Overview

Redstone Government Consulting has created an affordable, subscription-based solution for employee awareness of government contract compliance expectations. Regular training on employee responsibilities regarding their performance under government contracts is a critical control required in all business system areas. An educated workforce illustrates the company’s commitment to compliance with external auditors, provides an additional avenue for identifying employee concerns regarding potential non-compliances, and provides assurance that should a problem occur, the company has done its part to mitigate risks of non-compliance.

The Redstone Learning Management System is a turnkey solution for educating your employees on recurring compliance responsibilities and offers ease of use, value, and peace of mind for government contractors. Employee training is an essential element of developing a government compliance infrastructure. The use of courses accompanied by support from the Redstone GCI consulting team to develop compliant policies/practices while evaluating their effectiveness through recurring monitoring provides a total solution. This is effective for maintaining your business system adequacy and providing effective risk mitigation from costly non-compliance problems.

Human Resources (HR) Course Package

This course package is available as a complete course containing 6 modules. CPE is not offered for these training course modules or the training course package.

Course Overview

This Human Resources (HR) course package includes modules for critical areas of employee annual training and new employee onboarding training. Each module touches on a different topic that is either required or strongly recommended for training employees of government contractors. The modules address timekeeping requirements, DCAA floorchecks, preventing harassment and discrimination in the workplace, business ethics (FAR 52.203-13), drug-free workplaces, and anti-human trafficking. In addition, the modules will address what DCAA reviewers look for when reviewing contractor policies and procedures and the documentation needed in company files.

Individual Modules

Often the timekeeping requirements for government contractors are a source of frustration for employees, but they are a necessary evil for all companies doing business with the U.S. Government. In this course, we demystify the rules and requirements around timekeeping with an emphasis on explaining why timekeeping controls are not only necessary but essential for the protection of both the employee and the company. This course addresses critical controls around timekeeping and the individual liability for employees charging time to U.S. Government contracts where their timesheet forms the basis of a claim as part of the invoicing process. At the completion of the course, attendees will have a greater understanding of required timekeeping controls and the employee’s role in ensuring compliance with U.S. Government contracts.

The Defense Contract Audit Agency (DCAA) utilizes labor floorcheck audits as part of their real-time testing of employee labor controls. The floorcheck process is often overwhelming for employees because interacting with government auditors is not a routine occurrence for personnel outside of a company’s accounting or compliance areas. This course provides an overview of the DCAA Labor Floorcheck process from an employee perspective and offers interactive scenarios covering the questions asked of employees by DCAA. Narration is provided by a former DCAA auditor and explains the “why?” behind the questions asked by auditors. This knowledge is invaluable to the employee and the company to ensure that employees are informed and prepared for DCAA Labor Floorchecks.

Federal agencies and Courts regularly emphasize the importance and, in some instances, the requirement that employers provide harassment prevention training to all employees on a routine basis so they understand their rights and responsibilities in the workplace. Indeed, employers are obliged to exercise reasonable care to promptly prevent and correct any sexually (or other illegal) harassing behavior. Government contractors have additional obligations to ensure their workplace is free of discrimination and harassment and that they are making good faith efforts to advance diversity, equity, and inclusion. Moreover, contractors subject to the affirmative action obligations of Executive Order 11026 are subject to more stringent requirements to address and prevent harassment in the workplace. This course provides an overview of equal employment opportunity law, “protected classes,” what “harassment” in the workplace means, additional responsibilities for supervisors, and how to facilitate a workplace free of discrimination, harassment, and retaliation.

Government contractors have specific obligations to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law. FAR 52.203-13 provides that all contractors must have a written code of business ethics and conduct, and ensure that all employees are aware of their ethical obligations and how to report any concerns they have based upon a reasonable belief that violations or wrongdoing has occurred. This course provides an overview of government contractors’ ethics requirements, including identification of personal and organizational conflicts of interest and protection for whistleblowers. A licensed attorney provides narration with experience creating ethics awareness programs for government contractors and investigating potential ethical violations.

Many federal contractors and all federal grantees are required by law to establish and maintain a drug-free workplace policy and awareness program pursuant to the Drug-Free Workplace Act of 1988. Failure to comply may result in penalties, up to and possibly including suspension or termination of contracts or grants. This course provides an overview of the requirements of the Drug-free Workplace Act, including personal reporting obligations and the organization’s obligation to make reports to the contracting agency. Furthermore, the course addresses possible red flags that indicate someone has a problem with drugs or alcohol so that the organization can promptly address issues to avoid safety risks, maintain a healthy workplace and maximize productivity.

Human trafficking is a multibillion-dollar criminal industry that uses force, fraud, or coercion to exploit vulnerable people with the intent of obtaining forced labor or services, including sex. The U.S. Government condemns these practices and requires those who do business with them to take action to prevent, report and remedy human trafficking in federal contracts. FAR Subpart 22.17 requires that clause 52.222-50, Combating Trafficking in Persons, be incorporated in all solicitations and contracts and that the substance of this clause shall be included in all subcontracts and all contracts with agents. FAR clause 52.222-50 prohibits contractors, subcontractors, their employees, and their agents from, among other things, engaging in severe forms of trafficking in persons, using forced labor during the period of performance of the contract, using misleading or fraudulent recruitment practices, and charging employees for recruitment. The FAR clause requires contractors and subcontractors to notify employees and agents of the U.S. Government policy prohibiting trafficking in persons and the actions that will be taken against them for violations of this policy. Further, U.S. Government contractors working abroad on large contracts (valued at $550,000 or more) are required to have an anti-human trafficking compliance plan, according to FAR 52.222-50. This course will educate participants on what human trafficking is, how to recognize human trafficking situations, and what contractors and their employees are required to do to help stop this violation of human rights.

Contractor Purchasing System Review (CPSR) Course Package

This course package is available either as a complete course containing 11 modules or each module can be purchased individually. CPE is not offered for these training course modules or the training course package.

Course Overview

This CPSR course package includes modules for the significant areas in a contractor’s purchasing system. Each module touches on the DFARS 252.244-7001 Contractor Purchasing System Administration criteria for the particular topic. The modules address FAR clauses and the required criteria, information that should be included in policies and procedures, areas to consider when performing the requirements, and documentation. In addition, the modules will address what the DCMA CPSR reviewers look for when reviewing contractor policies and procedures and the documentation in the purchasing/subcontract files.

Individual Modules

This CPSR course module provides an overview of a contractor purchasing system review. The course covers the purchasing system in general, the different agencies that perform CPSR reviews, when a CPSR review is required, the scope of the review, and the different criteria addressed during the review. The course also covers the CPSR review process and what to expect from the entrance conference to the report. While other agencies can perform a CPSR review, this course will concentrate solely on DCMA’s review process.

This CPSR course module covers the DFARS CPSR requirements for consent to subcontract, when it is required, the information to provide to the contracting officer for approval, and the documentation needed for the purchase order file. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files.

This CPSR course module provides an overview of the DFARS CPSR requirements for protecting the government’s interest when subcontracting with contractors debarred, suspended, or proposed for debarment, otherwise known as debarment. The course covers the requirements for checking debarment and the steps performed to confirm the subcontractor is not debarred. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files.

This CPSR course module provides an overview of the purchasing system expectations, procurement process, the regulatory expectation for competition, different types of procurements, and the regulatory basis for sole source. The course covers the impacts of using competition and sole source in the procurement process, the expectation for well-documented sole source justifications, and the importance of market research in sole source justifications and the procurement process. The course also covers DCMA’s perspective in evaluating sole source justifications.

This CPSR course module provides an overview of the DFARS CPSR requirements for the Federal Funding Accountability and Transparency Act (FFATA). The course goes over the reporting of executive compensation and first-tier reporting. The course also covers the requirements under FFATA and what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files.

This CPSR course module provides an overview of the DFARS CPSR requirements on flowdowns and what a flowdown is. The course covers the mandatory and non-mandatory flowdown clauses and other clauses that DCMA checks for. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files.

This CPSR course module provides an overview of the DFARS CPSR requirements for purchase requisitions. The course covers what information is normally included in purchase requisitions. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files related to purchase requisitions.

This CPSR course module discusses the DFARS CPSR Requirements for negotiations, contracting by negotiation, and negotiation documentation for purchases by threshold. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files related to negotiation documentation.

This CPSR course module provides an overview of the DFARS CPSR requirements for the Truthful Cost or Pricing Data Act (formerly the Truth in Negotiations Act or TINA). The course covers the definition of TINA and cost or pricing data, the applicability of TINA, and the requirements and flowdown clauses. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files for compliance with TINA.

This CPSR course module provides an overview of the DFARS CPSR requirements for cost and price analysis. The course covers the definition of cost analysis and price analysis, when a cost or price analysis should be conducted, cost analysis techniques, and price analysis techniques. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files related to cost and price analysis.

This CPSR course module provides an overview of the DFARS CPSR requirements for commercial determinations. The course covers when a commercial determination is required, the benefits of commercial products and services, and criteria in a well-written commercial determination. The course also covers what DCMA CPSR reviewers look for in the policies and procedures and in the purchasing files.

Additional Featured Courses

CPE is not offered for these training course modules or the training course package.

This course discusses provisional billing rates and their importance. FAR 42.704 Billing Rates addresses the government’s regulation on establishing provisional billing rates. Provisional billing rates are used to bill indirect costs on vouchers for cost-type contracts, the materials portion of T&M contracts, and progress payment requests on fixed-price contracts. Contractors should be proactive and submit proposed provisional indirect rate information to the government prior to the beginning of the calendar or fiscal year. If the contractor is negligent and does not submit provisional rate information for acceptance, the government can unilaterally establish the provisional billing rates for a contractor. This course also addresses some of the information that may be submitted or requested by the government when establishing provisional billing rates, as well as the need for contractors to monitor indirect rates on a regular basis and update them, if necessary.

This Export Compliance Management course covers introductory training that is intended for both novice and experienced export compliance professionals with an overview on complying with United States export regulations. Export Control Laws are a set of federal regulations that restrict the release of certain items, information, and software to foreign nationals in the United States and abroad. This course covers the International Traffic in Arms Regulations (ITAR), The Export Administration Regulations (EAR), and the Office of Foreign Asset Control (OFAC).

The U.S. Department of State Directorate of Defense Trade Controls administers ITAR, which covers items, services, and technology with explicit military/defense applications. Examples of items controlled under ITAR are satellite technology, some unmanned aerial vehicles, global positioning systems, chemicals, night vision technology, navigation systems, sonar and radar systems, military electronics, and software. The U.S. Department of Commerce Bureau of Industry and Security administers the EAR and establishes controls over “dual-use” items, services, and technologies that have both civilian and military purposes. Examples of items controlled under EAR are lasers, infectious agents, computers, encryption technology, sensors, navigation and avionics, propulsion systems, toxins, chemicals, certain materials for the manufacture of controlled goods, and telecommunications equipment. The U.S. Department of the Treasury administers OFAC and oversees foreign trade embargoes and economic sanctions.

Moreover, this course offers guidance on the implementation of these regulations as well as the components of Export Compliance Programs.

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