Tag Archives: contractor

Year-End Compliance Planning for Federal Contractors and Awardees

As another year comes to a close, BRG’s Government Contracts Advisory Services team is here to share a year-end compliance planning checklist for Federal Contractors and Awardees. As you get ready to close the books on another year, these proactive efforts can help your organization prepare for and reduce delays in completing annual compliance and business processes, audit readiness, mitigation of potential issues, and improvement of audit outcomes and internal/external reporting. Continue reading Year-End Compliance Planning for Federal Contractors and Awardees

President Obama Orders Paid Sick Leave for Federal Contractors

On Labor Day 2015 (Monday, September 7), President Obama signed the Executive Order “Establishing Paid Sick Leave for Federal Contractors,” requiring Federal contractors to offer their employees up to seven days of paid sick leave per year.  Continue reading President Obama Orders Paid Sick Leave for Federal Contractors

Updated DCAA Guidance on Expressly Unallowable Costs

In recent months, expressly unallowable costs have emerged as a focal point for the Defense Contract Audit Agency (DCAA). DCAA has issued two Memorandums for Regional Directors (MRDs) providing auditors with new guidance on identifying expressly unallowable costs, much to the dismay of contractors who believe that the guidance does not align with the intent of the applicable cost principles. These MRDs likely mean that contractors will receive more penalty recommendations than in years past, in addition to potential assertions of CAS 405 non-compliances. Continue reading Updated DCAA Guidance on Expressly Unallowable Costs

The DCAA Website Gets a Facelift

By: Kelly Lynch

The Defense Contract Audit Agency (DCAA) website has received a facelift (www.dcaa.mil). The website now provides contractors with detailed instructions on how to request an audit; the site also provides a more direct path for contractors to understand the DCAA processes for all audits the agency conducts. Unfortunately, the new website will not help contractors receive more timely audits; however, it provides more information on what to expect during an audit.

If you notice that something is missing from the DCAA website, or if there is something you think should be added, we would love to hear from you.

Continue reading The DCAA Website Gets a Facelift

Key FAR Updates

Nondisplacement of Qualified Workers Under Service Contracts – Final Rule (FAR Case 2011–028)

By: Ryan Byrd

This final rule adds FAR subpart 22.12, entitled ‘‘Nondisplacement of Qualified Workers Under Service Contracts,’’ and a related contract clause.

The regulations require that workers on a federal service contract who would otherwise lose their jobs as a result of the completion or expiration of a contract be given the right of first refusal for employment with the successor contractor. The regulations apply to all service contracts (prime and subcontractor) above the simplified acquisition threshold (currently $150,000) and their solicitations, except those excluded, that succeed contracts for the same or similar services at the same location. The FAR excludes certain types of contracts and employees from its requirements, and allows the head of a contracting department or agency to exempt any of its contracts from the regulations if it finds the requirements would not serve the purposes of the Equal Opportunity Act or would impair the federal government’s ability to procure services economically or efficiently.

Continue reading Key FAR Updates

GAO Report GAO-13-158 – Pension Costs on DoD Contracts: Additional Guidance Needed to Ensure Costs Are Consistent and Reasonable

By: Matt Franz

On January 22, 2013, the GAO issued a report on its review of DoD contractor pension costs. The review was performed in response to an increase in pension costs since the 2008 market downturn and the prospect of recent changes to Cost Accounting Standards (CAS) and Employee Retirement Income Security Act (ERISA) rules regarding the calculation of pension costs potentially resulting in further cost increases.

Continue reading GAO Report GAO-13-158 – Pension Costs on DoD Contracts: Additional Guidance Needed to Ensure Costs Are Consistent and Reasonable