Stimulus Contractors Must Also Report Subcontracting Data
In addition to the prime contract information described in Wednesday’s blog post, Recovery Act prime contractors must also report on their subcontracting activity. As with the prime contract data, the subcontractor information is due on the 1oth day after the end of the calendar quarter. The subcontractor data must be reported using the tool available at http://www.federalreporting.gov/. For more information on the schedule and reporting tool please see Aronson’s previous blog posting.
Stimulus Contracts Require Extensive Reporting
This blog post will describe what information is to be reported, when the reports are due, and how the reports are to be submitted. The post will conclude with a few reporting tips for the stimulus contractor. Continue reading »
Stimulus Contracts Bring Increased Oversight
Contracts funded with stimulus dollars will be subject to more oversight than any other spending in U.S. Government history. Transparency is the catch phrase and almost anybody, including citizens, employees, whistleblowers, contracting officers, inspector generals, and auditors, will have the the opportunity to monitor stimulus spending for fraud, waste and abuse.
The Recovery Accountability and Transparency (RAT) Board has been established to oversee the oversight. The RAT board, staffed primarily with agency Inspector Generals, is tasked to conduct oversight of Recovery Act funds to prevent fraud, waste, and abuse. The RAT board has the authority to audit the spending of Recovery Act funds. The RAT board also has the authority to order agency IGs to either conduct or refrain from conducting investigations. Significantly, the RAT Board has subpoena power for both documents and individuals and can conduct public hearings. Continue reading »
Share Teaming, Subcontracting Ideas and Opportunities
The Coalition for Government Procurement invites you to attend the Small and Large Business Partnering Session to Share Teaming, Subcontracting Ideas and Opportunities. This event will consist of multiple fifteen minute sessions for small businesses to meet with large businesses. The sessions will give small and large businesses one-on-one opportunities to discuss teaming, partnering and subcontracting opportunities. Meetings with the large businesses are based on a first-come-first-serve basis. Sign up early to guarantee one-on-one sessions with large businesses of your choice. We ask every small business to be prepared to answer: who they are and what specialization/niche they bring to their industry/partners/government customers.
Who Should Attend: Executives from small government contracting companies interested in learning more about growth opportunities through teaming or subcontracting.
What: Small & Large Business Partnering Session
When: Wednesday, Jul 15, 2009, 7:00am – 11:00am
Event Type: Conference / Networking / Meetup
Where: Hilton Arlington, 950 N Stafford St, Arlington, VA 22203
Price: $50.00. Click here to register.
Aronson has no involvement in this event.
Welcome to Stimulus Week on Aronson’s Fedpoint Blog
Aronson will devote this week’s blog postings to the administrative and regulatory requirements included in the American Recovery and Reinvestment Act (The Recovery Act). The Recovery Act was signed into law by President Obama on February 17, 2009. It’s primary purpose is to “stimulate” the nation’s economy by providing $789 billion in new spending or tax cuts. The Recovery Act is a tremendous opportunity for contractors but there are “strings” attached. This is because the Recovery Act also contained numerous regulatory requirements which will apply to any Government contract funded with Recovery Act money. These requirements are in addition to the normal FAR requirements.
On Tuesday’s blog we will describe the additional oversight and compliance requirements included in the Recovery Act. Wednesday’s and Thursday’s blogs will address prime contractor and subcontractor reporting respectively. Friday’s blog will describe the impact of the Recovery Act regulations on GSA schedule contractors. Please check out the blog each day this week to learn more about the regulatory requirements associated with the stimulus funding. Or better yet, subscribe to our Fed Point RSS Feed and have the news delivered directly to you! (Click here to learn more about RSS.)
DCAA Issues Guidance on Reporting Suspected Contractor Irregularities to Investigative Agencies
The Defense Contract Audit Agency issued a Feb 2009 audit alert reminding their auditors of agency policy to report suspected contractor fraud and other contractor irregularities encountered in the performance of their audits. Suspect contractor fraud and irregularities should be reported promptly using DCAA Form 2000 in accordance with the DCAA Contract Audit Manual 4-700 and DCAA Instruction No. 7640. Auditors are told, in bold letters, “There is no requirement for the auditor to prove the existence of fraud or other contractor irregularity in order to submit a DCAA Form 2000.” The guidance also states that DCAA management reviews of Form 2000 prior to formal submission “should be limited to that necessary to ensure clarity. No attempt should be made to dissuade an auditor from completing and submitting a DCAA Form 2000.” Examples of irregularities cited in the guidance includes labor mischarging, submitting false claims, repeated overbilling, falsifying labor charges, improper transfers of costs between contracts and bribes/kickbacks. Any other suspected irregularity may be referred (09-OTS-004(R)).
GovCon Report Editor’s Note: We have been seeing incidences where individual DCAA auditors have been referring contractors to governmental investigation agencies for possible criminal or fraud investigations when they have concerns about a contractor’s cost allocation or screening of unallowable cost practices identified during an audit. We are particularly concerned about these because we have seen little DCAA management review of such referrals. A referral usually exposes contractors to significant potential liability and usually requires expensive legal efforts to counter. The above guidance encourages these referrals and does not seem to provide much management control over individual auditors submitting erroneous referrals.
Source: Bill Lennett, Principal, GCA Report, March – April 2009 Vol 15, No. 2
Website: http://www.govcontractassoc.com
Stimulus Spending Could Boost GSA GSA Sales Growth – GSA Contractors Must Sign On
General Services Administration’s federal supply schedules have grown at a modest 2 – 3% rate in past four years. The annual growth rate reached 22 percent in 2004, then dropped to 5 percent in 2005 and has hovered at the modest rate of 2-3% ever since. Most recently, Schedule sales reached $36.6 billion in 2008, compared with $35.8 billion in 2007, a 2 percent increase from the previous year, according to a Federal Times analysis by FedSources Inc., a McLean, Va., market research firm.
The $787 billion economic stimulus package could be a big part of General Services Administration’s (GSA) federal supply / multiple award schedules (MAS/FSS) return to higher sales. Joe Jeu, assistant Federal Acquisition Service commissioner for general supplies and services said he thinks customers [federal and state/local] will turn to GSA’s pre-competed contracts for stimulus needs because they offer better prices than individual contracts would. This is a two part equation which also requires GSA Schedule government contractors to accept the recently released FX75 mass modification which includes more stringent reporting requirements related to stimulus spending. Continue reading »
The Defense Eagle is Spreading Its Wings But Not Its Money
Fiscal year 2009 defense spending is soaring literally like an aeroplane! The top industry code where the Navy and the Air Force spent most of their money – NAICS Code 336411, Aircraft Manufacturing. The Army on the other hand spent most of its money so far in NAICS Code 541330, Engineering Services. But contracts are hardly being competed.
- The Navy spent over 22.78% or $ 7,915,420,099 in its top sector, and chose not to compete close to 50% of all its contracts so far amounting close to $34.7 Billion. Details…
- The Army on the other has spent $5,753,130,677 in its top industry sector amounting to 16.6% of its total spending, and chose not to compete 54% of its total spending – close to $34.5 Billion. Details...
- The Air Force spent $7,575,487,183 or 23.87% of its money in its top industry sector, and chose not to compete 44.08% of its awarded contracts, amounting to $31.7 Billion reported thus far. Details…
For further details about these numbers and linked reports, email Ashok Mehan at: amehan@fedmine.us, or visit: www.fedmine.us for more information. If you mention Aronson, you will receive a 10% discount off standard subscription rates!
Ask FedPoint: Tips to Prevent Administrative Conflicts with Settings in Deltek GCS and T&E
Dear FedPoint: Does anyone have a cheat sheet or tips to prevent administrative conflicts with the settings in Deltek GCS and T&E? Example: I’m always forgetting to update the work force file in GCS. Since I’m in T&E daily, it is more natural to navigate to the charge trees. Needless to say, when the Time data is imported into GCS, I get the “friendly” reminder to update the work force file. – Maxine, Washington, DC
Dear Maxine:
Below are some tips for GCS and T&E to assist you:
Here’s a checklist of GCS addition/updates that will require to you export the GCS tables to T&E.
- GCS Employee Master File
- Setting up a new employee
- For changes to an employee’s division, dept, suffix or default pay type
- GCS Employee T&E panel
- Setting up a new employee
- For changes in the primary supervisor, work group, timesheet class, email address or timesheet schedule of an employee. Continue reading »
SmartPay 2 – What You Need To Know When The Feds Ask You To Accept Credit Cards
Why should you accept Visa and MasterCard? The Federal Government is the largest user of Visa and Mastercard in the world for purchasing. This applies not just for micro-purchases (<$3,000), but also large dollar invoices (e.g., $100,000). The SmartPay 2 program which commenced November 30, 2008, is the successor to SmartPay I and the well-known IMPAC Card.
Why do some contracting officers prefer to pay with Visa/MasterCard purchase cards? What requirements are contained in my GSA Schedule conditions in regard to Visa/Mastercard acceptance? What if our company is a services-only business? How can we minimize the fees we pay to accept Visa/Mastercard? What is Level III data and why is this important? The answer to these and other questions can be found in the Fairfax County Chamber of Commerce GovCon Newsletter article.
Guest Contributor: Wade Tetsuka, a C.P.A. and Executive Vice President of Diamond Mind, Inc., is among the first niche merchant service providers in the U. S. to make Level III for Government-Contracting a central focus of its business, He is an expert in payment processing providers and has authored numerous articles on this subject. He can be reached at wade.tetsuka@diamondmindinc.com or (888) 566-0945 x 705.
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- 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)