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CPSR 360: Part Two–Newsworthy CPSR Updates

CPSR 360: Two-Part Series – Part Two –Newsworthy CPSR Updates By: Chase Kunk, Vice President, Contracts & Procurement and Michael Carter, Senior Consultant In December 2016, we released CPSR 360: Part One – Insights from Our Recent CPSR Experiences, which outlined several high-risk procurement file documentation areas we continue to see are a challenge for …

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CPSR 360: Part One of a Two-Part Series 

CPSR 360: Two-Part Series  –  Part One – Insights from Our Recent CPSR Experiences Part Two (Coming Soon!) – Other Newsworthy CPSR Updates By: Chase Kunk, Vice President, Contracts & Procurement and Michael Carter, Senior Consultant The Defense Contract Management Agency’s (DCMA) Contractor Purchasing System Review (CPSR) Group continues to remain highly active in their …

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Blended Rates – Accounting Treatment Option for Employee Compensation Costs under Flexibly Priced Government Contracts

Craig Stetson, Director, Capital Edge Consulting The Bipartisan Budget Act of 2013, dated April 7, 2014 implemented a compensation limit of $487,000 applicable to new contracts awarded by all federal agencies on or after June 24, 2014 and subject to Federal Acquisition Regulation (FAR) Subpart 31.2.   The $487,000 limit is applicable to all contractor employees …

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DCMA and DoD Business System Withholds

by Craig Stetson, Director, CPA and Terry A. Carlson, Managing Director,  MBA Summary The Department of Defense Inspector General (DoD-IG) issued earlier this month a second audit report (see report) heavily criticizing and identifying significant deficiencies pertaining to the Defense Contract Management Agency’s (DCMA) business system review and administration processes associated with DoD contractors.  This report …

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DCAA’s View on Expressly Unallowable Cost Audit Guidance

Craig Stetson CPA, CGMA Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting PubKLaw recently met the DCAA Deputy General Counsel and discussed the DCAA’s December and January MRD audit guidance re expressly unallowable costs.  The DCAA comments are a prelude to the upcoming Annual Government Contracts Review and address the objective of …

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DCAA’s New Aggressive Approach to Incurred Cost Submissions 

CAPITAL EDGE CONSULTING NEWSLETTER – EARLY SPRING 2015   The DCAA’s New Aggressive Approach to Overdue Incurred Cost Submission (ICS) by-Norman McCord, CPA, MSA Director, Capital Edge Consulting In a recent Capital Edge “Ask an Expert” series, we noted that the Defense Contract Audit Agency (DCAA) recently issued a Memorandum for Regional Directors (MRD), instructing its staff …

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Business Systems Audits – When the other shoe drops…

Capital Edge Consulting – Late Winter Newsletter Norman McCord, CPA, MSA Director, Capital Edge Consulting Sign up for the CEC Newsletter Series Background and Status The Department of Defense recently withdrew its proposed amendments to the Business Systems rules related to Estimating, Accounting and Material Management and Accounting Systems.  The proposed amendments would have required …

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DCAA Opines on the Identification of “Expressly” Unallowable Costs

In a previous publication, we noted that the DCAA issued guidance1.2, to its auditors to assist in their identification of “expressly unallowable costs.” The apparent intention of the two memoranda is to address cost principles covered in FAR Subpart 31.2, DFARS Part 231 or other Agency Supplements. The identification and elevation of a cost to the “expressly” …

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Contractors’ Purchasing System Review – Five Hot Topics

Contractors’ Purchasing System Review – Five Hot Topics In the simplest of terms, a contractor’s purchasing system review (CPSR) is formal Defense Contract Management Agency (DCMA) review of a contractor’s purchasing system with respect to direct purchases of goods and services under certain FAR Part 15 contracts. DFARS 252.244.7001, Contractor Purchasing System Administration, contains the …

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