New DCAA Focus Areas – Questioned Costs
Thursday, November 3rd, 2011
More examples of how DCAA is interpreting the FAR for the purpose of finding more areas in which cost can be disallowed. Companies must prepare themselves for a more aggressive DCAA.
Click here for a copy of the article
CAS exemption for contracts performed outside the US no longer applies
Wednesday, August 10th, 2011
You will remember that a few months back I sent out a news alert about a proposed rule to remove the exemption from CAS for contracts performed outside the US. The proposal rule is not finalized.
Performing a contract entirely outside the US no longer exempts the contract for CAS coverage if under normal circumstance the contract would be CAS qualified.
Click here for the Feg Reg publication of the final rule
Determining Manufacturing Readiness Risk as part of the Source Selection process
Monday, August 1st, 2011
DFARS (DFARS Case 2011-D031) is proposing that as part of the source selection process, manufacturing readiness and manufacturing-readiness processes of potential contractors and subcontractors, be considered for major defense acquisition programs (MDAP).
Of course nothing in the proposed rule, as described in the Federal Register, defines what manufacturing readiness and processes are and how that will be measured/determined during the source selection process.
Most likely DoD is floating this rule out there to get major manufactures input, through their comments, on how this would work, and what the parameters should be.
While most major prime contractors would be able to address this potential issue, it is the subcontractors on such MDAP that need to be concerned about the proposed rule. Because it would not be the CO obtaining this information during the source selection process, but the prime obtaining the information from prospective subcontractors. This could expose the subcontractors intellectual property as it relates to its manufacturing processes, to the prime.
This could put the subcontractor at a significant negotiating disadvantage with the prime. Another area, from this administration, in a long line of new risks being faced by subcontractors.
Tim Di Guiseppe
Click here for a copy of the Federal Register and info on where to submit comments
