Increase threshold in Price proposal audits
Monday, November 1st, 2010
A DCAA memo issued 10/18/2010 raises the threshold for price proposal audits.
According to the memo, contracting officers’ requests for DCAA reviews of contractor cost data must meet a threshold of $10 million for fixed-price proposals and $100 million for cost-type proposals, unless there are exceptional circumstances.
Previously, the threshold was $700,000 for fixed-price proposals and $10 million for cost-type proposals. The rule became effective Sept 17, 2010
Tim
Click here for a copy of the DCAA memo
Full CAS coverage for contracts performed entirely outside the US
Wednesday, October 20th, 2010
Attached is a Federal Register on the Office of Federal Procurement Policy seeking comments on its proposed rule change in CAS exemption CAS qualified contracts performed entirely outside the US, its territories, and possessions from the CAS. As you read through this doc you will see that OFPP submitted this same proposal for public comment in April 2009. The comments received are included in this doc and make for interesting reading. No indication why the OFPP felt it necessary to resubmit this proposal for public comment again, but this is your opportunity to voice your opinion.
Most likely this rule change will become final. It will place additional burdens on US companies with such contracts and will place these companies at a competitive disadvantage to foreign companies who, even with this change, will still only have to comply with CAS 401 and 402.
Click here for a copy of the Federal Register
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
