Dirty Little Secrets Behind Advance Payments on Government Contracts Whitepaper

Are you navigating the complex world of government contracting? Do you find the policies and procedures surrounding advance payments bewildering? Our whitepaper on FAR 32.4, “Dirty Little Secrets Behind Advance Payments on Government Contracts,” is your guide to understanding these intricate rules.

Whitepaper: Cost Accounting for Software Related Costs To Be Sold, Leased, or Marketed

Does Federal Acquisition Regulations (FAR) or Cost Accounting Standards (CAS) provide specific requirements when it comes to accounting for costs related to software to be sold, leased, or marketed in the future? The simple answer is “no”, however, a review of FAR Part 31 certainly supports that the cost is allowable and allocable to both…

Understanding 2 CFR 200 Requirements Related to Subrecipients vs Contractors Whitepaper

A White paper by John Shire, Director & Lynne Nalley, Director

Federal Acquisition Regulations (FAR) is structured significantly differently than OMB Guidance 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (i.e., Grants and Cooperative Agreement).

Total Time Accounting in the Govcon Environment (Uncompensated Overtime for FLSA Exempt Employees)

A Whitepaper by John C. Shire, CPA, Director, Redstone GCI & Asa Gilliland, President & Director, Redstone Government Consulting

Based on DCAA’s track record of disregarding its own guidance on what are acceptable accounting methods for contractors incurring potentially significant amounts of uncompensated overtime, DCAA is very likely to see the risk sufficient to report what they see as a non-compliance as a significant deficiency and therefore recommend system disapproval and the implementation of a withhold.

Novation Agreements – Prime U.S. Government Contracts Whitepaper

A Whitepaper by John C. Shire, CPA, Director, Redstone GCI & Jerome S. Gabig, Attorney, Wilmer & Lee

Although technically 41 USC § 6305 prohibits the transfer of Government contracts from one contractor to another, there are times when the Government realizes it is in its best interest to waive this rule—in a document called a novation agreement. If you want the Government to recognize your transfer, you need to design and execute an agreement that protects the Government while ensuring all parties assume (or waive) rights and obligations where necessary, including those situations where subcontracts are involved. Additionally, finding the Contracting Officer is another key step in the process of executing a novation agreement, especially where contracts are large enough to be administered by DCMA. Lastly, you must ensure that risks are averted in the transfer process, the required documentation is submitted, and the format meets FAR requirements before the Government finally gives its final approval.

Planning vs. Organization Costs

A White paper by John C. Shire, CPA, Director

Where does allowable planning end and unallowable organization begin? Two FAR clauses are at odds with each other in terms of merger/acquisition activities being allowable. Contractors need to understand where their planning activities cross the line from allowable, generalized consideration of an opportunity, to unallowable, where specific actions are taken to plan for a specific opportunity. Documenting decision-making, clarifying employee activity, and noting the point at which the organization’s decisions move from a generalized consideration to a specific opportunity plan will help avoid having salaries and employee efforts ruled unallowable by the Government.

What Are The Prime Contractor’s Risks Related to Subcontracts

A White paper by Asa Gilliland President & Director &
Robert L. Eldridge, CPA, Director

Due to several factors, including the desire to reduce the work for DCAA auditors, the federal government has put subcontractor audit responsibility on prime contractors. Although not specifically assigned to prime contractors in the regulation, it is assumed their responsibility. Learn why it is important for prime contractors to have guidance to monitor subcontractor awards and handle contract closeouts and audits.

DFARS Business Systems White paper

A white paper by Michael Steen, Senior Advisor & Robert L. Eldridge, CPA, Director

The proposed DFARS amendments related to case 2012-D042 shed light on some of the inefficiencies surrounding the DCAA auditing concerns, both in the burden shift to contractors and the financial burden of juggling both internal audits and external independent CPA audits. When combined with increased DCAA oversight, government contractors could experience oppressive auditing requirements.