Category Archives: Subcontract Oversight & Compliance

Government Shutdown: Day 24

The partial government shutdown began at midnight on December 21, 2018. As the shutdown entered its twentieth-fourth day, many government contractors were rightfully concerned about the status of negotiations between Congress and the president, the length of the shutdown, and its impact on their current and future contracts. As for the status of White House/Capitol Hill negotiations and the likely length of the shutdown, it is hard to say. Continue reading Government Shutdown: Day 24

Civilian Board of Contract Appeals’ 2018 Annual Report – A Review and Quantitative Snapshot

The US Civilian Board of Contract Appeals (CBCA)[1] released its FY 2018 Annual Report in December 2018.[2] Significant developments in FY 2018 included the institution of new board procedural rules, the transition to all-electronic files from a combination of electronic filings and paper file-based systems, and the addition of Disaster Disputes stemming from damages caused by Hurricanes Katrina, Rita, and Gustav.

From a case-load perspective, the number of cases filed at the CBCA ticked up to 409 in FY 2018 from 385 in FY 2017. The number of CBCA cases appealed to the US Court of Appeals for the Federal Circuit also increased 69 percent in 2018 to twenty-seven from sixteen in 2017. Continue reading Civilian Board of Contract Appeals’ 2018 Annual Report – A Review and Quantitative Snapshot

Pentagon Has Issued New “Other Transactions Guide”

The Pentagon has stated for some time the need for increased innovation, speed, and affordability in defense systems acquisition. The Pentagon, via the Office of the Under Secretary of Defense for Acquisition and Sustainment, now has added additional clarification by issuing a new Other Transactions (OT) Guide. Continue reading Pentagon Has Issued New “Other Transactions Guide”

GSA Inspector General Investigating Fraudulent Activity on Contractor and Grantee Registration Website

The General Services Administration’s inspector general is investigating fraudulent activity on its contractor and grantee registration website after someone allegedly redirected federal payments to bank accounts not tied to the appropriate contractors. Continue reading GSA Inspector General Investigating Fraudulent Activity on Contractor and Grantee Registration Website

Information on Corporate Contractor Performance and Integrity

The Department of Defense, General Services Administration, and National Aeronautics and Space Administration issued a final rule on March 7, 2016, that requires offerors to disclose within the Federal Awardee Performance and Integrity Information System (FAPIIS) information on any parent, subsidiary, or successor entities that held a Federal contract or grant within the last three years.   Continue reading Information on Corporate Contractor Performance and Integrity

OMB Circular – Proposed Guidance

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Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements (including Single Audit Act)

By: Mary Karen Wills

The complete text of this proposal and a crosswalk of policy changes from the existing guidance are available on the OMB website under Proposed Policies.

This guidance is applicable to grants and cooperative agreements that involve state, local, and tribal governments, as well as institutions of higher education and nonprofit organizations. The proposal rule seeks to consolidate and streamline the requirements from OMB Circulars A-21, -89, -110 and -122. In addition, Circulars -50, -89, -102, and -133 on audits would be consolidated and streamlined. This guidance seeks to minimize the burden associated with compliance and audits for the grants and cooperative agreements with the aforementioned organizations. The goal would be to replace these eight circulars with one document, resulting in a single set of rules across these entities that currently have varying degrees of requirements.

Continue reading OMB Circular – Proposed Guidance