Tag Archives: Defense Procurement and Acquisition Policy

DRAFT Department of Defense “Guidebook for Acquiring Commercial Items”

The Defense Procurement and Acquisition Policy (DPAP) is interested in comments and input on the DRAFT of “Part A: Commercial Item Determination” and “Part B: Pricing Commercial Items” in the Guidebook for Acquiring Commercial Items. Continue reading DRAFT Department of Defense “Guidebook for Acquiring Commercial Items”

Defense Federal Acquisition Regulation Supplement: Proposed Rule Change Adds New Requirements for Contractors’ Business Systems

On July 15, 2014, the Defense Procurement and Acquisition Policy (DPAP) issued DFARS Case 2012-D042, a proposed rule adding new requirements for applicable contractors to annually self-assess their estimating systems, accounting systems, and material management accounting systems (MMAS) in accordance with DFARS 252.215-7002, 252.242-7006, and 252.242-7004, respectively.

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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