February 2017 - page 11

There are many ways to overstate travel costs. Employees can pad their travel claims. They can take unnecessary trips because they like to travel or need to build their airline miles to get preferred boarding and “free” class upgrades, or have other personal reasons. Employees can claim and charge off to the government higher than prescribed lodging and per diem maximums because of poor internal controls or because no one wants to challenge the claim of a person in authority. They can easily game the system requiring lowest available air fares. And so on. Most of these intrusions can be minimized with effective internal control systems. But what if the owners of a company are doing the padding? That’s what a company called Para-Plus Translations was doing. And they got caught. Got turned in by a whistleblower.

Source: PNWC’s Government Contracting Update: How Are Your Internal Controls Over Employee Travel Costs?

Every Government contractor with cost-type contracts is familiar with the requirement at FAR 52.216-7(d)(2)(iii) that requires them to submit an indirect cost rate proposal within six months after their fiscal year ends. This requirement continues for the duration of the contract. That same FAR clause even specifies the elements that comprise an “adequate” indirect cost rate proposal. There are 15 items listed, delineated as (a) through (o). There are also a listing of 15 optional items – also delineated as (a) through (o) – most of which will be N/A (not applicable) to small Government contractors.

Source: PNWC’s Government Contracting Update: DCAA Requests for Extra-Regulatory Data

The Federal Acquisition Regulation (FAR) requires Government officials to evaluate contractor performance in the Contractor Performance Assessment Reporting System (CPARS) (see FAR Part 42.15). CPARS is the Government-wide reporting tool for past performance on contracts. The primary purpose of CPARS is to ensure that current, complete, and accurate information on contractor performance is available for use in procurement source selections. Government officials evaluate contractors in CPARS by preparing a PAR (Performance Assessment Report). PARs are to be prepared at least annually and at the end of the contract.

Source: PNWC’s Government Contracting Update: DoD Fails to Issue Adequate or Timely Appraisals of Contractor Performance