The procurement regulations require large business prime contractors to award subcontracts to small businesses to the maximum extent practical. In fact large business primes must establish small business subcontracting goals and a plan for meeting them prior to the award of a contract that exceeds $650,000. For as long as these regulations have been in place, small businesses have complained that large businesses use them to qualify for the award but never give them the promised work or fail to pay when the work is performed.
In response to these complaints, the Small Business Administration promulgated a new rule designed to ensure that small businesses that help a prime win the contract receive their agreed upon share of the work and are paid accordingly. Initially large business offerors must represent in their proposal that they will in good faith utilize the proposed subcontractors for the work envisioned in the proposal. Prime contractors are also required to
Generally, to be eligible for the domestic production activities deduction (DPAD), a taxpayer must earn gross receipts from a disposition of qualifying production property. This typically involves a sale and delivery of a manufactured product by the taxpayer to a customer. However, the IRS recently ruled that a government contractor made a disposition for DPAD purposes despite the fact that title to the property reverted back to the contractor (Technical Advice Memorandum 201314043, 04/05/2013). The ruling disposition was not requiring
As a follow-up to the L2 Federal Resources webinar on “Attributes of an Adequate Accounting System,” Aronson LLC government contracting specialists Nicole Mitchell and Brian Bender have prepared answers to several attendee questions:
Is my contract covered by the Cost Accounting Standards (CAS), and how do I determine the level of CAS coverage (e.g., Full, Modified, Not CAS Covered)?
Click here to download a flowchart that illustrates the method for determining CAS coverage and whether or not your company should be submitting a Disclosure Statement.
Does my company have a robust set of policies and procedures?
At a minimum, your business should have the following written policies and procedures (P&P) in place prior to DCAA review/audit:
The Federal Acquisition Institute courses and modules available on the Defense Acquisition University’s website provide online anytime training to assist with your understanding of GSA Schedules and offer continuous learning points (CLPs) that may count towards your contracting certification and continuing education.
You’ll learn how to effectively use the GSA Schedules program to meet your requirements, use GSA tools to enhance competition, achieve small business utilization, procure sustainable acquisitions and much more. Most courses require passing a test with a 100% score to earn CLP credits.
GSA Schedules related courses include:
GSA’s Multiple Award Schedules (MAS) webinar for November 2012 is on FAR Subpart 8.4 (Federal Supply Schedules) vs FAR Part 13 and FAR Part 15 (Open Market / Contracting by Negotiation). GSA offers a mixture of scheduled webinar, online anytime, and in-person training to help Schedule contractors effectively use the Schedules program to best achieve desired goals. After the webinar you should be able to: