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Guidance Issued on Treatment of “Blended” Compensation Caps in Incurred Cost Submissions

On June 30, 2016, the Defense Contract Audit Agency (“DCAA”) issued Memorandum for Regional Directors (“MRD”) 16-PSP-007(R), Audit Alert on Handling Incurred Cost Proposals Using a Blending Approach of Compensation Caps. In this memo, the DCAA discusses how auditors are to treat new and existing incurred cost submissions (“ICS”) that include blended compensation caps, in the absence of an advance agreement. One of the key points of the memorandum is that DCAA should not delay the adequacy review of an ICS if an advance agreement is not present. The audit team must continue with the adequacy review. During the adequacy. Read More.

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Preparing a Compliant Proposal: An Art or a Science?

By: Kristen Kwiatkowski, Manager; and Eric Poppe, Manager Preparing a technical and cost proposal for any company can be a daunting task. Not only do you need to prove that you have the services or products the customer needs, but you need to prove you can provide them better than your competitors, at the best price, and still make your company a profit. Layer in the complexities of government contracting, and you have an intricate dance that many spend their whole careers trying to master. In addition to fighting your own challenges on preparing a compliant proposal, you may also. Read More.

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It’s About Time: GSA Finally Releases Alliant 2 Request for Proposals

On June 24, 2016, the General Services Administration (“GSA”) released its Request for Proposal (“RFP”) for the long-awaited Alliant 2 Small Business (“A2SB”) Governmentwide Acquisition Contract (“GWAC”). The government estimates that a maximum of 80 awards will be made for A2SB, which has a $15 billion ceiling over 10 years. A2SB will be an  contract that provides IT solutions through a broad range of services. For contractors deciding or preparing to bid on A2SB, it is imperative to gain sufficient information about the RFP and its scoring methodology. GSA officials are adamant that respondents read the entire 174 page RFP,. Read More.

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New DCAA Guidance on Revised Policies Related to Low-Risk Incurred Cost Submissions

As the Defense Contract Audit Agency (“DCAA”) slowly pushes to eliminate Incurred Cost Submission (“ICS”) audit backlog, DCAA has recently published a new memorandum (“MRD”) revising guidance for selecting low-risk Incurred Cost Submission proposals less than $250 million in “auditable dollar volume” (“ADV”). Published on May 27, 2016, the memorandum revises the MRD 12-PPD-023(R), dated September 6, 2012, and MRD 13-PPD-021(R), dated October 29, 2013. While not specifically defined in the Federal Acquisition Regulation (“FAR”), Contract Audit Manual (“CAM”) or elsewhere, ADV is typically considered by DCAA to be the total contract cost for flexibly priced government contracts and subcontracts. Read More.

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Subcontractor Oversight (Who’s Responsible?)

By: John N. Ford, JD ; Senior Consultant  Who has privity? 42.505 – Post-award Subcontractor Conferences (a) The prime contractor is generally responsible for conducting post-award conferences with subcontractors. However, the prime contractor may invite Government representatives to a conference with subcontractors, or the Government may request that the prime contractor initiate a conference with subcontractors. The prime contractor should ensure that representatives from involved contract administration offices are invited. (b) Government representatives– (1) Must recognize the lack of privity of contract between the Government and subcontractors; (2) Shall not take action that is inconsistent with or alters subcontracts; and (3) Shall ensure that. Read More.

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Accounting System Assessment – Alliant 2 Contract

By: Eric Poppe, Manager; Kristen Kwiatkowski, Manager; and Jacob Barclay, Consultant There have long been rumors that the General Services Administration (“GSA”) will be releasing Alliant 2 (“A2”) and Alliant 2 Small Business (“A2SB”) Governmentwide Acquisition Contract (“GWAC”) Request for Proposals (“RFP”) in the near future. While there has been much speculation of a June 2016 release, nothing yet is certain. As companies begin to prepare for the final release of these two separate solicitations, companies should consider what regulatory impact the potential award could have on their compliance environment. The Draft Request for Proposals (“DRFP”) previously released on March. Read More.

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