The New Revenue Recognition World
By: Michael Brown, Senior Manager The effective date for the new revenue recognition standard is fast approaching and will be here before we know it. By now, you have probably heard speculation about the impact of the standard to your company. Speculation has been from no impact at all to the world is going to be entirely different post implementation. As always, the reality is somewhere in the middle. Generally speaking, for the government contracting industry, the end result of when and how much revenue is recognized will be similar as in the past or at least should not significantly. Read More.
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"
If the Government Claims a Refund, When did the “Claims Clock” Start Running?
By: David Lundsten , Partner, Government Contractor Services Group and John Ford , Senior Consultant, Government Contractor Services Group The Contract Disputes Act (“CDA”) requires a contract claim by either party (the government or the contractor) to be submitted within six years after accrual of the claim. This six-year “claims clock” is otherwise known as the CDA Statute of Limitations (“SOL”). The CDA does not state the test for determining when a claim accrues. However, the Federal Acquisition Regulation (“FAR”) has filled this gap at FAR 33.201, which states that a claim accrues when “all events, that fix the alleged liability . . .. Read More.
Required Documentation in Support of Consultant Costs
By: Curt Smith, Manager, Government Contractor Services Group The allowability of consultant costs is sometimes a point of contention between contractors and Defense Contract Audit Agency (“DCAA”) auditors, and often the issue is insufficient documentation. What evidence is required by the Federal Acquisition Regulation (“FAR”) to document consultant costs sufficiently and how do auditors determine allowability given this requirement? A quick review of FAR and guidance for DCAA auditors concerning consultant costs will greatly help answer these questions. The general parameters of allowability for consultant costs are described in FAR 31.205-33 — Professional and Consultant Service Costs. However, other cost. Read More.
Department of Labor Proposes Rule Implementing Paid Sick Leave
On September 7, 2015, President Obama signed Executive Order (“EO”) 13706, establishing paid sick leave for federal contractors. The EO requires federal contractors to establish a policy to provide at least seven paid sick days annually, including paid leave allowing for family care. The Secretary of Labor was given until September 30, 2016, to issue regulations on the EO, which goes into effect January 1, 2017. On February 26, 2016, the Department of Labor (“DOL”) published its Notice of Proposed Rulemaking (NPRM) implementing EO 13706. The DOL predicts that the proposed rule will have a significant impact on federal contractors. Read More.
Prohibition of Reimbursement of Congressional Investigation Costs
On February 17, 2016, the Federal Register published a proposed rule that would prohibit government contractors from claiming costs incurred in response to a congressional investigation or inquiry that is the subject matter of a proceeding resulting in a disposition as described in 10 U.S.C. 2324(k)(2). As a refresher for those who are lucky enough to not deal with legal expense on a recurring basis, 10 U.S.C. 2324(K)(2) – Allowable Costs Under Defense Contracts, states that a disposition includes any of the following that results from a violation or failure to comply with, a Federal or State statute or regulation: A conviction. Read More.