Jeffery Trammell

Big Kudos to Defense Contract Audit Agency #DCAA Strategic Recruiters! Office of the Under Secretary of Defense Comptroller / CFO released the #DoD #FM Community Workforce Plan 2023 Year in Review. https://lnkd.in/eFsT-HkQ "DCAA implemented an aggressive on campus recruiting effort, temporarily assigning field auditors as recruiters to participate in a new outreach and recruiting program..." See more on page 9 in the Year in Review, linked above. I want to especially recognize Patrick Grimes and Ann Parker for leading this effort and Lori Tucker for being instrumental to ensuring implementation. Please tag our strategic recruiters in the comments, and anyone I left out. To learn more about careers at DCAA, see https://lnkd.in/eJrniuEy .

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CLIENT ALERT: On June 7, 2024, the Defense Contract Audit Agency (DCAA) released its Report to Congress for Fiscal Year (FY) 2023. Consistent with previous years, the report provides a comprehensive analysis of the Agency's audit performance, recommendations for enhancing audit processes, highlighted industry outreach activities, and key accomplishments. As noted in the report, DCAA questioned $5.4 billion of the $254 billion of reviewed contract costs; resulting in net savings to DoD and Taxpayers of $3.5b. Savings represent a $5.10 to $1.00 return on investment (ROI). FY2023 results are comparable to FY2022 when adjusted for the recent Booz Allen false claims settlement of $377 million. Related to their audit findings, DCAA notes an ICS sustention rate of 31.9% in 2023. While still relatively low, the sustention rate is an increase from the FY2022 rate of 26.2%. As with previous years, ROI varies significantly between contract types. For example, ROI for forward pricing audits was $17.4:1, while ROI for systems, CAS, and TINA audits was $0.30:1. The high ROI associated with forward pricing is not surprising (nor are the significant audit findings) given the nature of the materials audited. Forward pricing audits are concerned with estimates and while often supported by historical experience, the related estimates are just that… estimates based on a combination of cost history and assumptions. Similarly, the ROI regarding Systems, CAS, and TINA isn’t surprising as the audits are more concerned with compliance rather than cost allowability, and require significantly more time to complete. Other items of note highlighted in the report include: - Process revisions for mandatory annual audit requirements (MAAR ), including MAAR 6 (Labor Floor Checks) and MAAR 13 (Material Consumption) audits. - No longer a “mandatory”, annual requirement - Audit performance will be based on risk assessments - Continued discussions and communications with industry regarding DCAA guidance related to Cost Impacts for Unilateral Cost Accounting Practice changes (MRD 23-PAC-009(R). Notably, the National Defense Industrial Association and Aerospace Industries Association both object to some of DCAA’s issued guidance - Continued Small Business outreach, including additional staff allocations to help small businesses understand the contract requirements and complexities of government contracting and related regulations - Overall staffing remains unchanged from FY2022 to 2023. However, the bulk of hiring has focused on new college graduates (550 heads). Left unsaid is the loss of experienced auditors and the overall impact to DCAA��s mission Access the entire Report to Congress on FY 2023 Activities by the Defense Contract Audit Agency: https://lnkd.in/ecP7vmWV Read the entire article by Capital Edge Consulting Director, Eric Hayman here: https://lnkd.in/eETFYpgq #GovCon #RegulatoryUpdates #DCAA

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On May 24, 2024, GAO released a Contract Financing report entitled Factors That Influence the Use of Financing Methods and DoD's Progress on Proposed Actions. The May 24th report presents the results of DoD's assessment of the extent to which DoD had implemented proposed actions emanating from its April 2023 Contract Finance study. Specifically, the GAO report found that DoD had begun addressing most of the 16 proposed actions from the April 2023 study, but most of the actions will take 1-3 years to complete. Below is a brief summary of the current status of each of the 16 proposed actions: 1) Category 1 - Completed actions a) Retain existing profit approach (no adjustment to weighted guidelines methodology) b) Retain policy that interest related to financing is unallowable c) Return to customary progress payment rate of 80% for large businesses d) Retain the 95% progress payment rate for small businesses 2) Category 2 - Ongoing actions a) New DoD Contract Cash Flow Model b) Improve ability of subcontractors to contact the contracting officer when there are delays in payment from the prime contractor c) Implement faster payments to subcontractors from prime contractors d) Modify regulations to improve timely payments to subcontractors from prime contractors e) Pilot new form of contract financing to meet needs of small businesses f) Consider other payment protections for subcontractors g) Educate acquisition workforce on cash flow h) Study cost and effectiveness of performance-based payments i) Extent the prime contractor benefit of Prompt Payment (30 days) to subcontractors 3) Category 3 - "Not started" actions a) Educate businesses and DoD stakeholders on accounting system requirements b) Explore "higher-than-customary" progress payment rate to motivate / reward large businesses c) Improve subcontract payment oversight #governmentcontracts #governmentcontracting #governmentcontractors

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If you have not yet picked up a copy of Marsha Lindquist’s #1 best-selling book, Secrets of Strategic Pricing for Government Contractors join thousands of Gov Con avid readers in celebrating the first anniversary of the book’s launch. As Josh Frank of RSM Federal says in the foreword: “This is the type of book that you will refer to over and over again and each time you pick it up you will learn something new. Imagine being in business for ten years. How many times have you said, “I really wish I had been aware of this business strategy when I first started the company.” https://lnkd.in/gRHFb2tV #StrategicPricing #GovCon #PricingStrategies

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A quick recap of Q1 earnings season for the government contracting ecosystem as we prepare for Q2. Brad Sawyer and I highlight quite a bit here. Generally speaking, it is a high stakes and complex world out there. Have a wonderful 4th! #govcon #governmentcontracting #defense https://rsm.buzz/3W72lwj

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Cara Wulf and Marcos Gonzalez breakdown the changes in the DOD Final Rule amending the DFARS Buy American requirements and explain what contractors should be aware of when supplying “domestic end products” to the government. Read more: https://lnkd.in/gV6Q9JDk #governmentcontracts #DOD #DFARS #buyamerican

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On April 25, 2024, DoD issued a final rule to amend the DFARS to implement Section 808 of the FY 2023 National Defense Authorization Act. The April 25 final rule, which follows a September 29, 2023 proposed rule, limits the number of low-rate initial production (LRIP) lots associated with a major defense acquisition program. Specifically, a contracting officer shall not procure more than one lot for LRIP associated with a major defense acquisition program if a fixed-price contract is authorized at the time of Milestone B approval and the scope of work of the fixed-price contract includes both the development and LRIP of items for such major defense acquisition program. A waiver may be granted subject to certain limitations within FAR 234.004 Acquisition Strategy. The effective date of the final rule is April 25, 2024. #governmentcontracts #governmentcontractors #governmentcontracting https://bit.ly/4bbPca1

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Read our most recent blog post (link in comments) to find out what the Five Things to Know About NSPA's Contracting Process are. Contact Jim Shields (jim@pts.careers) to learn more about how we can help you succeed in the NATO market.

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📢 Important Announcement from the DoD: Defense Federal Acquisition Regulation Supplement: Procurement Technical Assistance Program (DFARS Case 2024-D006) 📢 The #DepartmentofDefense is proposing amendments to the Defense Federal Acquisition Regulation Supplement. This update aims to implement a section of the National Defense Authorization Act for Fiscal Year 2024, modifying certain definitions associated with the Procurement Technical Assistance Program. 🗓️ Key Date: Submit your comments on the proposed rule in writing by July 29, 2024. 🔗 https://buff.ly/456HCM8 #DoD #DFARS #Procurement #NationalDefense #PublicComments #DONOSBP #Navy #MarineCorps

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Are you prepared to show auditors how you comply with Whistleblower Protection Rights? New emphasis will be placed on contractors to show how they comply. Check out our blog on the topic and how to prepare.

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On May 30, 2024, DoD issued a final rule to amend the DFARS to clarify "the data to be provided for certain procurements related to major weapons systems." The final rule follows a December 22, 2023 proposed rule and implements Section 803 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2023. It includes additional guidance for data required to be submitted to support commerciality and price reasonableness determinations for the acquisition of major weapons systems. The final rule enables the contractor to either submit or provide the contracting officer access to such data. Notably, and in alignment with Section 803 of the FY 2023 NDAA, the final rule outlines the following requirements that an offeror must follow for weapons systems proposed as commercial that have not previously been determined to be commercial. 1) Identify the comparable commercial product that it sells to the public 2) Provide a comparison of the physical characteristics and functionality of the comparable commercial product and the subsystem, component, or spare part 3) Provide the national stock number for the comparable commercial products and for the subsystem, component, or spare part If the offeror does not sell a comparable product, the offeror must notify the contracting officer in writing and provide a "comparison between the physical characteristics and functionality of the most comparable commercial product in the commercial market and the subsystem, component, or spare part, if available." Regarding price reasonableness, the final rule allows the contractor to provide a representative sample of prices paid under similar terms and conditions. If the contractor cannot provide such data, the contracting officer shall request a representative sample of prices paid for the same or similar commercial products under comparable terms and conditions. To the extent that the contracting officer determines that the sales data provided is insufficient to establish price reasonableness, or the sales data indicates that the price is not reasonable, the contracting officer shall seek approval to obtain data other than certified cost or pricing data. The final rule was effective May 30, 2024. #governmentcontracts #governmentcontractors #governmentcontracting

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A lot of great info on audit readiness and sundowning of legacy systems. Legacy systems are redundant, very costly to maintain and just isn’t adaptable to our needs now for audit.

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Read Guidehouse Defense and Security's new article, Managing Change Fatigue in the Federal Workforce, outlining our team's recommendations for agencies looking to produce better outcomes in the face of complex workforce challenges: https://lnkd.in/ep3bnyPS.

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The GovCon Index broke its downward trend by securing a weekly gain, overcoming potential losses. Learn more about this positive shift in the industry here: https://okt.to/fjwm1E. #GovCon #IndustryTrends #Finance

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Greetings all. Cool story, I've been cited in a DefenseScoop article (Deb Karagosian). I think this is the first time since being published. I also think it is critical to continue to foster scholarly debate of tough topics through these esteemed journals. I would like to both thank Mr Long and MAJ Pytlar for putting in the effort (it is substantial) and congratulate both for getting published - although I disagree with the article. What say you? #Cyber #CyberSecurity #NationalSecurity #NationalSecurityStrategy #USCyberForce #USCF

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