July 2016 - page 11

A little over a year ago, DoD, GSA, and NASA (the FAR Councils) published a proposed FAR rule to implement small business subcontracting improvements among Government contractors. A number of commentators provided written comments and suggestions to the proposed regulations, most of them positive. Yesterday, the FAR Council’s made it formal by publishing the rules in final form.

Source: PNWC’s Government Contracting Update: New FAR Rules for Small Business Subcontracting Plans

Prospective Government contractors often panic when they hear the term “CAS” (Cost Accounting Standards). CAS has a reputation of adding onerous layers of regulations to an already overloaded regulatory system for Government contractors. Yet, with many exemptions from CAS available – the small business exemption being the most significant – very few contractors will ever need to concern themselves with Cost Accounting Standards.

Source: PNWC’s Government Contracting Update: Only 1 Percent of Government Contractors are CAS-Covered

Back in April, we published a four-part series on the use of blended labor rates to implement the new $487 thousand compensation cap that applies to all employees charging to Government contracts awarded after June 24, 2014. For a comprehensive look at the blending methodology, refer to that series Part 1, Part 2, Part 3, and Part 4. The Department of Defense came up with the blending methodology as a means of streamlining implementation of the lowered compensation cap while there is a mix of contracts under the old and the new caps. As a prerequisite to using a blended approach, a contractor must enter into an advance agreement with the ACO (Administrative Contracting Officer). The advance agreement includes detailed methodologies to calculate blended rates – which differ for incurred cost proposals and for forward pricing proposals.

Source: PNWC’s Government Contracting Update: Incurred Cost Submissions using Blended Rates but No Advance Agreement Will Get Bounced