DCAA Compliance Blog

Your Source for DCAA & FAR Compliance News and Discussion

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

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!  


 

Tribal & other SBA 8(a) Sole Source Awards

Posted by Mike Anderson on Fri, Dec 19, 2014 @ 04:36 PM

As the Federal Budget tightens up and opportunities for contractors become more difficult to find, there may be more partnerships and joint ventures. There is a unique way for some of these partnerships to provide opportunities for small business. There is a section in the Federal Acquisition Regulations (FAR) that allows for both teaming arrangements and/or joint ventures. This is found in FAR 9.6. The reason for this is the government believes that these arrangements could provide for the best value to the government in certain situations. According to the FAR these are especially appropriate in research and development focused awards as a single vendor may not have all the expertise that is required to complete the research on their own. That makes sense. They also think that this is applicable to production awards. Again, it may make sense, especially if there could be a specialty operation required that a company needs to enlist an “expert” in the field.

What may not be widely known, is that an SBA 8(a) company that is owned by an Indian Tribe, an Alaskan Native Corporation (ANC) or Native Hawaiian Organization (NHO) may be exempt from the competitive bidding process per 13 CFR 124.506(b). The only major restriction is that the procurement may not be designated for competition and then subsequently removed from competition to award it sole source per 13 CFR 124.506. This could provide opportunities for small businesses to partner with Indian Tribe owned company or an ANC or NHO company. If the small business holds an expertise that is valuable to these companies, it can be a beneficial to a small business with a unique service to partner with an Indian Tribe, ANC or NHO company on one of these opportunities.

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Topics: SBA, Sole Source


Small Business Subcontracting Goals

Posted by Mike Anderson on Fri, Sep 19, 2014 @ 05:06 PM

ReliAscent is a small business (as defined by the SBA). All of our clients are small businesses. The Small Business Administration’s Office of Advocacy has recently released statistics relative to small business that I think are encouraging to all of us small businesses. The overall statistic of interest to people in industry is the amount of government contracts being given to small business. The government wide objective is 23% of all contracts to go to small business. The report for FY 2013 shows that the overall government small business contract level at 23.9%, which meets the objective. What is a little misleading here is that not all agencies are above the objective. For instance, let’s look at 2 of the largest agencies in the government, the DoD and DoE. DoD is at 21% and DoE is at 5.71%. Both are below the goal. Other departments like Agriculture (at 54.88%) and Interior (at 59.16%) help make up the difference. It takes quite a few of the smaller agencies above the limit to make up a small difference in defense spending because the overall budget of the Defense Department is so large. Also, contracts in areas like the Commission on Civil Rights (at 100%), Commission of Fine Arts (at 100%) or the Agency for International Development (at 101.71%) probably don’t use any technical services. So a lot of the expenditures by the government in meeting the small business goal may be skewed to certain areas which mean not all industries (especially some of the technically oriented businesses) are going to receive 23% of the share in their area of expertise. Still, this is an achievement to reach the goal of 23%, which hasn’t happened in the past. The fact that 63% of the net new private-sector jobs have come from small business over the last several years is significant. 99.7% of the “employer firms” in this country are small businesses. From 2008 thru 2010 there were more small businesses that “died” than new firms created. That trend has changed and there were 800,000 new business creations in 2012 compared to 732,000 business deaths in 2012 (the most current year data is available). California leads, by far, all states in the creation of new small businesses. For 2013, California recorded 73,900 new businesses, more than twice the amount of the next state (Florida with 33,000). California also leads the country in small business employment with over 6 million employees in small businesses (Texas is second with over 4 million). What is encouraging to me is that the trend is up for government contracts going to small business. The number of new small businesses is again growing and employment from small business is growing. These are all solid signs of an economic recovery. Small business is definitely the driver in America’s economy and we are seeing the Federal Government recognize this. Yes, the way in which some of these statistics are measured is debatable but the fact of improvement cannot be lost.

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Topics: SBA, Small Business Goals, Small Business Subcontracting Plan


Region VIII SBA Regulatory Fairness Board Hearing

Posted by Mike Anderson on Tue, Aug 26, 2014 @ 10:59 AM

Back in May I wrote a blog on the Small Business Administration’s Office of the Ombudsman.   I had the opportunity to meet the National Ombudsman, Brian Castro, earlier this month.  Brian is a busy man and spends a lot of his time trying to be the “go between” for small business to the various agencies.  I met Brian at a Region VIII Regulatory Fairness Hearing.  Several small businesses were offering their testimony of problems or issues regarding federal regulations and enforcement or compliance actions impacting small Business.   There are ten regions across the country, like our Region VIII, and Brian regularly travels around to the regions to hear testimony and to talk with Small Businesses, trade associations and other members of the small business community. 

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Topics: SBA, Small Business Regulatory Fairness Board, Office of National Ombudsman


NDIA & Colorado PTAC Panel Discussion on Contracting Issues (Part 2)

Posted by Mike Anderson on Fri, Aug 22, 2014 @ 07:00 AM

This is a continuation of the last blog relating issues that were discussed in the Colorado Springs NDIA panel discussion.  I thought these issues were relevant enough to devote 2 blogs to cover the content.

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Topics: PTAC, SBA, NDIA, Office of National Ombudsman


NDIA & Colorado PTAC Panel Discussion on Contracting Issues

Posted by Mike Anderson on Tue, Aug 19, 2014 @ 04:11 PM

Last week I attended a Rocky Mountain Chapter NDIA meeting in Colorado Springs.  The meeting was a panel discussion about small business issues in government contracting and featured the Small Business Administration’s (SBA) Ombudsman, Brian Castro.  Brian is tasked with assisting small businesses that experience excessive or unfair regulatory enforcement actions involving a Federal agency.  Essentially this means that the Ombudsman is a “go between” to help small businesses resolve issues with Federal agencies.  Other members of the panel, moderated by the Colorado PTAC Executive Director Gary Henry, were Willie Franklin (CH2MHill – large business representative), David Hollenbach (DSoft Technologies – small business representative), Paul Aldrich (Small Business Specialist – Schriever AFB), Kim Diercks (Contracting Officer – USAFA) & Russ Farmer (representing NDIA & ReliAscent).  The goal of the discussion was to create open dialog between small businesses, industry and government personnel.  I found the panel discussion enlightening as it raised some issues I hadn’t heard before.

 

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Topics: PTAC, SBA, NDIA, Office of National Ombudsman


SBA Statistics Show Small Business Improving

Posted by Mike Anderson on Tue, Jul 15, 2014 @ 03:07 PM

The Small Business Administration (SBA) keeps statistics on small businesses in the United States.  Recent data from the first quarter of 2014 show positive results for small business growth after a period of stagnant growth since the recession of 2009.  Across the United States, Small Business accounts for a majority of job growth so when the small business sector took a hit in the last recession, it had a significant impact on the economy as a whole.  For instance, in 2009 the "birth rate" of new small business was at it's lowest point in the last 10 years.  This rate has been on a slow, but steady, increase since early 2010.  When you combine that with the "death rate" of small businesses (again at a peak in 2009) there are some positive indicators.  The death rate has declined more rapidly over the last several years, meaning more small businesses are surviving.  The amount of income from small business has steadily increased since 2009 showing again a positive indicator for this sector.  Finally, the hiring rate for small businesses is above the separation rate (indicating a positive gain in employment) and the gap appears to be the largest gap for several years. Take Colorado for instance, there are almost half of the state's private workforce employed by small business concerns.  This percentage is not too far off of the national average.  Further, almost 98% of all employers in the state are small businesses.  It is also interesting to see that the largest gain in new jobs was from firms in the 1-4 employee size category. 

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Topics: SBA, Small Business


SBA report on Small Business Procurement Goals

Posted by Mike Anderson on Fri, Jun 06, 2014 @ 01:26 PM

The National Defense Authorization Act of 2013 called for an independent assessment of the small business procurement goals.  The SBA has just released a report entitled "Evaluation of the Small BUsiness Procurement Goals Established in Section 15(g) of the Small Business Act: A Report Pursuant to SECtion 1631(d) of the National Defense Authorization Act of 2013".  We will summarize some of the findings of this report in this blog but there is always a debate about the validity of the numbers.  I attended an NDIA meeting a couple of months ago where many small business owners in the room questioned and doubled the numbers being reported by the government.  I guess it boils down to the old adage that the three biggest lies are resumes, "the check is in the mail" and statistics. 

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Topics: SBA, National Defense Authorization Act of 2013, Procurement Goals