Category Archives: Mary Karen Wills

National Conversation on Board Diversity

On Thursday, November 20, in Washington, DC, Mary Karen Wills will participate in this third annual 2020 Women on Boards event, which will discuss how the United States can become a global leader in the advancement of women in board rooms.  Continue reading National Conversation on Board Diversity

Understanding the New OMB SuperCircular

On September 16, Mary Karen Wills and Ryan Byrd were instructors at a webinar concerning non-governmental organizations and federal awards. Continue reading Understanding the New OMB SuperCircular

Understanding the New OMB SuperCircular (Webinar)

On August 13, Mary Karen Wills and Ryan Byrd were instructors at a webinar concerning non-governmental organizations and federal awards. Continue reading Understanding the New OMB SuperCircular (Webinar)

Understanding the New OMB SuperCircular

On July 15, Mary Karen Wills and Ryan Byrd were instructors in this Public Contracting Institute webinar concerning non-governmental organizations and federal awards.

Continue reading Understanding the New OMB SuperCircular

Update on Unallowable Costs for Ineligible Dependent Health Care Benefit Costs

By: Mary Karen Wills

On February 17, 2012, Shay Assad, the director of Defense Procurement and Acquisition Policy (DPAP), issued a memorandum regarding “Unallowable Costs for Ineligible Dependent Health Care Benefits.” This memo reiterated that costs incurred by contractors for ineligible dependent healthcare are unallowable as they represent invalid claims made by employees. The memo affirmed that DoD would not pursue penalties under FAR 42.709 related to these costs, but that DoD intended to amend the DFARs in this regard to enable it to pursue penalties in the future.

Fast-forward to March 28, 2013: DCAA issues Audit Guidance Memorandum 13-PAC-004(R) transmitting the DPAP guidance to its auditors (http://www.dcaa.mil/mmr/13-PAC-004.pdf). DCAA affirms that auditors should not pursue application of penalties under FAR 42.709 related to questioned ineligible dependent healthcare benefit costs. In addition, DCAA auditors are instructed not to cite contractors for CAS 405 noncompliance when they fail to exclude these costs from Government contracts.

Continue reading Update on Unallowable Costs for Ineligible Dependent Health Care Benefit Costs