be difficult. The Federal Acquisition Regulation (“FAR”) points us to FAR 31.205-25 — Manufacturing and Production Engineering Cost, to help companies determine if the cost incurred should be considered a manufacturing and production engineering cost. However, the issue companies have is where one draws the line if the costs should actually be considered independent research & development (“IR&D”). Determining if the costs falls under FAR 31.205-25 or meets the definition of FAR 31.205-18 and is considered IR&D doesn’t just impact. Read More.
Topics: DCAA Contract Audit Manual, Defense Acquisition Regulations System, Defense Contract Audit Agency "DCAA", Federal Acquisition Regulation "FAR", Independent Research and Development "IR&D", Manufacturing and Production Engineering Costs