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
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.
Click here for a copy of this article
The changing landscape of Government contract compliance
Tuesday, April 20th, 2010
The attached PowerPoint presentation address the many changes in compliance requirement facing government contractors and the potential impact on their business
- High-Visibility Procurement & Audit Issues
- DCAA and Access to Contractor Records
- Proposed DFARS Rule – Withholding Payments to DoD Contractors
- Contractor Business Systems and Internal Controls
- Ensuring a Compliant Cost Accounting System
- Prime Contractor Management of Subcontractors
- Interim Rule to Increase Competition in Major Defense Acquisition Programs (MDAP)
- How to Survive a DCAA Audit
Click here for a copy of the PowerPoint document
