DCAA Compliance Blog

Government Contracting News and DCAA Information for Contractors

ReliAscent® LLC is the only government contract accounting firm that specializes in all aspects of government contracting compliance.  From monthly DCAA compliant accounting services, to contract management & administration, and financial services & planning for contractors and grantees, our goal is to ensure the success of our clients, and all small business government contractors.  

In our DCAA Blog, we discuss the latest government contracting news from the Federal Government, the DCAA, and DCMA, as well as promotions offered by ReliAscent, and helpful tools and resources for contractors.

We hope you will visit and take part in the discussions on our blog on a regular basis. If you ever have any questions or would like to discuss how our experts can help, do not hesitate to contact us at any time!  

To browse our extensive library by topic, use the form on the right and search by tags, and don't forget the subscribe!

DCAA Compliant Accounting & Contract Management Services

 

Customer Reviews


 

DCAA ICE Submissions

Posted by Tyler Link on Wed, Apr 04, 2018 @ 12:47 PM

DCAA ICE Submission Help

ReliAscent would like to remind contractors that if you had a Cost Reimbursable type contract in 2017, your Incurred Cost Proposal / ICE Submission is due 6 months after the end of your FY (per FAR 52.216-7).  If your FY ends on Dec 31st, that means your submission deadline will be here faster than you think, and it's time to get started!

Just like you don’t wait until April 1st to select your accountant and start your tax return, you should not wait any longer to select a qualified government accounting firm to help you with your Incurred Cost Submission.  The experts at ReliAscent have completed thousands of Incurred Cost Proposals for contractors over the last 20+ years, and can alleviate the stress of this process.

ReliAscent also has a number of helpful ICE resources for contractors:

Call us today to secure ReliAscent’s professional and expert services to help you prepare your 2017 ICE.  Slots are filling up fast, so the time to act is now!

If you have any questions about our government contract accounting or contract management services, please feel contact us at any time!

 

Topics: incurred cost proposal, DCAA ICE, DCAA ICE Submission

Are Your Indirect Rates Helping or Hurting Your Business?

Posted by Tyler Link on Tue, Mar 20, 2018 @ 08:30 AM

Indirect Rates - Helping or Hurting Your Business?

Have Contracts But Still Losing Money? It May Be Time to Review Your Indirect Rates

Managing your Indirect Rates effectively is critical for managing your costs and maintaining profits. Unfortunately, most contractors face the same problem: they don't know HOW to properly manage their indirect rates, and they're not making strategic modifications to their rates at the right times...and the consequences could be killing your bottom line.

To help small businesses struggling with their rates and maintaining profitability, ReliAscent offers the industry’s only, Free Indirect Rates Review.  This review provides contractors and grantees with sound, valuable advice about their indirect rate system & structure, can help them to understand and maintain DCAA compliance, and can help a them use their indirect rates as a tool to grow the business.

TO GET YOUR FREE INDIRECT RATES REVIEW, CLICK HERE NOW!

With just a little information about your company, our experts can complete your review and schedule a call to discuss the path forward, should you need help fixing any errors detected.

We encourage small business federal contractors to take advantage of this helpful service, and as always, if you ever have any questions about FAR and DCAA compliance, or our accounting and contract management services for Federal Contractors & Grantees, please do not hesitate to contact us at any time.

Topics: Indirect billing rates, Indirect rates, indirect rates review, managing your indirect rates

ReliAscent Seminar: "Federal Acquisition Regulation (FAR) 101 – Quick Tour and Key Clauses"

Posted by Tyler Link on Tue, Mar 20, 2018 @ 08:02 AM

FAR Compliance - ReliAscent PTAC Seminar on the FAR.jpg

ReliAscent would like to remind all Colorado-based Federal Government Contractors and Grantees that our latest contracting compliance seminar is this Thursday:

Topic: FAR 101 - Quick Tour and Key Clauses

Date: March 22, 2018 (1:30  - 4:00 PM)
Cost: FREE
Location: 14305 E Alameda Suite #300, Aurora, CO

TO RESERVE YOUR SEAT, CLICK HERE NOW!

ReliAscent AE, Dave Donley, and the CEO of Palmetier Law, Karri Palmetier, are presenting the session, and will be taking questions (and available to speak with attendees after the seminar).  We encourage all Colorado-based government contractors and grantees to attend (but hurry; space is limited). 

Please feel free to contact us if you have any questions about the event, or contracting and compliance in general.

Topics: PTAC, Colorado PTAC, FAR compliance, FAR Training, DCAA Training

ReliAscent Seminar at Colorado PTAC - "FAR 101 – Quick Tour and Key Clauses"

Posted by Tyler Link on Mon, Mar 12, 2018 @ 10:58 AM

FAR Compliance - ReliAscent PTAC Seminar on the FAR.jpg

ReliAscent AE, Dave Donley, and the CEO of Palmetier Law, Karri Palmetier, will be presenting a seminar at the Aurora Office of the Colorado Procurement Technical Assistance Center (PTAC), on March 22nd, as part of their Expert Training seminar series. This training session is a valuable opportunity for all federal contractors, and small businesses looking to sell to the "World's Biggest Customer."

Topic: FAR 101 - Quick Tour and Key Clauses

Summary: Dave will cover a number of important issues for government contractors, including: 

  • FAR Organization
  • Contract Types
  • SAM.GOV Reps/Certs
  • Flowdown Clauses
  • Commercial Items
  • Cost-Pricing
  • Contract Financing
  • Contract Performance

This will be followed by a panel discussion on best practices, tips, and Q&A.

This class is essential especially for Federal contractors whether prime or sub!

Date: March 22, 2018 (1:30  - 4:00 PM)
Cost: FREE
Location: 14305 E Alameda Suite #300, Aurora, CO

TO RESERVE YOUR SEAT, CLICK HERE NOW!

We look forward to seeing you there, and as always; if you have any questions about DCAA compliance, government contract accounting, or contract management, please do not hesitate to contact ReliAscent.

Topics: PTAC, Colorado PTAC, FAR compliance, FAR Training, DCAA Training

NIH Salary Limitation for 2018 Just Released

Posted by Dave Donley on Wed, Mar 07, 2018 @ 10:50 AM

NIH Salary LimitsSince 1990, the NIH, through annual funding from Congress, and more recently continuing resolutions, sets salary limitations for individuals having NIH grants, cooperative agreements, and contracts. This annual salary limitation is benchmarked at the Executive Level II of the Federal Executive pay scale. The NIH Notice Number NOT-OD-18-137 released March 7, 2018, increases this limit to $189,600, or $91.15/hour.

The notice goes on to say, “If adequate funds are available in active awards, and if the salary cap increase is consistent with the institutional base salary, grantees may rebudget to accommodate the current Executive Level II salary level. However, no additional funds will be provided to these grant awards.”

Other details and FAQs provided in the past with this notice have not been published. If there are questions surrounding the implementation of this policy, please contact us.

Topics: NIH SBIR, NIH salary limits, NIH Salary Cap Increase

“Snatching Success From The Jaws of (Apparent) Defeat” - ReliAscent Featured Partner Blog (Part V)

Posted by Rich Busch on Tue, Mar 06, 2018 @ 10:43 AM

The following blog is the fifth in a series of special guest and ReliAscent partner blogs, contributed by Richard Busch of the Busch Law Firm, and Mike Anderson, of ReliAscent.  This series covers important topics ranging from an introduction to government contracting, to requests for equitable adjustments, risk management, contract change orders, and scope creep.  Additionally, our series will cover government financial assistance efforts, and how defense contractors--both small and large business (along with subcontractors)--can increase profits, improve their ability to strategically plan for the future and remain profitable.

By combining DCAA compliance and accounting expertise with defense contracting and FAR compliance legal representation and consultation, ReliAscent and Busch Law can help position contractors for financial success…

"Follow the Trail of What is Really Happening After Award, and POLICE your Competitor's Contract

Challenging your competitors contract

ATTN:  Small and medium-sized government contractors DO NOT miss a chance to still be awarded an opportunity previously awarded to your competitor.  More often than not, post award modifications to the competitor’s contract will disclose an out-of-scope change order that should have been competed.  If the modification is beyond the original general scope of the contract or outside of the terms of the original Solicitation----you have an opportunity to challenge that modification of the contract that was awarded to your competitor.   

 

Scenario

You consider your company a competitor in the Government marketplace for the Statement of Work being procured.  Nevertheless, you lost a heavily competed contract award based upon the Government’s perceived needs; yet you know the award is flawed through a combination of the factual circumstances and the Government’s actual needs.  You can see the gaping hole in the best value evaluation of the proposed performance of the awardee.  You know that a GAO review is subjective and focuses on discretion in the Government’s evaluation as stated in the procurement statutes and regulations.  In reality, the GAO’s analysis is superficial and unrealistically focused on the Government’s position.  This contract is still important to your company’s financial/technical future.

 Although compliant with the GENERAL terms of the statutes and regulations, can/how is the Government going to adjust the award to the reality of their mistakes? The actual facts and circumstances tell a different story.

 

Conclusion

You must proactively “police” your competitor’s contract for contract modifications, unilateral or bilateral, which are outside the general scope of the competition requirements and the awarded contract. 

 

“Policing” means What?

 The oversight Government Agencies will NOT review the administration of an awarded contract; including modifications.  The exception to this general rule is where you allege that a contract modification is beyond the scope of the original competition and awarded contract.

Your review of the facts must determine if, absent a valid sole-source determination, the work covered by the modification should be subject to full and open competition. In short, you must focus on:

“Is the modification, in effect, an unjustified sole source contract?”

You must determine what “material differences” are between the modified contract and the originally compete award.  Compare the modification with:

  • Extent of the any changes in the type of work;
  • Performance period;
  • Adjusted costs of performance;
  • If competed technical requirements were altered based upon the reality of the circumstances;
  • Changes in the “scope of the competition” more than changes in “scope of the contract;”
  • Do the ordered modifications alter the nature of the item that was competed and awarded;
  • Did the original Solicitation advise the offerors of the potential for these types of changes during the performance of the contract;
  • Would the field of competition be different after the modification;
  • Was the award made with the intent to modify it after award; and
  • Would you have reasonably anticipated this modification under the changes clause.

The simple initial question is whether the change is within the general scope of the competition. The terms of the solicitation and the contract are of paramount importance when compared to the language and INTENT of the modification and the overall acquisition planning process.

If properly justified and supported, your policing activities could be very effective by canceling the modification and obtaining work through the competitive process.  In addition, it may alter the way the Agency will administer the competitor’s contract and draw focus on their performance accounting.  You may get your costs of protest reimbursed AND have the Agency agree to an increase focus potential disallowance of your competitor costs.         .

 While it is true the statutes and regulation on their face may not have been violated, the facts and circumstances of the actual competition and award may create many more issues in your favor.  A thorough review of these factors are important, along with the actual accounting of the cost and should cost of performance.   This two prong approach combine to form a solid approach to “bust” the award and contract performance beyond the discretionary baseline of a normal protest. 

While the stated circumstances may cover the facts, the accounting of performance costs cannot hide the reality of changes beyond the general scope of the award.  

The team of the Busch Law Firm and ReliAscent can discover the true story if the general scope of the competition requirements and the awarded contract is now proper.  

- Richard Busch
Managing Partner, Busch Law Firm LLC

Topics: contract change orders, Colorado Defense Contractors, scope creep, How to stay profitable with defense contracts, Request for Equitable Adjustment (REA)

ReliAscent Introduces Free Indirect Rates Reviews for Contractors

Posted by Tyler Link on Tue, Feb 27, 2018 @ 10:00 AM

Indirect Rates Reviews for Government Contractors

Are your Indirect Billing Rates Causing you to Lose Money?

Indirect Rates are absolutely critical for managing costs effectively, and ensuring your small business stays profitable.  However, if a government contractor doesn't know HOW to properly manage their indirect rates—or, if they're not making strategic modifications to their rates at the right times—they could be losing a lot of money. 

To help small business government contractors make the most of their indirect billing rates, ReliAscent is excited to announce the industry’s first, Free Indirect Rates Review.  This review provides contractors and grantees with sound, valuable advice about their indirect rate system & structure, can help them to understand and maintain DCAA compliance, and can help a small business use their rates as a financial engine to grow their company.

TO GET YOUR FREE INDIRECT RATES REVIEW, CLICK HERE NOW!

With just a little information about your company, our experts can complete your indirect rates review and schedule a call to discuss the path forward, should you need help fixing any errors detected.

We encourage small business federal contractors to take advantage of this helpful service, and as always, if you ever have any questions about FAR and DCAA compliance, or our accounting and contract management services for Federal Contractors & Grantees, please do not hesitate to contact us at any time.

Topics: Indirect billing rates, Indirect rates, indirect rates review, managing your indirect rates

DCAA Compliance White Papers

Posted by Tyler Link on Wed, Jan 31, 2018 @ 11:48 AM

It's SBIR season again, and ReliAscent would like to remind contractors that the DoD 2018.1/A SBIR/STTR BAA closes on February 7th.

Now is a good time to make sure your business is prepared informed.  Be sure to download our popular white papers:

We wish you the best of luck on your proposal submissions, and do not hesitate to contact ReliAscent if you have any questions, or would like to discuss how our DCAA compliant accounting and contract management experts can help your small business.

Stay Informed. Stay Compliant. Stay Profitable.

Topics: DCAA compliance, DCAA Compliant Accounting, SF1408, white papers, dcaa audit checklist

“Requests for Equitable Adjustment – Essential in Government Contracting” - ReliAscent Featured Partner Blog (Part IV)

Posted by Rich Busch on Thu, Jan 25, 2018 @ 09:00 AM

The following blog is the fourth in a series of special guest and ReliAscent partner blogs, contributed by Richard Busch of the Busch Law Firm, and Mike Anderson, of ReliAscent.  This series covers important topics ranging from an introduction to government contracting, to requests for equitable adjustments, risk management, contract change orders, and scope creep.  Additionally, our series will cover government financial assistance efforts, and how defense contractors--both small and large business (along with subcontractors)--can increase profits, improve their ability to strategically plan for the future and remain profitable.

By combining DCAA compliance and accounting expertise with defense contracting and FAR compliance legal representation and consultation, ReliAscent and Busch Law can help position contractors for financial success…

"Maintain the benefit of the bargain during performance through requests for equitable adjustment." 

Requests for Equitable Adjustment

Government Contract Changes

There is no perfect contract.  Changes to the contract performance baseline is a common occurrence.  When contracting in the federal, state, or local government market place, the contractor must be prepared to effectively manage any changes to the negotiated performance baseline.   

Most importantly, the Government Change clause provides a  regulatory procedure to process an equitable adjustment due to a change to the work effort.  A Request for Equitable Adjustment is an administrative procedure used by the contractor to avoid a conflict and maintain the benefit of the bargain originally negotiated between the parties in an administrative action.

 

What Makes Government Contracts Unique

The Federal Acquisition Regulation Changes clause gives broad powers to the government to adjust the contract performance baseline. Good contract administration is not only important but required in order to:

  • Manage technical changes in a timely manner;
  • Avoid any misunderstandings;
  • Take mutually “agreed to” corrective actions, if necessary; and
  • Negotiate an administrative resolution without a dispute.

In that regard, the parties may mutually agree to changes considered to be part of the original work effort.  In addition, the Changes clause provides that the contractor may propose changes to the work to:

  • Gain more efficient performance;
  • Provide greater quality of the contract end product; and
  • Demonstrate a collaborative approach with their customer to achieve mission success.

The Changes clause also provides for the Government to issue a “unilateral” administrative change under specific circumstances.  It is important for the Contractor to recognize when and if the change must be bilateral and not unilateral.

Finally, this unique provision could allow the Government to order additional work within the general scope of the contract without conducting a full competition for the additional work.

 

Government Subcontractors

The Request for Equitable Adjustment from the prime contractor may include the cost of any changed work of the Subcontractor.  This “ripple effect” from Subcontractor to Prime contractor to the Government must be effectively managed.  A subcontractor Request for Equitable adjustment is a specialized process to recover compensation for additional work performed on the subcontract.  These “Pass-Through” claims must be developed and administered in such a manner to effectively recovery within the complex regulatory process of the Federal Acquisition Regulation.

 

Government Contract Administration

A successful prime or government subcontractor will always administer their performance against the requirements of the original performance baseline.  The Contractor must ensure any proposed change is within the general scope of the contract and properly documented.  Accurate cost records are vital to the development of any increased costs requested. Most importantly, a Request for Equitable Adjustment is an administrative function which would allow recovery of consultant and attorney’s fees as an allowable cost.        

This process is very unique to Federal Government contracts and many contractors do not understand how to process requests for Equitable Adjustments.  This is where experience is a big factor in not only knowing when this is possible but how to do it and what to ask for when you do it.  It is not uncommon for a government contractor to rely on a consulting expert in the field to help with these requests.   A good consulting expert (like ReliAscent and The Busch Law Firm) will not only know how to process this but when to process it and how to negotiate this to achieve the optimum result for the contractor.   

- Richard Busch
Managing Partner, Busch Law Firm LLC

Topics: contract change orders, Colorado Defense Contractors, scope creep, How to stay profitable with defense contracts, Request for Equitable Adjustment (REA)

Government Shutdown – Déjà vu All Over Again...

Posted by Dave Donley on Fri, Jan 19, 2018 @ 09:23 AM

Federal Government Shutdown

As of this writing, the U.S. is scheduled to shutdown at midnight, tonight. One of the first things you learn in government contracting is something called the Anti-Deficiency Act, first enacted in 1870, which says the government can’t obligate expenses unless funding has been appropriated through Congressional action. The Act also prohibits the government from accepting voluntary services not already authorized by law.

Without Congressional action for further appropriation of funds by midnight, the government is prohibited from paying personnel (except Congress, and other officials) and for other services, including grants and contracts. Fortunately, much of the funding provided by the government to our clients has already been appropriated and will continue to be funded.

Below is a list of what we know so far on the latest shutdown.

Payment systems

Payments through WAWF (DoD) could be delayed, however the Prompt Payment Act still applies, so interest penalties will be paid.

Grant draw down systems, such as the DOE’s ASAP and NSF FastLane are expected to be operating.

Contract funding

Contract funding for incrementally funded contracts could be disrupted during the shutdown. If contracts have costs or billings at or near the funded limit, contractors may not be reimbursed for performance during the shutdown period. However, if funding is sufficient, contractors are obligated to continue performance even if there is a government shutdown.

New Contracts and Grants

Contract and grant awards would likely be delayed due to a shutdown. Deadlines for submitting proposals or applying for grant may or may not be extended due to shutdown periods.

Government Support Contractors

Those who provide IT support or other personnel services to the government may be particularly vulnerable to a government shutdown. Support operations may be halted, so a contractor should expect a Stop Work order from their contracting officer. Employees may have to be either furloughed or charge to indirect labor accounts. Government employees typically receive back pay for shutdown periods. However, contractors may not.

Results May Vary

The impact from a government shutdown is wide-ranging. Government agencies have some latitude on what they can continue to fund during a shutdown period. As a government contractor and grantee, the implication for your business may vary widely from others. It’s always best to take up any specific concerns to your contracting officer who at this point is likely the most knowledgeable and your best advocate.

Contact Us

Bear in mind that even if the government avoids a shutdown tonight, continuing resolutions funding the government could be extended day-to-day or week-to-week, making this a chronic risk to contractors and grantees.

Feel free to contact us with your concerns and observations on this latest wild ride.

Topics: Federal Government Shutdown