Tag Archives: DFAR

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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GovCon Research Report: Volume 2, Issue 4

October – December 2013

Berkeley Research Group’s Government Contracts Advisory Services (GCAS) practice keeps its clients up to date on the latest regulatory developments affecting the government contracts industry.

The seventh edition of the GovCon Research Report summarizes the critical regulatory and compliance issues contractors faced in the fourth calendar quarter of 2013. The issues are summarized by the following key subject-matter areas

  •  National Defense Authorization Act of Fiscal Year 2014
  • OMB Final Guidance
  • Key Federal Acquisition Regulation Updates
  • Recent Updates to Defense Contract Audit Agency Guidance
  • Defense Federal Acquisition Regulation Supplement Updates
  • Relevant GAO Reports
  • Department of Defense – Office of Inspector General Reports

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GovCon Research Report: Volume 2, Issue 3

July–September 2013

Berkeley Research Group’s Government Contracts Advisory Services (GCAS) practice keeps its clients up to date on the latest regulatory developments affecting the government contracts industry.

The sixth edition of the GovCon Research Report summarizes the critical regulatory and compliance issues contractors faced in the third calendar quarter of 2013. The issues are summarized by the following key subject-matter areas:

  • Special Inspector General for Iraq Reconstruction
  • Office of Inspector General Reports
  • Key Federal Acquisition Regulation (FAR) Updates
  • Key Defense Acquisition Regulation (DFAR) Updates
  • Defense Contract Audit Agency (DCAA) Guidance
  • Small Business Administration Updates
  • Key Office of Management and Budget Updates

To read the full report, click here.

GovCon Research Report: Volume 2, Issue 2

April–June 2013

Berkeley Research Group’s Government Contracts Advisory Services (GCAS) practice keeps its clients up to date on the latest regulatory developments affecting the government contracts industry. This edition of the GovCon Research Report summarizes the critical regulatory and compliance issues contractors faced in the second calendar quarter of 2013. The issues are summarized by the following key subject-matter areas:

  • GSA Matters
  • DoD Office of Inspector General Reports
  • Pertinent Government Accountability Office (GAO) Audit Reports
  • Key Federal Acquisition Regulation (FAR) Updates
  • Key Defense Acquisition Regulation (DFAR) Updates
  • Latest on Sequestration and Government Spending

To read the full report, click here.

DFARS Forward Pricing Rate Proposal Adequacy Checklist

By: Kelly Lynch

On May 16, 2013, the Department of Defense (DoD) issued a proposed revision to the Defense Federal Acquisition Regulations System (DFARS) that would require contractors to submit a forward pricing rate proposal adequacy checklist with forward pricing rate proposals. Similar to the DFARS Proposal Adequacy Checklist implemented on March 28, 2013, this checklist is intended to ensure that offerors take responsibility for submitting thorough, accurate, complete, and current proposals.

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GovCon Research Report: Volume 2, Issue 1

Berkeley Research Group’s Government Contracts Advisory Services (GCAS) practice keeps its clients up to date on the latest regulatory developments affecting the government contracts industry. This edition of the GovCon Research Report summarizes the critical regulatory and compliance issues contractors faced in the first calendar quarter of 2013. The issues are summarized by the following key subject-matter areas:

  • GSA and VA Schedule Matters
  • Office of Inspector General Reports
  • Pertinent Government Accountability Office (GAO) Audit Reports
  • OMB Proposed Guidance
  • Key Federal Aquisition Regulation (FAR) Updates
  • Key Defense Acquisition Regulation (DFAR) Updates
  • Latest on Sequestration and Government Spending
  • Other News

To read the full report, click here.

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.

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