At first glance I thought I had accidentally gone to DCMA’s website instead of DCAA. It has a similar feel and look to DCMA’s website; however, it is just DCAA’s new look. This updated version is user friendly with the drop down tabs at the top and quick links. They organized all the checklists and Incurred Cost Submission model all under the new Checklist & Tools tab. The Guidance tab leads you directly to all of DCAA’s Audit Guidance Memos, the CAM, and a link to the FAR just to name a few. I also enjoy the Locator feature which allows contractors to find who their cognizant DCAA FAO is by CAGE code, DUNS code, or ZIP. Continue reading »
Aronson Capital Partners is a leading middle-market investment bank focused exclusively on the government services and technology industry. We invite you to read our February 2013 Newsletter, featuring the following topics:
- Continuing Resolution and Sequestration Update
- DoD Slows Contractor Payments
- Q4 2012 Government IT Services Earnings Calls
- Government Services Industry Performance
- Public Company Comparables Continue reading »
The Inspector General (IG) released the results of the 2010 Quality Assurance review of the Defense Contract Audit Agency (DCAA) on March 7, 2013. The results are not shocking as there is a 26% pass rate with 74% fail rate. DCAA did not exercise professional judgment on 37 out of 50 audit assignments reviewed. While the report is new the data released is old. DCAA has implemented a significant number of process improvements over the last 24 months that were not in place at the time of the review. This is a good time for you as a contractor to check out the new audit workplans and guidance that has been issued over the last 24 months. Obviously based on this report a lot needed to change at DCAA. We will not know the effectiveness of these changes for a few years. Continue reading »
In a recent Court of Appeals case (Berkshire Bank vs. Town of Ludlow MA and IRS, 1/11/2013) the Court ruled that an LLC owned by individual behind on his taxes was that individual’s alter ego. That is, the LLC and the individual were deemed to be one and the same, resulting in the assets of the LLC being available to satisfy the IRS tax debt.
Closely held businesses are in particular in danger of being seen as the alter ego of its owners. Common elements the IRS can use to find an alter ego relationship exists include Continue reading »
In August 2012 Defense Procurement and Acquisition Policy (DPAP) issued Class Deviation 2012-O0014 which implemented accelerated payments to prime contractors, who were in turn, to accelerate payments to their subcontractors. On February 21, 2013, Richard Ginman, Director, DPAP, issued a letter which rescinded Class Deviation 2012-O0014. This is only the beginning of the effects of sequestration.
The payment acceleration policy was implemented to assist with the cash flow of all small-business contractors, whether they are prime contractors or subcontractors to non-small-businesses. While the policy of accelerating payments has been rescinded the DoD will continue with the policy Continue reading »
In the National Defense Authorization Act for Fiscal Year 2013 (“NDAA FY13”), Congress amended the Small Business Act and fundamentally changed the method for calculating subcontracting limits on small business set-aside contracts. Previously, the SBA regulations (13 C.F.R. § 125.6) and implementing FAR clause 52.219-14 focused on the cost of performance. However, the NDAA FY13 amendment focuses on the amount paid under the contract. This change eliminates the contractor’s need to rely on cost-based accounting to ensure compliance and will hopefully make it easier for prime contractors to track their efforts to comply with the rule.
Under both the previous and new rules, the subcontracting limits are calculated based on the type of contract: service, supplies, or construction. Under the previous rules for service contracts, the small business prime contractor was required to perform at least 50% of the cost of labor. For supply contracts, the amount required is at least 50% of the cost of manufacturing supplies, not including the cost of material, and for construction contracts, at least 15% of the cost of the contract, not including the cost of materials. Under the new rules, Continue reading »
Remember to set your clocks forward one hour on Sunday, March 10.
Most of the United States follows Daylight Saving Time (DST), but there are a few exceptions: Hawaii, most of Arizona, American Samoa, Guam, Puerto Rico, and the Virgin Islands.
If you live in an area that observes DST, but you have a hard time remembering which way the time changes in March and November, think of the phrase, “spring forward, fall back.” Continue reading »
GSA has taken the first step in its new eBuy mobile initiative. eBuy vendors can now login to eBuy on their mobile devices (iOS and Android platforms) by opening the browser and going to www.ebuy.gsa.gov/mobile/login to access active Request for Quote (RFQ) and Request for Information (RFI) associated with their contracts.
Once logged in with the contract number and password, contractors will see a list of RFQs and RFIs associated with their awarded Special Item Numbers (SIN). Contractors can click on each opportunity to see more details including buyer information, a description of the requirement, any line items, as well as shipping information. In order to view attachments associated with RFQs, or to submit a quote, contractors will still need to access eBuy from their desktop computer or laptop.
eBuy vendors are also now capable of Continue reading »
On January 24, 2013, the Maryland Court of Special Appeals reversed a circuit court’s withdrawal of assessments and affirmed the Tax Court’s ruling that out-of-state subsidiaries of a company operating in Maryland are subject to Maryland’s corporate income tax because the subsidiaries are engaged in a unitary business with and under the complete control of the Maryland parent company (Comptroller v. Gore Enterprise Holdings, Inc., Md. Ct. Spec. App., Dkt. Nos. 1696; 1697, 01/24/2013). The ultimate conclusion in this case is consistent with prior appellate and Tax Court case law in Maryland; however, some of the language in the opinion reflects a very expansive Continue reading »
As a follow-up to the L2 Federal Resources webinar on “Attributes of an Adequate Accounting System,” Aronson LLC government contracting specialists Nicole Mitchell and Brian Bender have prepared answers to several attendee questions:
Is my contract covered by the Cost Accounting Standards (CAS), and how do I determine the level of CAS coverage (e.g., Full, Modified, Not CAS Covered)?
Click here to download a flowchart that illustrates the method for determining CAS coverage and whether or not your company should be submitting a Disclosure Statement.
Does my company have a robust set of policies and procedures?
At a minimum, your business should have the following written policies and procedures (P&P) in place prior to DCAA review/audit: Continue reading »
What We Are Writing
- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)