Key Concerns for Government Contractors
Thursday, August 12th, 2010
The environment in which government contractors have to work within has changed significantly over the last couple of years and the trend looks to continuing. The changes have created uncertainty in the industry and concerns as to potential increased risk to contractors. The attached PowerPoint documents address these changes and their impact to the industry. Subjects covered include:
- Life under the new DCAA attitude
- Allowability of Specific Costs
- Adequate and Timely Incurred Cost Proposals
- Business Ethics & Conduct and Mandatory Disclosure
- Proposed DFARS Rule: Withholding Payments to DoD contractors
- Prime Contractor Management of Subcontractors
- Organizational Conflict of Interest – DFARS update, Requirements and problems
- Reporting Subcontract Awards Greater than $25,000
- American Recovery and Reinvestment Act
FAR Subpart 4.15 – Reporting Requirements - DoD Finalizes Changes to DFARS on Export Control
- Labor Relations Cost – Cost to fight unionization unallowable
DoD finalizes changes to DFARS on export control
Wednesday, June 30th, 2010
DoD Contractors and Subcontractors: Are You Complying with the New Flowdown Notice Requirement on U.S. Export Control Laws?
Compliance with U.S. export control laws is critical during this time of heightened enforcement. A recent U.S. Department of Defense (“DoD”) Final Rule requires that a clause mandating strict compliance with U.S. export control laws and regulations be included in all DoD solicitations and contracts, including contracts between prime contractors and subcontractors. On April 8, 2010, the DoD amended the Defense Federal Acquisition Regulation Supplement (“DFARS”) to include this new requirement, which is provided at DFARS, 252.204-7008.1 This “flowdown” clause must be contained in all subcontracts arising from a DoD prime contract.
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DCAA audits of airfare cost
Monday, May 3rd, 2010
The changes to the definitions of what is allowable airfare cost chargable to the government is being miss-used by DCAA to require increases in documentation by the contractor and to disallow such cost which in turn significantly increses the administrative cost of documenting travel costs and the risk that such cost would be disallowed by DCAA
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