Cherry Bekaert: Government Contractors Guidance

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In this episode of Cherry Bekaert’s GovCon podcast, Neal Beggan is joined by cybersecurity professionals Steven Ursillo and Brian Kirk for a comprehensive deep dive into the current state of Cybersecurity Maturity Model Certification (CMMC) compliance.

They discuss how 48 CFR will reshape the enforcement of cybersecurity requirements in government contracts. This episode breaks down what the 48 CFR rule means, how it connects to DFARS and 32 CFR, and what contractors should be doing now to stay ahead of the rollout.

Listen to learn more about:

The definition of CMMC and why it matters
An overview of CFR 48
CFR 48 timeline and rollout
Potential readiness and compliance challenges and how to overcome them
Action items to prepare for CFR 48

The conversation includes:

0:37 – Introduction to CMMC: What It Is and Why It Matters
4:32 – Finalization of the 48 CFR Rule
12:50 – Challenges, Obstacles & Pain Points in Readiness and Certification
27:16 – Operational Challenges, GRC Tools and Assessment Readiness Tips
32:19 – Ecosystem Growth & Capacity
35:22 – Key Takeaways & Action Items
37:42 – Upcoming Events & Learning Opportunities

POCs

Steve Ursillo, Partner

Brian Kirk, Senior Manager

Related Insights:

Article | DoD CMMC Requirements: A Guide for Defense Contractors
Article | Cybersecurity Maturity Model Certification (CMMC): Compliance Process & FAQs

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In this episode of Cherry Bekaert’s GovCon Podcast, Advisory Managing Director Michael Cippel and Senior Audit Manager Sarah Tucker explore the foundational principles and nuanced challenges of joint ventures (JVs) within the government contracting sector.

Tune in to learn about:

► Definition and Structure of JVs

► Strategic Benefits of JVs

► Types of JVs

► Pros and Cons of JVs

► Role of the Small Business Administration’s (SBA) Mentor-Protégé Program

► Accounting for JVs

► How Cherry Bekaert can assist with JV setup, tax structuring, accounting systems and ongoing compliance

Whether you're exploring a JV for the first time or looking to refine your current structure, Cherry Bekaert professionals are here to help. Let our team support you in building a tailored JV that’s not only compliant but strategically sound.

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In this episode of Cherry Bekaert’s Government Contracting podcast, host Jonathan Reid, Director, is joined by Mike Cippel, Managing Director, to discuss the job differences between accounting managers, controllers and chief financial officers (CFO).

Tune in to learn more about:

The definition of an accounting manager, controller and CFO
Key differences between the three rolls
Responsibilities expected in these roles
Requirement to hold the positions
What type of work environment to expect
Skills needed to succeed in each role

Cherry Bekaert’s team of government contracting consultants has significant experience in outsourced accounting solutions. Our professionals provide regular updates, thought leadership, current and future state consulting, change management advisory and ready to stand up services. If you have any questions specific to your situation, our government contracting and tax consultants are here to discuss solutions tailored to you. Contact us.

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As of Monday, January 28, President Donald Trump has signed various executive orders requiring the halt of federal funding for various programs. This will allow the administration to determine the program’s alignment with legal and presidential priorities.

These orders impact funding for foreign aid, non-governmental organizations, diversity, equity and inclusion (DEI) programs, gender ideology, Green New Deal initiatives, as well as funding under the Inflation Reduction Act (IRA) and Infrastructure Investment and Jobs Act (IIJA) programs.

Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s Government Contracting practice who spent 13+ years with DCAA, to discuss what this means for government contractors moving forward.

Listen to learn more about:

What it means when an organization receives a stop work order
How to understand the terms and conditions of the contract or award
When to reach out to your contracting officer
The flow down of responsibilities for prime contractors vs. subcontractors when receiving a stop-work order or a termination of contract
The importance of documenting all costs and expenses
The differences between terminations of fixed price and cost-plus contracts or awards
Strategies to control and mitigate costs
Steps you can take to help minimize the settlement process timeline
Ways to maximize cost recovery during settlement or negotiations

Cherry Bekaert’s team of government contracting professionals has significant experience with the complexities and challenges of navigating these types of executive orders. If you have any questions specific to your situation, our government contracting consultants are available to discuss your situation with you.

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In this episode of Cherry Bekaert’s Government Contracting podcast, we discuss what to consider when planning the cost of a project. Eric Poppe, a Managing Director in the Government Contracting Industry practice, is joined by Jonathan Reid, a Director in Outsourced Accounting Services.

Tune in to learn more about:

What to expect when reporting cost
Impact revenue recognition on the cost of a project
Tax impacts
Financial reporting considerations
Compliance requirements
Setting up a project for joint venture
Companies who aren’t in government but work with Government Contractors

Cherry Bekaert’s team of government contracting professionals have significant experience in accounting and reporting. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored for you. Contact us.

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In this episode of Cherry Bekaert’s Government Contracting podcast, host Jeff Annessa, a Senior Manager in the Firm’s Government Contracting practice, is joined by Jade Casey, a director in the Firm’s Government Contracting Services group. Jeff spent more than 13 years working with the Defense Contract Audit Agency (DCAA) and brings valuable experience to their discussion on forward pricing rates and their benefits.

Tune in to learn more about:

An overview of forward pricing rates
How forward pricing rates differ from provisional billing rates
The forward pricing rates proposal process
Difference between a recommendation (FPRR) and an agreement (FPRA)
The forward pricing rate proposal adequacy checklist for contractors
Benefits of sound forward pricing rates

Cherry Bekaert’s team of government contracting professionals have significant experience in forward pricing rates. As more guidance comes forth, we are here to provide regular updates, and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored for you. Contact us.

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In this episode of Cherry Bekaert’s Government Contracting podcast, Romain Robveille, Advisory Services Director, is joined by Justin Pell, Senior Manager, for an overview of the Deltek Costpoint software and how to get the most out of this system.

Tune in to learn more about:

Effective uses of Deltek Costpoint for businesses
Issues with current Costpoint uses and leadership challenges
How changes in leadership can affect system and accounting efficiencies
Areas companies need to consider to make the most of Deltek Costpoint
Benefits of a system assessment for organizations using Deltek Costpoint

Cherry Bekaert’s team of government contracting professionals have significant experience with Deltek Costpoint. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored for you. Contact us.

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In this episode of Cherry Bekaert’s Government Contracting podcast, host Brendan Halloran, a Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s Government Contracting practice. Bringing extensive knowledge and experience in the government contracting space, Brendan and Jeff discuss the Truthful Cost or Pricing Data Act, formerly known as the Truth in Negotiations Act or TINA.

Brendan was previously a divisional administrative contracting officer (DACO) at the Defense Contract Management Agency (DCMA) and Jeff has spent over 13 years with the Defense Contract Audit Agency (DCAA), while holding several leadership positions.

Tune in to find out more about:

The background and history of the Truthful Cost or Pricing Act
What is considered cost or pricing data
Most common thresholds and exceptions to the act
The certification, sweep and disclosure process
Defective pricing and government audits
Best practices surrounding the Truthful Cost or Pricing Act

Cherry Bekaert’s team of government contracting consultants have significant experience and can help your growing government contracting business navigate the Truthful Cost or Pricing Data Act. If you have any questions specific to your situation, our consultants are available to discuss your situation with you. Contact us today.

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In this episode of Cherry Bekaert’s Government Contracting podcast, host and Advisory Services Manager Shaydah Naraghi is joined by Advisory Services Senior Manager Christine DeYuliis to discuss how Unanet could help guide your business forward.

Tune in to learn more about:

How Unanet got its name
How long it typically takes employees to adopt time and expense functionality in Unanet
The recommended company size needed to utilize Unanet
How Unanet supports growth in a company
How Unanet supports DCAA and FAR compliance
The ease of standard and analytics reporting
Additional resources available during and after implementation

Cherry Bekaert’s team of government contracting professionals has significant knowledge and experience with Unanet. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored to you.

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In this episode of Cherry Bekaert’s Government Contracting podcast, host and Government Contractor Services Director Brendan Halloran leverages his extensive knowledge and experience in the government contracting space. With a background as a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), Brendon offers valuable insights alongside Advisory Services Director Lynnette Leidwinger. Together, they discuss how subcontractor administration can be beneficial to a company’s success.

Tune in to find out about:

The definition of
- Subcontracting
- Flow downs
- Teaming arrangements
- Compliance considerations
The importance of flow-down clauses
How teaming arrangements can be a good tool for contractors
Compliance considerations
Circumstances in which a contractor’s compliance gets reviewed
Key takeaways for hiring a subcontractor

Cherry Bekaert’s team of government contracting consultants have significant experience in subcontracting administration and can help your growing government contracting business navigate the challenges. If you have any questions specific to your situation, our consultants are available to discuss your situation with you.

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In this episode of Cherry Bekaert’s Government Contracting podcast, Mike Cippel, a Managing Director in the Firm’s Outsourced Accounting Advisory practice, is joined by Irwin Kaplan, Director, to discuss how government contractors can begin to plan for next year. They cover the ideal timeframe for contractors to start preparing, as well as key planning considerations.

Tune in to learn more about vital elements of year-end planning, including:

Budgeting
Contract Waterfall
Cash Forecasting
Key Measures: Monthly Tracking and Reporting

Cherry Bekaert’s team of government contracting professionals have significant experience with next-year and year-end planning for government contractors. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored to you. Contact us.

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In this episode of Cherry Bekaert’s Government Contracting podcast, we discuss the do’s, don’ts and pitfalls of outsourced accounting. Host Eric Poppe, a Managing Director in the Government Contracting Industry practice, is joined by Jonathan Reid, a Director in Outsourced Accounting Services.

Tune in to learn more about:

How outsourced accounting helps government contractors
Differences between bookkeeping and outsourced accounting
Situations in which government contractors need accounting help
How to make a smooth transition into outsourcing accounting needs
Tips for forming a positive relationship with an outsourcing firm
Pitfalls a company should avoid before getting into an outsourcing relationship
Questions you should ask during the interview process

Cherry Bekaert’s team of government contracting professionals have significant experience in outsourced accounting. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored for you. Contact us.

Related Guidance

Podcast: How to Get the Most Out of Your Outsourcing Firm
Article: Outsourced Accounting Frequently Asked Questions (FAQs)

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In this episode of Cherry Bekaert’s Government Contracting podcast, we discuss how to choose the right Enterprise Resource Planning (ERP) system that fits your company’s unique needs. Host Eric Poppe, a Managing Director in the Government Contracting Industry practice, is joined by Christine DeYuliis, a Senior Manager.

Tune in to learn more about steps your business can take to find the right ERP, including:

Conducting an initial discussion with stakeholders
Defining and documenting current business processes, strengths and pain points
Determining required features and functions
Identifying needed software integrations
Integrating accounting and reporting considerations
Considering compliance requirements

Cherry Bekaert’s team of government contracting professionals have significant experience in ERP solutions. As more guidance comes forth, we are here to provide regular updates and thought leadership to guide your journey forward. If you have any questions specific to your situation, Cherry Bekaert is here to discuss solutions tailored for you. Contact us.

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In this episode of Cherry Bekaert’s Government Contracting podcast, we discuss ways to optimize the benefits of outsourcing your accounting operations. Host Craig Hunter, a Director in the Government Contracting Industry practice, is joined by Mike Cippel, Managing Director, and Directors Irwin Kaplin and Jonathan Reid.

Tune in to learn more about:

Deciding if outsourced accounting is your best option
Uncovering the benefits of using an outsourcing firm
Optimizing the working relationship with an outsourcing firm

Cherry Bekaert’s team of government contracting consultants have significant experience in outsourced accounting solutions. As more guidance comes forth, we are here to provide regular updates, thought leadership, current and future state consulting, change management advisory and ready to stand up services. If you have any questions specific to your situation, our government contracting and tax consultants are here to discuss solutions tailored for you.

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In the fourth episode of Cherry Bekaert’s Cost Accounting Standards (CAS) podcast series, Brendan Halloran, a Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s Government Contracting practice. Bringing extensive knowledge and experience in the government contracting space, Brendan and Jeff discuss cost impacts, as well as the differences between General Dollar Magnitude (GDM) and Detailed Cost Impacts (DCI).

Brendan was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA) and Jeff has spent over 13 years with the Defense Contract Audit Agency (DCAA), while also holding positions such as quality manager, supervisory auditor and field audit office manager.

Tune in to find out more about:
What cost impacts are
When cost impact proposals are necessary
Different types of cost impact proposals
A detailed overview of GDM and DCI
Cost Impact Materiality
How to position the cost impact

Cherry Bekaert’s team of government contracting consultants have significant CAS experience and can help your growing government contracting business navigate CAS. If you have any questions specific to your situation, our consultants are available to discuss your situation with you. Contact us today.

If you haven’t already, catch up on other parts of the series :

Cost Accounting Systems Series: Part 1 – A Comprehensive Overview
Cost Accounting Systems Series: Part 2 – Considerations for Growing a GovCon
Cost Accounting Systems Series: Part 3 – Implications When Acquiring Companies

Related Guidance

Webinar Recording: Cost Accounting Standards (CAS): Part 1 – CAS Coverage Types, Common Standards, and CAS Applicability
Webinar Recording: Cost Accounting Standards (CAS): Part 2 – Cost Accounting Changes and Impact

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In the second episode of Cherry Bekaert’s Operational Effectiveness podcast series, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Todd Angioli, a Director in the Firm’s Government Contracting practice with 20+ years of financial operations experience.

Together, Eric and Todd discuss mid-year considerations when budgeting and forecasting.

Listen to this episode to find out more about:

What government contractors should consider at the mid-year point when forecasting for the remainder of the calendar year
High-level considerations when reforecasting the operating plan:
- Revenue
- Direct Labor
- Fringe
- Overhead
- General and Administrative Expenses (G&A)
- Bottom Line
Key forecasting and planning areas:
- Recompete andNew Business
- Current Execution
- Improvement Initiatives
- Need Assessment for Mid-Year Burden Recalculation
- The Need to Move Investments
- Other Course Corrections
What growing government contractors should be doing at the mid-year point

Cherry Bekaert’s team of government contracting consultants have significant operations and contracting experience to help you navigate any operational considerations. If you have any questions specific to your situation, our government contracting consultants are available to discuss your situation with you.

If you haven’t already, catch up on part one of the budgeting considerations series:

Effective Operational & Financial Performance: Budget Considerations During Year-End

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In this episode of Cherry Bekaert’s GovCon Podcast host Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Vivian Kohrs, Director, Strategic Tax, and Bryan Weems, Senior Manager, Tax Credits and Incentives. Together they give an overview of research and development (R&D) credits for government contractors.

Listen to learn about:

What R&D credits are
Who is able to take advantage of these credits
Contract R&D Credits
- Rights and risks
- How subcontractors could potentially qualify
R&D credits by state:
- Virginia
- Georgia
- Texas
- Maryland
- Florida
Section 174 impact to tax liability and cashflow
Recommendations on how to collect R&D Credits and prepare for the potential impact of Section 174 capitalization

Cherry Bekaert’s team of government contracting and tax credit and incentives consultants have significant experience in R&D credits and Section 174 analysis. If you have any questions specific to your situation, our government contracting and tax consultants are available to discuss your situation with you. Contact us.

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In this episode of Cherry Bekaert’s GovCon Podcast, Brynn McNeil and Craig Hunter both Assurance Partners in Cherry Bekaert’s Government Contracting Industry practice, discuss revenue recognition for government contractors. Listen to learn more about:

The five steps for recognizing revenue under Accounting Standards Codification (ASC) 606
Understanding how costs drive revenue
Common errors in recording revenue
Best practices for government contractors regarding processes and controls for recording revenue

Cherry Bekaert’s team of government contracting consultants have significant experience in navigating the SBA 8(a) business development program and can assist your business with the best accounting practices. If you have any questions specific to your situation, our government contracting consultants are available to discuss your situation with you. Contact us.

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In the third episode of Cherry Bekaert’s Cost Accounting Standards (CAS) podcast series, Brendan Halloran, a Director with Cherry Bekaert Advisory, is joined by Jeffery Annessa, a Senior Manager in Cherry Bekaert’s Government Contractor Industry practice, to discuss CAS implications during mergers and acquisitions.

Cherry Bekaert’s government contracting consulting team has years of CAS experience and can help you navigate CAS compliance issues or disclosure statement development.

This episode highlights key topics to help guide your business forward, including:

Scenarios and implications to CAS when:
- A CAS-covered company acquires a company that is non-CAS covered
- A non-CAS covered company acquires a company with CAS coverage
The two most common approaches on how to treat the company you are acquiring, specifically:
- A legal entity dissolved and integrated fully
- A legal entity being maintained as a wholly owned subsidiary
Understanding CAS structure as it relates to the company
Steps to consider when merging with or acquiring a company
Common areas that do not constitute a cost accounting practice change
Impacts and considerations when the acquired company is CAS covered
Areas a CAS-covered company should focus their attention on when acquiring, including:
- Transitional accounting period
- Indirect rate structure
- Similarity of labor
- Allocations
- Restructuring cost
- Pitfalls to avoid
Areas a non-CAS covered company should focus their attention on when acquiring, such as:
- Analysis of the CAS-covered contracts to understand period of performance, numbers and money magnitude
- Additional exposure
- Compliance requirements

If you haven’t already, catch up on part one and two of the series:

Cost Accounting Systems Series: Part 1 – An Overview
Cost Accounting Systems Series: Part 2 – Growing a GovCon

Related Guidance

Webinar Recording: Cost Accounting Standards (CAS): Part 1 – CAS Coverage Types, Common Standards, and CAS Applicability
Webinar Recording: Cost Accounting Standards (CAS): Part 2 – Cost Accounting Changes and Impact

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On December 26, 2023, the proposed rule for the Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC) Program was published in the Federal Register.

Listen to Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contractor Industry practice and Brian Kirk, Senior Manager in the Firm’s Information Assurance & Cybersecurity practice, as they share insights into the proposed rule, including the surprises that came out and DoD’s timing for implementation.

Refresher on CMMC Level 1 Self-Assessment, CMMC Level 2 Self-Assessment + CMMC Third-Party Assessment Organization (C3PAO) Assessment, and CMMC Level 3 Government-Led Assessment
Equivalency: Cloud Service Provider (CSP) and External Service Provider (ESP)
Phased Implementation (DoD rollout in solicitations)
Final Certification vs. Conditional Certification
CMMC Level 3 requires a CMMC Level 2 Final Certification
Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) High conversion to CMMC Level 2 Final Certification for perfect scores
Cost Considerations

How do I prepare for CMMC certification?

If you have any questions regarding CMMC, Cherry Bekaert’s Information Assurance & Cybersecurity and Government Contracting advisors are available to discuss your situation with you.

Cherry Bekaert is an authorized CMMC Third-Party Assessment Organization (C3PAO) by the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, Inc. (The Cyber AB). We assist Organization’s Seeking Certification (OSCs) with CMMC readiness assessments for Levels 1, 2 and 3. Additionally, as an authorized C3PAO, Cherry Bekaert partners with the Defense Contractor Management Agency (DCMA) Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) under their Joint Surveillance audit program to perform DIBCAC High (NIST 800-171) Assessments which are convertible to CMMC Level 2 Certification, if a perfect score is obtained.

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In this episode of Cherry Bekaert’s GovCon Podcast series on the Small Business Administration’s (SBA) 8(a) Business Development Program, Brynn McNeil and Craig Hunter, assurance partners in Cherry Bekaert’s Government Contracting Industry practice, discuss accounting best practices for 8(a) companies. Listen to find out about:

Setting up an accounting system to segregate costs
- Chart of Accounts
- Indirect rates
Reporting functionality for:
- Contract revenue summary by contract
- Showing cumulative revenue
- Annual revenue
- Direct costs
Importance of month end reconciliations of balance sheet account
Recent accounting pronouncements that impact accounting
- ASC 505
- ASC 842
What to consider when selecting an accounting system
Accounting department general housekeeping best practices

Cherry Bekaert’s team of government contracting consultants have extensive experience in navigating the SBA 8(a) Business Development Program and can assist your business with accounting best practices. If you have any questions specific to your situation, our GovCon consultants are available to discuss your situation with you. Contact us.

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
The SBA 8(a) Business Development Program Application Process and Requirements
What Are the Compliance Requirements for 8(a) Certified Companies?
Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Winning an 8(a) Competitive Contract
Small Business Administration (SBA) Mentor-Protégé Program
SBA Mentor-Protégé & Joint Venture Arrangements – Important Elements of the Agreement
The lifecycle of an 8(a) Company
OIG Report: SBA’s Business Development Assistance to 8(a) Program Participants
Contract Performance After the SBA 8(a) Business Development Program

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In the first episode of a new series on effective operational and financial performance for government contractors, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Todd Angioli, a Director in the Firm’s GovCon practice with 20+ years of financial operations experience, to discuss considerations when budgeting for year end. Listen to this episode to find out more about:

What government contractors should consider during year end and while budgeting for the next calendar year
High-level considerations when reviewing the operating plan:
- Revenue
- Direct Labor
- Fringe
- Overhead
- General and Administrative Expenses (G&A)
- Bottom Line
Key budget planning areas:
- Recompete/New Business
- Resources
What growing government contractors should be doing at year end

Cherry Bekaert’s team of government contracting consultants have significant operations and finance experience. If you have any questions specific to your situation, our GovCon consultants are available to discuss your situation with you. Contact us.

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In the second episode of Cherry Bekaert’s Cost Accounting Standards (CAS) podcast series, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s GovCon practice who spent 13+ years with DCAA and held various positions such as Quality Manager, Supervisory Auditor, Field Audit Office Manager, and Artan Ivezaj, a manager in Cherry Bekaert’s GovCon practice with 15 years of experience at the DCAA, to discuss CAS considerations for a growing GovCon. Listen to this the episode to find out more about:

When a company should start thinking about CAS
The difference between full and modified CAS coverage
Explanation of the fundamental requirements of CAS 401 and 402
- CAS 401: Consistency in Estimating, Accumulating, and Reporting Costs
- CAS 402: Consistency in Allocating Costs Incurred for the Same Purpose
The commonality of Federal Acquisition Regulation (FAR) Cost Principles, Approved Accounting System, and CAS
Being aware of CAS 405 and 406
- CAS 405: Approved accounting system requires the system to ensure unallowable costs are reviewed and removed from government billings
- CAS 406: Cost Accounting Period
Important notes about CAS Coverage and the applicability towards subcontracts
Disclosure Agreement as it pertains to CAS

Cherry Bekaert’s team of government contracting consultants have significant CAS experience and can help your growing government contracting business navigate CAS. If you have any questions specific to your situation, our GovCon consultants are available to discuss your situation with you. Contact us.

If you haven’t already, catch up on Part 1 of the series:

Cost Accounting Systems Series: Part 1 – An Overview

Related Guidance

Webinar Recording: Cost Accounting Standards (CAS): Part 1 – CAS Coverage Types, Common Standards, and CAS Applicability
Webinar Recording: Cost Accounting Standards (CAS): Part 2 – Cost Accounting Changes and Impact

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Cost Accounting Standards (CAS) are 19 standards and rules promulgated by 41 U.S.C. 422. These standards impact emerging small and large businesses alike. They are designed to achieve uniformity and consistency in cost accounting practices and to improve the accuracy of cost data by ensuring its basis on consistent definitions and principles.

Ultimately, the Federal government wants a reliable basis for cost comparison and decision making. This allows them to be able to compare proposals from contractor to contractor and from a single contractor year-over-year.

In this new Cherry Bekaert GovCon Podcast CAS series, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s GovCon practice who spent 13+ years with DCAA holding positions such as Quality Manager, Supervisory Auditor and Field Audit Office Manager, to give an overview of CAS. Listen to find out:

An overview of CAS
The differences between the Federal Acquisition Regulation (FAR) and CAS
What the standards consist of, including the four main categories
When CAS comes into consideration as it pertains to government contracting
When CAS would apply to a contract and if there are certain dollar thresholds
The current exemptions, differences in full and modified CAS coverage and application
Overview of the disclosure statement requirement
Why contractors should consider completing a disclosure statement prior to being CAS- covered
Who is responsible in administering CAS and making the required determinations and findings
The benefits of abiding by CAS
Pitfalls and compliance considerations for changes in accounting practices, M&A activity and budgeting/forecasting

Cherry Bekaert’s Government Contractor Industry practice has significant CAS experience and can help you navigate CAS compliance issues or disclosure statement development. Contact us to discuss your situation.

Don’t forget to keep an eye out for the remainder of our GovCon podcast CAS series, where our hosts will go into more detail on the specifics of the individual CAS standards, general requirements, cost accounting changes and the disclosure statement.

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In this episode of Cherry Bekaert's Government Contracting podcast, Brendan Halloran, a Director in Cherry Bekaert’s Government Contracting Industry practice ,and Jeff Annessa, a Senior Manager in the Firm’s GovCon practice continue our Contractor Business Systems series, discussing system reviews, audit findings, corrective actions, and ACO determinations.

Indicators of potential findings or noncompliances during a DCAA system audit and steps contractors can take
The DCMA system review process
The ACO process in determining the level of deficiencies
Ways to get a DCAA finding viewed as non-significant and differences between DCAA and DCMA Business System Deficiency terminology
Tools used by the ACO and how they work through the process
The corrective action process

Cherry Bekaert's Government Contracting Industry advisors excel in navigating business systems requirements and intricate control environments, offering guidance in the development, maintenance, assessment, and audit preparation of compliant systems for contractors facing reviews by DCAA, DCMA, or related agencies.

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The Federal Acquisition Regulation (FAR) doesn’t provide many details on the specifics related to an adequate timekeeping system. However, the Defense Contract Audit Agency (DCAA) does have some specific requirements they look for when performing accounting system audits and labor floor checks.

In this episode of Cherry Bekaert’s GovCon Podcast, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s GovCon practice who spent 13+ years with DCAA and held various leadership positions such as Quality Manager, Supervisory Auditor and Field Audit Office Manager, and Jacquelin LaClair, a Manager in the Firm’s GovCon practice who spent 10 years working with DCAA and the Defense Contract Management Agency (DCMA). They discuss one of their favorite topics: timekeeping and the government’s expectations. Listen to find out:

Why contractors should have written timekeeping policies and procedures in place and should consider including all types of work arrangements available by your organization (in-office, remote or hybrid)
Key elements for an adequate timekeeping system
Ensuring segregation of responsibilities for labor-related activities
Total Hours Worked approach and why the government cares
Policies and procedures that address how direct and indirect time is recorded
How to handle paper vs. electronic timesheets
The employee and the supervisor roles in certifying the accuracy of timesheets on a daily, weekly, bi-weekly or monthly basis
Record retention requirements for timesheets

At the end of the day, would a government auditor be able to review your current timekeeping policies and procedures and compare them to what is currently happening at your organization and find no discrepancies? If you have any questions specific to your situation, we are available to discuss your situation with you. Contact us.

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The Defense Contract Audit Agency (DCAA) recently released its Fiscal Year 2022 Report to Congress. By law, the DCAA is required to submit an annual report detailing the DCAA’s activities for the previous year.

In this episode of Cherry Bekaert’s GovCon Podcast, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, is joined by Jeff Annessa, a Senior Manager in the Firm’s GovCon practice who spent 13+ years with the DCAA and held various positions such as Quality Manager, Supervisory Auditor, Field Audit Office Manager and Senior Financial Liaison Advisor, and Jacquelin LaClair, a Manager in the Firm’s GovCon practice who spent 10 years working with the DCAA and the Defense Contract Management Agency (DCMA), discuss key takeaways from the DCAA’s report as an update to Cherry Bekaert’s DCAA Update webinar in February 2023.

Listen in to find out about:

Number of audits conducted by the DCAA, noted questioned costs and which audits were performed more frequently
Overall return on investment (ROI) for each audit type and what this means for government contractors
Investigative cases
Sustention rates by audit, how those rates are important to the DCAA and how this impacts contractors
Timing to complete an audit, by audit type
Number of incurred cost audits performed by Independent Public Accounting Firms
How the DCAA assists with Other Transaction Authorities (OTAs), the overall impact to the DCAA and current trends
Difference between an incurred cost audit and a low-risk memo, when one is issued over the other and how many audit reports and memos were issued by the DCAA in FY22
Post-pandemic changes occurring within the DCAA
Establishment of Operations Business Enterprise and Data Intelligence Division (OBD) and what is currently being worked on with the DCAA
DCAA’s External Peer Review

Whether you are a small business expecting your first audit, or a large contractor preparing for one of your many different audits, Cherry Bekaert’s GovCon consultants work with clients to prep for audits, resolve DCAA findings and have extensive hands-on experience in this subject. If you have any questions specific to your situation, we are available to discuss your situation with you. Contact us

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In this episode, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contractor Industry practice is joined by Matt Schiavone, Managing Director, and Brian Kirk, Senior Manager in the Firm’s Information Assurance & Cybersecurity practice to discuss the Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 program milestone and what contractors should be doing now to prepare.

Listen in as they share insights into the:

Recent updates to the final CMMC rule, including next steps and an updated expectation on when it will go final
Projected timeline implications for contractors and action steps to prepare
Recommendations for ensuring preparedness for timely achieving a certification

If you have any questions regarding CMMC, Cherry Bekaert’s Information Assurance & Cybersecurity and Government Contracting advisors are available to discuss your situation with you. Cherry Bekaert is authorized by the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, Inc. (The Cyber AB) as a CMMC Third-Party Assessment Organization (C3PAO). As an authorized C3PAO, Cherry Bekaert assists DoD contractors seeking a CMMC assessment with CMMC readiness and Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) Joint Surveillance Voluntary Level 2 assessments in partnership with the DIBCAC.

Having undergone Level 2 assessment as a Firm, Cherry Bekaert has a deep understanding of the assessment process to guide DoD contractors seeking a CMMC assessment.

Catch up on Cherry’s Bekaert’s previous guidance pertaining to CMMC 2.0:

Podcast: How Will NIST Special Publication (SP) 800-171, Revision 3 Impact CMMC?
Article: Updated Projected Timeline for CMMC: What this Means for Contractors and How to Prepare for Certification
Final CMMC Rule: March 2023 Update
Podcast: CMMC 2.0 – Where Does It Stand?
Podcast: What’s New with CMMC 2.0?: August 2022 Update
Podcast: CMMC 2.0 Brings Major Program Changes
On-Demand Webinar: CMMC 2.0 Brings Major Program Changes

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In this eighth episode of Cherry Bekaert’s podcast series on Contractor Business Systems, Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice who was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), is joined by Roy Rushing, a Manager in the Firm’s GovCon practice and a former Contracting Officer with various federal agencies, to talk about navigating Contractor Business Systems audits and reviews.

Listen in to find out about:

The two primary types of system audits/reviews:
- Defense Contract Audit Agency (DCAA) audits
- Defense Contract Management Agency (DCMA) reviews
Steps to take early on once you have received notification of a planned audit/review
Considerations leading up to the audit/review
Typical timing/scheduling
Pointers to navigate the process once the audit/review has started
Benefits of an approved system

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on other parts of the series:

Contractor Business Systems Series: Part 1 – Applicability
Contractor Business Systems Series: Part 2 – Accounting System
Contractor Business Systems Series: Part 3 – Cost Estimating System Requirements
Contractor Business Systems Series: Part 4 – Purchasing System
Contractor Business Systems Series: Part 5 – Earned Value Management System
Contractor Business Systems Series: Part 6 – Property Management System
Contractor Business Systems Series: Part 7 – Material Management and Accounting System

Cherry Bekaert’s Government Contracting Industry advisors are well versed in business systems requirements and complex control environments. We guide contractors in developing and maintaining compliant business systems, performing systems assessments, providing audit support and preparing contractors for audits or reviews by the Defense Contract Audit Agency (DCAA), the Defense Contract Management Agency (DCMA) or other cognizant agencies.

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In this episode, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contractor Industry practice, is joined by Brian Kirk, Senior Manager in the Firm’s Information Assurance & Cybersecurity practice, to discuss the impact of the Draft NIST Special Publication (SP) 800-171 Revision 3 on the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The Revision 3 draft was released on May 10, 2023, and is out for public comment through July 14, 2023.

Listen in as they share insights into:

Why the update to NIST SP 800-171 is significant to CMMC
Timeline for the final version of NIST SP 800-171 Revision 3 and subsequent revisions to the CMMC Assessment Guide, which is based on NIST 800-171 Revision 2
Revisions to the set of supporting NIST publications on protecting controlled unclassified information, including SPs 800-171A (security requirement assessment), SP 800-172 (enhanced security requirements) and SP 800-172A (enhanced security requirement assessment)
A summary of the significant changes between NIST SP 800-171, Revision 2 and Draft NIST SP 800-171, Revision 3
Recommendations to DoD contractors seeking a CMMC assessment with CMMC readiness and Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) Joint Surveillance Voluntary Level 2 assessments in partnership with the DIBCAC

If you have any questions regarding CMMC, Cherry Bekaert’s Information Assurance & Cybersecurity and Government Contracting advisors are available to discuss your situation with you. Cherry Bekaert is authorized by the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, Inc. (The Cyber AB) as a CMMC Third-Party Assessment Organization (C3PAO). As an authorized C3PAO, Cherry Bekaert assists DoD contractors seeking a CMMC assessment with CMMC readiness and DIBCAC Joint Surveillance Voluntary Level 2 assessments in partnership with the DIBCAC.

Having undergone Level 2 assessment as a Firm, Cherry Bekaert has a deep understanding of the assessment process to guide DoD contractors seeking a CMMC assessment.

Catch up on Cherry’s Bekaert’s previous guidance pertaining to CMMC 2.0:

Article: Updated Projected Timeline for CMMC: What this Means for Contractors and How to Prepare for Certification
Podcast: Final CMMC Rule: March 2023 Update
Podcast: CMMC 2.0 – Where Does It Stand?
Podcast: What’s New with CMMC 2.0?: August 2022 Update
Podcast: CMMC 2.0 Brings Major Program Changes
On-Demand Webinar: CMMC 2.0 Brings Major Progra

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A government contractor Material Management and Accounting System (MMAS), as outlined in Defense Federal Acquisition Regulation Supplement (DFARS) 252.242-7004, is a system for planning, controlling and accounting for the acquisition, use, issuance and disposition of material. It is under the cognizance of the Defense Contract Audit Agency (DCAA) and geared towards a contractors’ manufacturing planning and production.

In this seventh episode of Cherry Bekaert’s podcast series on each of the Contractor Business Systems, Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice who was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), is joined by John Bula, a Manager, and Chris Morris, a Senior Associate, in the Firm’s GovCon practice to discuss the requirements for a contractor MMAS, when contractors are obligated to maintain a MMAS and what to expect from DCAA during an audit.

Listen in to find out about:

What is a Material Management and Accounting System?
When are contractors obligated to maintain an adequate and acceptable MMAS?
What are common elements of MMAS?
When is a MMAS review or audit needed and what is expected from the DCAA?
How should a contractor prepare for a review or audit by DCAA?
What are operational benefits of a MMAS?
What are typical issues encountered with internal monitoring, or a government audit or review?

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on other parts of the series:Contractor Business Systems Series: Part 1 – Applicability

Contractor Business Systems Series: Part 2 – Accounting System

Contractor Business Systems Series: Part 3 – Cost Estimating System Requirements

Contractor Business Systems Series: Part 4 – Purchasing System

Contractor Business Systems Series: Part 5 – Earned Value Management System

Contractor Business Systems Series: Part 6 – Property Management System

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Government Property Management System is one of the six systems covered by the Department of Defense’s (DoD) Contractor Business Systems. In this sixth episode of Cherry Bekaert’s podcast mini-series on each of the six Contractor Business Systems, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice, and Brendan Halloran, a Senior Manager in the Firm’s GovCon practice who previously was a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), discuss the requirements for a Contractor Property Management System, 252.245-7003, and when it is required.

Listen in to find out about:

Property Management Systems and their requirements
Best practices and processes for handling government property
Policies, procedures and documentation
Flow down requirements to subcontractors
Common pitfalls
Disposal of government property
Other integral Business Systems requirements

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on the series:

Contractor Business Systems Series: Part 1 – Applicability
Contractor Business Systems Series: Part 1 – Accounting System
Contractor Business Systems Series: Part 3 – Cost Estimating System Requirements
Contractor Business Systems Series: Part 4 – Purchasing System
Contractor Business Systems Series: Part 5 – Earned Value Management System

Cherry Bekaert’s Government Contracting Industry advisors are well versed in Business Systems requirements and complex control environments. We guide contractors in developing and maintaining compliant Business Systems, performing systems assessments, providing audit support and preparing contractors for audits or reviews by the Defense Contract Audit Agency (DCAA), the Defense Contract Management Agency (DCMA) or other cognizant agencies.

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Contractors with the Federal Acquisition Regulation (FAR) Clause 52.216-7, Allowable Cost and Paymentincluded in their cost reimbursable and time & materials (T&M) contracts are required to submit an Incurred Cost Submission (ICS). Submitting your ICS on time to the appropriate Government Administrative Contracting Officer and the cognizant Defense Contract Audit Agency (DCAA) office can be a hurdle but a requirement. Late submissions are subject to a unilateral decision by the Contracting Officer (CO) to apply a decrement factor, which will reduce the billed cost.

In this episode of Cherry Bekaert’s GovCon Podcast, Brendan Halloran, a Senior Manager in the Firm’s GovCon practice who was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), welcomes Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice. Together they cover the ICS submission process, the first step in developing final indirect cost rates for contractors with flexibly priced contracts, due six months after the end of the fiscal year.

Listen in as they discuss:

When an ICS is a requirement
ICS preparation and required schedules
DCAA’s ICE Model
The importance of the preparation, due diligence and review process
Factors that can play into questioned costs and the full audit program
Process for extensions and repercussions for not timely submitting an ICS
Common issues and best practices

If you have any questions specific to your situation, Cherry Bekaert’s GovCon consultants are available to discuss your situation with you.

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In this episode, Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contractor Industry practice, and Brian Kirk, Senior Manager in the Firm’s Information Assurance & Cybersecurity practice, share an update on the status of the final rule of the Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 program and what contractors should be doing now to prepare.

Listen in as they share insights into the:

Current state of the final CMMC rule, including next steps and an updated expectation on when it will go final
Comparison of the current projected timeline with the original timeline
Congress’s concern about the cost of compliance
Projected timeline implications for contractors and action steps to prepare

Having undergone Level 2 assessment as a Firm, Cherry Bekaert has a deep understanding of the assessment process to guide DoD contractors seeking a CMMC assessment.

Catch up on Cherry’s Bekaert’s previous guidance pertaining to CMMC 2.0:

Podcast: CMMC 2.0 – Where Does It Stand?
Podcast: What’s New with CMMC 2.0?: August 2022 Update
Podcast: CMMC 2.0 Brings Major Program Changes
On-Demand Webinar: CMMC 2.0 Brings Major Program Changes

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In Part 1 of this two-part series, Cherry Bekaert’s Government Contracting Industry advisors discussed what companies need to consider when being acquired or acquiring a company that has federal contracts that are a significant part of their business, including some of the administrative items critical to that process.

In Part 2 Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice, is joined by John Ure, a Tax Partner and member of the Firm’s GovCon practice, to discuss some of the additional administrative steps and tax considerations.

Listen to find out about:

Contract novations and Novation Agreements
Administrative Contracting Officers’ (ACO) expectations in a Novation package
Standard acquisition and due diligence considerations for an S Corp
Beneficial sales structures from a tax perspective for company owners
Popular sales structures for C Corps and the often-overlooked 1202 sale
Tax and planning considerations in preparation for a Letter of Interest (LOI)
Considerations for government contractors when bringing on an acquisition

If you have any questions specific to your situation, Cherry Bekaert’s GovCon consultants are available to discuss your situation with you. Contact us

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An Earned Value Management System (EVMS) refers to the software, processes, tools, templates and management controls a contractor uses to accomplish their earned value management activities in accordance with the guidelines established by the Electronics Industry Alliance (EIA) Standard 748. Earned Value Management Systems (EVMS) is the standard for DoD (Department of Defense) Earned Value Management System Programs and Defense Federal Acquisition Regulation Supplement (DFARS) 252.234-7001 Notice of Earned Value Management System.

In this fifth episode of Cherry Bekaert’s podcast series on each of the six Contractor Business Systems, Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice who was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), and John Bula, a Manager in the Firm’s GovCon practice, discuss the requirements for a Contractor EVMS, when it is required and what it entails.

Listen in to find out about:

What is an Earned Value Management System
What is being seen in solicitations and RFPs
EVMS requirements and key components
DCMA EVMS guidelines, surveillances and reviews
Processes, documentation, metrics and reporting
Benefits in having an EVMS system in place
EVMS Best practices

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on the series:

Contractor Business Systems Series: Part 1 – Applicability
Contractor Business Systems Series: Part 1 – Accounting System
Contractor Business Systems Series: Part 3 – Cost Estimating System Requirements
Contractor Business Systems Series: Part 4 – Purchasing System

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What are size standards and how does the Small Business Administration (SBA) determine a small business’s size?

In this episode of Cherry Bekaert’s Government Contracting podcast series, John Ure and Carol Marin, Tax Partners in Cherry Bekaert’s Government Contractor Industry practice join James Kahrs, a Business Development Director in the Firm’s GovCon practice. Together, they discuss SBA size standards and recent threshold adjustments, which are used to determine whether a business entity is considered small, and subsequently eligible for government programs and preferences reserved for small business concerns.

Listen in to find out about:

SBA size standards and how they are established
SBA calculation of annual receipts
SBA calculation of number of employees
SBA’s recent adjustment of the size standard thresholds

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

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What is a Contractor Purchasing System? When is a Contractor Purchasing System required? What trends are being seen in solicitations?

The fourth episode of Cherry Bekaert’s podcast series on each of the six Contractor Business Systems features Brendan Halloran, a Senior Manager in the in Cherry Bekaert’s Government Contracting Industry practice who previously was a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), and John Bula, a Manager in the Firm’s GovCon practice. Together they discuss the requirements for a Contractor Purchasing System, as outlined in Defense Federal Acquisition Regulation Supplement (DFARS) 252.244-7001, when it is required and what it entails.

Listen in to find out about:

What constitutes an acceptable and compliant Contractor Purchasing System
What triggers the Contractor Purchasing System requirement
Key components and considerations of a Contractor Purchasing System
Policies, processes and documentation to demonstrate compliance
Benefits contractors can realize in having an approved system
Contractor Purchasing System Reviews (CPSR)

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on the first three parts of the series:

Contractor Business Systems Series: Part 1 – Applicability
Contractor Business Systems Series: Part 2 – Accounting System
Contractor Business Systems Series: Part 3 – Cost Estimating System Requirements

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Merger and acquisition activity is complex on its own, much less when you factor in government contracts. What should government contracting companies consider when evaluating a potential transaction? Join Cherry Bekaert’s Government Contracting Industry practice for a two-part series on government contract considerations during an acquisition.

In the first episode, Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice, and Roy Rushing, a Manager in the Firm’s GovCon practice, discuss contract types, requirements and considerations when a company evaluates acquiring a company or being acquired. Listen to find out about:

Types of contracts and past performance considerations
Potential impacts to contracts and revenue stream
Organizational conflicts of interest and other considerations for different contract types
Special security considerations
Contract novations and requirements

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

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In this episode Eric Poppe, a Director in Cherry Bekaert’s Government Contractor Industry practice, leads a panel discussion on the current state of the Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 program. He and the panel draw from the Firm’s own experience with the assessment process, having undergone a Level 2 assessment to receive authorization from the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, Inc. (The Cyber AB) as a CMMC Third-Party Assessment Organization (C3PAO).

Listen in to hear from Neal Beggan, Partner and leader of Cherry Bekaert’s Risk Advisory Services, Matthew Schiavone, Managing Director and Brian Kirk, Senior Manager, from the Firm’s Information Assurance & Cybersecurity Practice as they share insights into:

Current state of CMMC
Status of the Final Rule – Defense Federal Acquisition Regulation Supplement (DFARS) Clause 252.204.7021, or the “CMMC Clause”
What we are seeing in contracts
What a C3PAO means
Assessment pitfalls
Joint Surveillance Voluntary Assessments program in partnership with the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)

Catch up on Cherry’s Bekaert’s previous guidance pertaining to CMMC 2.0:

Podcast: What’s New with CMMC 2.0?: August 2022 Update
Podcast: CMMC 2.0 Brings Major Program Changes
On-demand webinar: CMMC 2.0 Brings Major Program Changes

If you have any questions regarding CMMC, Cherry Bekaert’s Information Assurance & Cybersecurity and Government Contracting advisors are available to discuss your situation with you.

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The 8(a) Business Development Program is a nine-year program created by the Small Business Administration (SBA) to help small, disadvantaged businesses compete and conduct business with the Federal government. The 8(a) Program offers small, disadvantaged businesses tremendous opportunities but contains stringent compliance requirements.

What must companies be aware of to avoid early graduation from the program? At what point should companies prepare for life beyond the program? What should companies consider to thrive in a more competitive business environment?

Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting Industry practice, and Sarah Tucker, a Senior Manager in the Firm’s GovCon practice, discuss what an 8(a) company needs to know and focus on as it prepares for life beyond the 8(a) Program, including:

Why some companies graduate early from the 8(a) Program
What to consider when contemplating an early graduation
What to monitor to stay in compliance of the 8(a) Program
What pre-planning steps to take to transition from the 8(a) Program
Which areas to focus on to successfully graduate from the 8(a) Program and thrive

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
The SBA 8(a) Business Development Program Application Process and Requirements
What Are the Compliance Requirements for 8(a) Certified Companies?
Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Winning an 8(a) Competitive Contract
Small Business Administration (SBA) Mentor-Protégé Program
SBA Mentor-Protégé & Joint Venture Arrangements – Important Elements of the Agreement
The lifecycle of an 8(a) Company
OIG Report: SBA’s Business Development Assistance to 8(a) Program Participants
Contract Performance After the SBA 8(a) Business Development Program

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What year-end, tax-saving steps can government contracting businesses and their owners take? How can they prepare for tax law changes impacting 2023?

In this episode of Cherry Bekaert’s Government Contracting podcast series, John Ure and Carol Marin, Tax Partners in Cherry Bekaert’s Government Contractor Industry practice and Private Client Services practice, discuss year-end tax planning at the entity and individual levels, including pertinent information for government contractors and 8(a) government contractors.

Listen in to find out about:

Methods to reduce current year income
Captial expenditures, fixed assets and phase out of bonus depreciation rules starting in 2023
Retirement plans to manage income, including VIP retirement plans
Research & Development (R&D) tax credit
Employee Retention Credit (ERC)
Projections and estimated tax payments to avoid surprises
Pass-thru entity considerations
Qualified Business Income deduction
Charitable contributions
Special regulations and thresholds for SBA 8(a) program government contractors

If you need help with year-end tax planning, Cherry Bekaert tax advisors are available to discuss your situation. We welcome the opportunity to identify the best tax positions and opportunities for you and your company.

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When should government contractors that work with the Department of Defense (DoD) be concerned about Cost Estimating System Requirements for compliance and adequacy per the Defense Federal Acquisition Regulation Supplement (DFARS) What are the requirements and trends being seen in solicitations?

In this third episode of Cherry Bekaert’s podcast series on each of the six Contractor Business Systems, Eric Poppe, a Director in Cherry Bekaert’s Government Contracting Industry practice, and Brendan Halloran, a Senior Manager in the Firm’s GovCon practice who previously was a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), discuss the requirements for an adequate estimating system as outlined in Cost Estimating System Requirements, 252.215-7002.

Listen in to find out about:

What constitutes an adequate Estimating System
When it is a requirement
Policies, processes, and documentation to demonstrate compliance
Best practices and pitfalls to avoid
How to prepare for getting an approved Estimating System

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on Part 1 in the series:

Contractor Business Systems Series: Part 1 – Applicability
Contractor Business Systems Series: Part 1 – Accounting System

Cherry Bekaert’s Government Contracting Industry advisors are well versed in business systems requirements and complex control environments. We guide contractors in developing and maintaining compliant business systems, perform systems assessments, provide audit support, and prepare contractors for audits or reviews by the Defense Contract Audit Agency (DCAA), the Defense Contract Management Agency (DCMA) or other cognizant agencies.

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The Contractor Business Systems podcast series hosts members of Cherry Bekaert’s Government Contracting Industry team to discuss each of the six contractor business systems—Accounting, Estimating, Purchasing, Earned Value Management Systems (EVMS), Material Management and Accounting System (MMAS), and Property Management.

In this second episode, Eric Poppe, a Director in Cherry Bekaert’s Government Contracting Industry practice, and Jacquelin LaClair, a Senior Associate in the Firm’s GovCon practice who spent 10 years working with the Defense Contract Audit Agency (DCAA) and the Defense Contract Management Agency (DCMA), discuss the requirements for an adequate accounting system as outlined in Accounting System Administration, 252.242-7006 and required by FAR 16.301-3 in the award of a cost reimbursable type contract.

Listen in to find out about:

What types of Accounting System audits might be requested by Contracting Officers
What the differences are between Pre-Award Accounting System audits and Post Award Accounting System audits
What the government is reviewing
How contractors should prepare for an Accounting System audit

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on Part 1 in the series:

Contractor Business Systems Series: Part 1 – Applicability

Cherry Bekaert’s Government Contracting Industry advisors are well versed in business systems requirements and complex control environments. We guide contractors in developing and maintaining compliant business systems, perform systems assessments, provide audit support, and prepare contractors for audits or reviews by the Defense Contract Audit Agency (DCAA), the Defense Contract Management Agency (DCMA) or other cognizant agencies.

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Continuing in our series on the Small Business Administration (SBA) 8(a) Business Development Program and the All-Small Mentor-Protégé Program (previously the 8(a) Mentor-Protégé Program), the focus of this podcast episode is on how to handle basic accounting when entering into a Joint Venture (JV) agreement as part of a Mentor-Protégé (M-P) arrangement.

Listen to Eric Poppe, a Director in Cherry Bekaert’s Government Contracting Industry Practice, and Craig Hunter, an Assurance Partner and member of the Firm’s GovCon practice, to find out about:

The SBA All Small Mentor-Protégé Program
How JV arrangements are traditionally set-up
How the day-to-day accounting flows between entities
Billing and best practices
Cost allocation
How to handle the accounting for different contract types

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us.

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
The SBA 8(a) Business Development Program Application Process and Requirements
What Are the Compliance Requirements for 8(a) Certified Companies?
Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Winning an 8(a) Competitive Contract
Small Business Administration (SBA) Mentor-Protégé Program
SBA Mentor-Protégé & Joint Venture Arrangements – Important Elements of the Agreement
The lifecycle of an 8(a) Company
OIG Report: SBA’s Business Development Assistance to 8(a) Program Participants
Contract Performance After the SBA 8(a) Business Development Program

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Listen to Eric Poppe, a Director in Cherry Bekaert’s Government Contracting Industry Practice, and Craig Hunter, an Assurance Partner and member of the Firm’s GovCon practice, to find out about:

The SBA All Small Mentor-Protégé Program
How JV arrangements are traditionally set-up
How the day-to-day accounting flows between entities
Billing and best practices
Cost allocation
How to handle the accounting for different contract types

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us.

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
The SBA 8(a) Business Development Program Application Process and Requirements
What Are the Compliance Requirements for 8(a) Certified Companies?
Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Winning an 8(a) Competitive Contract
Small Business Administration (SBA) Mentor-Protégé Program
SBA Mentor-Protégé & Joint Venture Arrangements – Important Elements of the Agreement
The lifecycle of an 8(a) Company
OIG Report: SBA’s Business Development Assistance to 8(a) Program Participants
Contract Performance After the SBA 8(a) Business Development Program

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Join Cherry Bekaert’s Government Contracting Industry team for part one of a new podcast series discussing the six contractor business systems—Accounting, Estimating, Purchasing, Earned Value Management Systems (EVMS), Material Management and Accounting System (MMAS), and Property Management. The series will discuss Business Systems applicability, requirements and trends currently seen for Business Systems in solicitations.

In the first episode Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice, and Roy Rushing, a Manager in the Firm’s GovCon practice and a former Contracting Officer with various federal agencies, discuss Business Systems applicability, including an overview of what the Business Systems are and background. Listen in to find out about:

An overview of the Business Systems
When contractors should be concerned about Business Systems
Which three systems are the most common and come into play first for contractors
When companies would encounter the other three systems
Small business applicability and the value of these requirements beyond meeting contractual requirements

Cherry Bekaert’s Government Contracting Industry advisors are well versed in business systems requirements and complex control environments. We guide contractors in developing and maintaining compliant business systems, perform systems assessments, provide audit support, and prepare contractors for audits or reviews by the Defense Contract Audit Agency (DCAA), the Defense Contract Management Agency (DCMA) or other cognizant agencies.

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

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As companies prepare for graduation from the Small Business Administration (SBA) 8(a) program, there are many important considerations and decisions to be made. The key to successfully graduate and thrive is to plan well in advance.

Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice, John Ure, a Tax Partner and member of the Firm’s GovCon practice, and Brendan Halloran, a Senior Manager in the Firm’s GovCon practice and former Divisional Administration Contracting Officer (ACO) with the Defense Contract Management Agency (DCMA), discuss what an 8(a) company needs to know and focus on as it prepares for graduation from the 8(a) Business Development Program.

We will discuss:

Why for some contractors focusing on staying a small business is a good thing
If your path is to stay small, what to be aware of and to focus on for more success
Considerations and planning for growth to meet requirements as a large business
New SBA rule to help small businesses meet past performance requirements

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you. Contact us

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
The SBA 8(a) Business Development Program Application Process and Requirements
What Are the Compliance Requirements for 8(a) Certified Companies?
Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Winning an 8(a) Competitive Contract
Small Business Administration (SBA) Mentor-Protégé Program
SBA Mentor-Protégé & Joint Venture Arrangements – Important Elements of the Agreement
The lifecycle of an 8(a) Company
OIG Report: SBA’s Business Development Assistance to 8(a) Program Participants

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Where does the Cybersecurity Maturity Model Certification (CMMC) 2.0 program currently stand? Neal Beggan, leader of Cherry Bekaert’s Risk Advisory Services and a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice and Eric Poppe, a Director in the Firm’s Government Contractor Services Group, discuss the latest information about the Department of Defense (DoD) CMMC 2.0 program.

Listen in to find out about:

The CMMC accreditation body - now called “The CYBER AB”
CAP, a pre-decisional draft of the CMMC assessment process (CAP) released by The CYBER AB
FedRAMP certification and NIST SP 800-171
Recent DoD memorandum and DoJ Comprehensive Cyber Review highlighting enforcement mechanisms for compliance with cybersecurity requirements
Voluntary assessments, which are now allowed prior to the interim final rule for CMMC, and expected to begin in late summer/early fall of 2022

If you haven’t already, catch up on Cherry’s Bekaert’s previous guidance on CMMC 2.0:

On-demand webinar: CMMC 2.0 Brings Major Program Changes
Podcast: CMMC 2.0 Brings Major Program Changes

If you have any questions regarding CMMC, Cherry Bekaert’s Risk Advisory and GovCon Consultants are available to discuss your situation with you.

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On February 14, 2022, the Office of Inspector General (OIG), U.S. Small Business Administration (SBA) issued a report on SBA’s Business Development Assistance to 8(a) Program Participants. The objective of the audit was “to determine to what extent SBA measures and monitors an 8(a) firm's progress toward achieving individual business development goals. The objective was also to ensure 8(a) firms receive the help needed to meet their goals and if the program adapted during the Coronavirus Disease 2019 pandemic.”

Why should we care about the findings of this report? Often OIG reports foreshadow what might be expected in the coming year. This report gives 8(a) companies a preview of what SBA may focus on.

Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice and Brendan Halloran, a Senior Manager in the Firm’s GovCon practice, discuss what they learned from the OIG report and key takeaways, including:

Background on the SBA 8(a) Program and data points from the Report
OIG’s findings and recommendations
What 8(a) contractors should expect in the coming year

Our Government Contractor Services group has an in-depth understanding of the 8(a) program and advises a number of 8(a) government contractors through each step of the process to add value and anticipate ongoing opportunities. From the initial important decisions made in becoming an 8(a), to the first contract, to how the company is growing throughout the life of the program.

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you.

If you haven’t already, listen to other episodes in our podcast series discussing various aspects of the SBA 8(a) Program:

Part 1: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
Part 2: The SBA 8(a) Business Development Program Application Process and Requirements
Part 3: What Are the Compliance Requirements for 8(a) Certified Companies?
Part 4: Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Part 5: Winning an 8(a) Competitive Contract
Part 6: Small Business Administration (SBA) Mentor-Protégé Program
Part 7: The Lifecycle of an SBA 8(a) Company

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The use of teaming agreements when competing for government contracts can create new government contract opportunities for businesses both large and small. Teaming and subcontracting agreements give companies the chance to win awards that they might not otherwise qualify for or have the depth of technical expertise and resources individually.

There are many factors to consider when entering a teaming or subcontract arrangement, including types of arrangements, regulatory compliance requirements, rate structures and operating and entity agreements.

In this episode, Eric Poppe, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice, and Brendan Halloran, also a senior manager in the Firm’s Government Contracting practice, share their insights into the different types of teaming arrangements and what government contractors should consider when entering into an agreement, along with best practices.

Discussion includes:

Reasons for entering a teaming arrangement
Small business plans and subcontractor arrangements
Rate structures and contract mix
The differences between a subcontract and other teaming arrangements
Operating and entity agreements
Regulatory compliance considerations

If you need any help developing your teaming strategy or navigating the proposal process, Cherry Bekaert’s Government Contracting consultants are available to discuss your situation with you.

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In this episode Neal Beggan, leader of Cherry Bekaert’s Risk Advisory Services and a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, and Eric Poppe, a senior manager in the Firm’s Government Contractor Services Group, discuss the current state of the Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 program and share insights on what contractors and subcontractors in the defense industrial base (DIB) should be doing now to prepare.

Discussion includes:

The Pentagon’s shift of responsibility for the CMMC program to the DoD CIO
Change in leadership at the CMMC Accreditation Body
Debunking some of the rumors around the CMMC 2.0 rollout, including:
- DoD’s rollback on the number of companies who would have been allowed to self-attest, increasing the number of contractors that may require a third-party assessment
- The expected length of the rulemaking process and when the actual requirements will be incorporated into procurements
The Government Accountability Office (GAO) report on the CMMC rollout
What companies should be doing now to prepare for CMMC
Incentives being considered by DoD to encourage early adoption of certification

If you haven’t already, catch up on Cherry’s Bekaert’s previous guidance on CMMC 2.0:

On-demand webinar: CMMC 2.0 Brings Major Program Changes
Podcast: CMMC 2.0 Brings Major Program Changes

If you have any questions regarding CMMC, Cherry Bekaert’s Risk Advisory and GovCon Consultants are available to discuss your situation with you.

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Idle facilities and the associated costs have always been a topic of debate between government contractors and the Federal government. Contractors need to proactively monitor their facility use to avoid potential questioned costs while ensuring they can meet contract work fluctuations and future demand.

With businesses becoming more comfortable with employees working from home due to the COVID 19 pandemic, office occupancy has greatly declined and there is uncertainty as to when, or if, government contractors will go back to a fully occupied office environment. Many contractors now find themselves in a position of evaluating their long-term needs for facility space.

Listen to Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry (GovCon) practice who previously spent 10 years at the Defense Contract Management Agency (DCMA), and Curt Smith, a Manager in the Firm’s GovCon practice who spent 12 years at the Defense Contract Audit Agency (DCAA), discuss how the Federal government views idle facilities, how much time contractors are allowed before the government considers facility costs unallowable, and how contractors should address the costs associated with these facilities.

If you need help determining or supporting idle facilities costs, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you.

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Listen to Brynn McNeil, an Assurance Partner in Cherry Bekaert’s Government Contracting Industry practice and Eric Poppe, a Senior Manager in the Firm’s GovCon practice, discuss the important elements of an agreement when forming a Mentor-Protégé/Joint Venture arrangement.

They discuss:

Benefits of the Mentor-Protégé Program
Basic principles to consider in Agreements
Regulatory requirements
Other considerations

In our previous podcast on the SBA Mentor Protégé program, we gave an overview of the program, discussed some of the goals and benefits from participating in this program, as well as eligibility to participate both from the mentor and the protégé perspectives.

We will continue to do future podcasts on this topic, highlighting the annual evaluations that need to be performed, compliance issues, including limitations on subcontracting, accounting and financial reporting, and pricing considerations.

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The nine-year Small Business Administration (SBA) 8(a) Business Development Program is a business assistance program that was created to help small, disadvantaged businesses wanting to do business with the Federal government gain a foothold in Federal government contracting.

Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice and John Ure, Tax Partner and member of the Firm’s GovCon practice, discuss the lifecycle of an 8(a) company, including a brief overview of the 8(a) program and qualifications; and what an 8(a) company needs to know and focus on during the Developmental Stage, Transition Stage and as you prepare for graduation to help your 8(a) qualified business thrive and successfully graduate.

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you.

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

Part 1: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
Part 2: The SBA 8(a) Business Development Program Application Process and Requirements
Part 3: What Are the Compliance Requirements for 8(a) Certified Companies?
Part 4: Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know
Part 5: Winning an 8(a) Competitive Contract
Part 6: Small Business Administration (SBA) Mentor-Protégé Program

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The Coronavirus Aid, Relief, and Economic Security (CARES) Act at the start of the pandemic was a lifeline for millions of small businesses in the U.S. The Paycheck Protection loan program (PPP) and the Employee Retention Credit (ERC) provided relief and cash for all kinds of small businesses, but for government contractors, the confusion and changing guidance and interpretations has caused much consternation, stress, confusion, and frustration.

Now, almost two years after the initial programs were put in place, there is still confusion.

Listen to Susan Moser, Advisory Partner and leader of Cherry Bekaert’s Government Contracting industry practice, Martin Karamon, a Tax Services Principal and leader of Cherry Bekaert’s Tax Credits and Incentives advisory practice, Brynn McNeil, an Assurance Partner in the Firm’s GovCon practice, and Eric Poppe, a Senior Manager in the GovCon practice, as they provide a recap of the programs and discuss their current state, how contractors are handling relief, the accounting for these credits, the tax implications and how government auditors are looking at these credits and the impact on contracts.

If you have any questions specific to your situation, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you.

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Join Cherry Bekaert’s Government Contractor Services Group for part six of our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program. In this episode, Brynn McNeil, an Assurance Partner in Cherry Bekaert’s Government Contracting practice and Eric Poppe, a Senior Manager in the Firm’s GovCon practice give an overview of the Small Business Administration (SBA) Mentor-Protégé Program, including program goals, eligibility requirements, benefits from both the mentor and protégé perspective and why it’s advantageous to participate in the program.

This is our first podcast on the SBA Mentor-Protégé Program, and we will be doing future podcasts on this topic, highlighting compliance issues, including limitations on subcontracting, accounting and financial reporting considerations, pricing considerations and best practices.

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Listen to Brendan Halloran, a Senior Manager in Cherry Bekaert’s Government Contracting Industry practice who previously spent 10 years at the Defense Contract Management Agency (DCMA), and Curt Smith, a manager in the Firm’s GovCon practice who spent 12 years at the Defense Contract Audit Agency (DCAA), discuss allowability and where contractors might run into audit findings with questioned costs.

Discussion includes:

What makes a cost allowable, including Reasonableness, Allocability, Cost Accounting Standards (CAS) and terms of the contract
Direct and indirect costs
Facilities costs
Unallowable costs
Supporting questioned costs

If you need any help in determining or supporting cost allowability, Cherry Bekaert’s GovCon Consultants are available to discuss your situation with you.

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Many of our government contracting clients are taxed as a pass-thru entity, generally an LLC that's taxed as a partnership or an S corporation. It is important to plan at both the entity level and the individual level since in the case of pass-thrus, the income is passed down to the individual owners through a Form K-1 regardless of distributions received during the year.

Year-end tax planning should be done to reduce the taxable income that passes down through K1s to the individual return. In the case of a C Corporation, year-end tax planning is helpful to defer taxes or potentially avoid taxes as much as possible.

Listen to John Ure, Carol Marin and Greg Marx, Tax Partners in Cherry Bekaert’s Government Contracting Industry practice and Private Client Services group, discuss tax-saving steps government contractors can take before the year ends.

Discussion includes:

Methods of reducing current year income
Special regulations and thresholds for SBA 8(a) program government contractors, including excessive withdrawals
How retirement plans can be used to help manage income, including VIP retirement plans
Research & Development (R&D) tax credit: qualifying activities and types of contracts not eligible for the credit
New limitations coming back into play for 2021
New tax legislation pending in the US House and Senate

If you need any help with year-end tax planning, Cherry Bekaert tax advisors are available to discuss your situation with you. We welcome the opportunity to work with you to identify the best tax positions and opportunities for you and the company.

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The Incurred Cost Submission (ICS) is an administrative hurdle and something that government contractors do not look forward to putting together every year. However, it is required to be submitted six months after the end of a company’s fiscal year for any contractor who has cost-type and T&M contracts that contain the Allowable Cost and Payment Clause.

Listen to Eric Poppe, Senior Manager in Cherry Bekaert’s Government Contracting practice and Rich Wilkinson, Director of Product Marketing at Unanet discuss the importance of the calculation of a Company’s indirect rates and Incurred Cost Submissions and the consequences for not having final rates or late submissions, as it is more than just an administrative exercise.

Don’t put it off and don’t ignore the ICS. If you think you don’t have to submit, confirm with your contracts manager to identify all your active contracts containing Federal Acquisition Regulation (FAR) 52.216-7, Allowable Cost & Payment.

If you haven’t already, catch up on part one, part two and part three of our four-part series:

Indirect Rates – More than Just a Math Exercise: Part One
Indirect Rates – Monitoring and Best Practices in Calculating Your Rates: Part Two
Indirect Rates – The Close Out Process: Part Three

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On November 4, the Department of Defense (DoD) announced the strategic direction of the Cybersecurity Maturity Model Certification (CMMC) program, which marks the completion of an internal program assessment led by senior leaders across DoD.

CMMC 2.0 brings about a number of changes which DoD will be pursue through the rulemaking process and will include public comment periods.

Listen to Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, and Eric Poppe, a senior manager in the Firm’s Government Contractor Services Group, as they discuss DoD’s modifications and their potential impact on contractors and subcontractors in the defense industrial base (DIB).

Changes include:

Eliminating levels 2 and 4 of the framework and using National Institute of Standards and Technology (NIST) cybersecurity standards
Companies at Level 1, and a subsection of companies at Level 2 will only be required to demonstrate compliance through annual self-assessments
Triannual third-party assessments at Level 2 for critical national security information, as well as triannual government-led assessments at Level 3
Increase in oversight of professional and ethical standards of third-party assessors
New waiver processes for select requirements - DoD indicated:
- “Under certain limited circumstances”, companies can make “Plans of Action & Milestones (POA&Ms)” to achieve certification
- “Under certain limited circumstances”, waivers to CMMC requirements will be allowed

DoD is also suspending the current CMMC pilot program for select contracts and will not approve any CMMC requirements in DoD solicitations while the rulemaking is underway. The Defense Department further indicated that it is looking at providing incentives to contractors who voluntarily obtain certification during the interim period and more information will be forthcoming.

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Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice, and Eric Poppe, a Senior Manager in the Government Contracting practice, discuss winning an 8(a) competitive contract in episode five of our podcast series on the Small Business Administration’s (SBA) 8(a) Business Development program.

In part five, they discuss:

An overview of what Section 8 of the Small Business Act authorizes
Best practices for finding 8(a) competitive procurement opportunities
Single award vs. multiple award contracts, and what to be aware of when considering teaming partners
Best practices and considerations when putting together a proposal, from identifying teaming partners early on, to understanding the Federal Acquisition Regulation (FAR) compliance requirements and contract types, to cost and pricing and indirect rates.
Benefits of requesting a debrief on your proposal

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

Part I: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?
Part II: The SBA 8(a) Business Development Program Application Process and Requirements
Part III: What Are the Compliance Requirements for 8(a) Certified Companies?
Part IV: Winning an SBA 8(a) Sole Source Award Contract – What’s Involved and What to Know

Our Government Contractor Services group has an in-depth understanding of the 8(a) program and advises 8(a) government contractors through each step of the process to add value and anticipate ongoing opportunities. From the initial important decisions made in becoming an 8(a), to the first contract, to how the company is growing throughout the life of the program.

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Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice, Deb Walker, Compensation & Benefits Leader, and John Ford, Senior Consultant in the Firm’s Government Contracting practice discuss some of the unique considerations for government contractors around executive compensation, including financial reporting, tax considerations (both to company and employee) and allowability issues, as well as commonly asked questions.

Topics discussed include:

The basics: where compensation is addressed in the Federal Acquisition Regulation (FAR) (Part 31), reasonableness and some of the current limitations regarding executive compensation.
An explanation of the required disclosures regarding subcontractors for the five mostly highly compensated individuals.
Common executive compensation plans implemented by government contractors: bonus plans, incentive compensation plans, stock option plans, Stock appreciation rights (SARs), phantom stock and deferred compensation plans.
The allowability of various executive compensation plans.

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The Small Business Administration’s (SBA) 8(a) Business Development program offers small, disadvantaged businesses tremendous opportunities for sole source and limited competition contracts. During the program, participants can be awarded sole source contracts up to $4.5 million for goods and services ($7.5 million for manufacturing). But what does the contracting process entail and what should 8(a) contractors know to avoid mistakes?

Listen to Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice and Eric Poppe, a Senior Manager in the Government Contracting practice discuss the 8(a) contracting process and sole source awards, including certified cost and pricing data to determine fair market price, preaward surveys and best practices.

If you haven’t already, catch up on other episodes in our podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program:

Part I: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?

Part II: The SBA 8(a) Business Development Program Application Process and Requirements

Part III: What Are the Compliance Requirements for 8(a) Certified Companies?

In future 8(a) segments, we will discuss competitive contracts and the All Small Mentor Protégé Program.

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It’s year end and your company has closed out its fiscal year. What should you do from an indirect rate standpoint? Listen to Eric Poppe, Senior Manager in Cherry Bekaert’s Government Contracting practice and Rich Wilkinson, Director of Product Marketing at Unanet discuss the importance of indirect rates and the close out process.

Rate variance is consequential. It has a half-life of about a year. If the government owes you $1K in rate differential at the end of the year and you bill it immediately, you can normally expect to collect it all. If you wait until next year, however, some projects may be out of funding. A project office may push back on what they now see as a “late invoice.” The Defense Contract Audit Agency will often refuse to sign-off on it saying that the rate differential invoices should wait until contract close out (which could be three or four years).

On average, at the one-year mark, that $1k in rate variance is probably worth $500 or less. After another year, the collectability falls still further. It’s now probably worth $250 or less. The $1k example is bad enough, but what if the variance is $1M – or more?

By the way, this cycle isn’t over. There is still the dreaded Incurred Cost Submission to do to finalize the rates. But the pressure of negotiating final rates is eased a great deal if most of the variance was collected at year end. Remember, it’s a never-ending cycle. As one-year ends, another begins.

Steps for closing out the rate year:

Calculate the (near) final rates as soon as practical after the close of the last month.
Immediately submit a request for revised provisional rates equal to the actual rates for the year.
Immediately bill the rate differential as a separate invoice between the last (provisional) rate billing of the year and the first vouchers of the new year.

If you haven’t already, catch up on part one and two of the series where we discuss why government contracting firms need indirect rates and where and when to start, as well as monitoring and best practices in calculating your rates:

Indirect Rates – More than Just a Math Exercise: Part One
Indirect Rates – Monitoring and Best Practices in Calculating Your Rates: Part Two

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Listen to Eric Poppe, a Senior Manager in Cherry Bekaert’s Government Contracting practice, and Brendan Halloran, also a Senior Manager in the Firm’s Government Contracting practice who previously spent 10 years at the Defense Contract Management Agency (DCMA), including 7 years as a Divisional Administrative Contracting Officer (DACO), discuss proposal pricing in response to solicitations, from both a government contractor perspective and an audit and government evaluation perspective, including compliance considerations and the planning and estimating processes.

Our government contracting consulting professionals have worked extensively in the Federal contract arena and provide proposal preparation assistance, including cost and pricing proposals in response to RFPs, cost impact studies, forward pricing rate proposals, GSA Schedules, provisional rate proposals, SBIR proposals, Small Business (“SBA”) set aside programs and compliance (8a, Hubzone, SDVOB, Woman-Owned) and training to help contractors navigate the procurement process.

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Join Cherry Bekaert’s Government Contractor Services Group for part three of our new podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program. In this third episode, Brynn McNeil, an Assurance Partner in Cherry Bekaert’s Government Contracting practice and John Ure, Tax Partner and member of the Firm’s GovCon practice discuss the compliance requirements 8(a) companies must follow once they have been certified by the Small Business Administration (SBA), including:

An Annual Update Review (Form 1450)-8(a) based on the 8(a)’s annual program year, disclosing certain company data to remain in the program, including progress on meeting goals and annual personal financial statements for the individuals upon whom the 8(a) eligibility is based showing net worth, fair market value of all assets, personal income, and excessive withdrawal limitations
Required company financial statements:
- 8(a) participants with > $10 million in revenue must submit annual audited financial statements within 120 days of the company’s fiscal year.
- 8(a) participants with revenue between $2M and $10M must submit annual reviewed financial statements within 90 days of the company’s fiscal year.
- 8(a) participants with < $2M in revenue must provide an annual in-house or compiled financial statement within 90 days after the close of the company’s fiscal year

If you haven’t already, catch up on part one and two of the series where we discuss the overall SBA 8(a) program and eligibility, and the application process and requirements:

Part I: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?

Part II: The SBA 8(a) Business Development Program Application Process and Requirements

In future segments, we will discuss winning sole source and competitive contracts and the All Small Mentor Protégé Program.

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Listen to Eric Poppe, Senior Manager in Cherry Bekaert’s Government Contracting practice and Rich Wilkinson, Director of Product Marketing at Unanet discuss the importance of indirect rates. In part two we talk about monitoring indirect rates, why it is important, best practices in calculating indirect rates and why it is a great tool for project management.

Monitor the rates:

If your accounting system can calculate your rates, do it monthly at a minimum
Don’t be alarmed when they fluctuate significantly early in the fiscal year
Track the trends in the rates and pool costs

Make course corrections as required:

If the rates aren’t tracking to the budget, ask why
Fix the errant cost or change the estimate in the budget
Adjust your target rates used for project management
If the new target rates are materially different, submit a request for approval of revised rates
Bill the rate differential in the next billing cycle after approval.
Keep monitoring (rinse, repeat as necessary)

This part of the cycle repeats during the year to keep the billing/target/pricing rates as close to actual as feasible. Rate variance can be a killer to profitability and in the next segment, we’ll discuss how to keep it to a minimum.

If you haven’t already, catch up on part one of the series where we discuss why government contracting firms need indirect rates and where and when to start:

Indirect Rates – More than Just a Math Exercise: Part One

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Listen to Eric Poppe, a Senior Manager in Cherry Bekaert’s Government Contracting practice, and Brendan Halloran, also a Senior Manager in the Firm’s Government Contracting practice who previously spent 10 years at the Defense Contract Management Agency (DCMA), including 7 years as a Divisional Administrative Contracting Officer (DACO), discuss contractor Business Systems requirements and trends they are currently seeing for Business Systems in large Request for Proposals and solicitations.

The Defense Contract Audit Agency (DCAA) has a renewed focus on Accounting, MMAS and Estimating systems and is getting back into the program audit cycle with a focus on completing Business Systems audits. Contractors need to think ahead to understand what the criteria are and prioritize the Systems that apply to their business. By working towards being prepared for a potential audit or review, contractors can avoid surprises or scrambling to get a system reviewed for an RFP requirement.

Our government contracting consulting professionals have worked extensively in the Federal contract arena and are well versed in business systems requirements and complex control environments. We guide contractors in developing and maintaining compliant business systems, perform assessments against the criteria, provide audit support, and prepare contractors for audits or reviews by DCAA, DCMA or other cognizant agencies.

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Join Cherry Bekaert’s Government Contractor Services Group for part two of our new podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program, created to help small disadvantaged businesses wanting to do business with the Federal government gain a foothold in Federal government contracting.

In this second episode, Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice and John Ure, Tax Partner and member of the Firm’s GovCon practice discuss:

What you will need to prepare for the 8(a) application process
The five-part application – eligibility, ownership requirements, controls, potential for success and character, an overview and guidance on each section of the application, the requirements and what information and documents will need to be provided
SBA approval – top 10 reasons why companies do not get approved

If you haven’t already, catch up on part one of the series where we discuss the overall SBA 8(a) program, eligibility for getting into the program, what is needed and what is required:

Part I: The SBA 8(a) Business Development Program – What Is It and What Are the Requirements?

In future segments, we will discuss what happens when you get certified, winning sole source and competitive contracts and the All Small Mentor Protégé Program.

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Join Cherry Bekaert, a Registered Practitioner Organization (“RPO”) and Candidate Certified Third-Party Assessment Organizations (C3PAO), for part five of our podcast series discussing the various elements of the Department of Defense’s (“DoD”) Cybersecurity Maturity Model Certification (“CMMC”) program.

Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, leads the series along with Eric Poppe from the Firm’s Government Contractor Services Group, to provide contractors with the latest information on CMMC and navigating its impact on the government contracting community.

In part five of the series, Neal and Eric discuss the current status of CMMC, including

Is the rule final yet?
How does it relate to the Executive Order?
Recent News Articles and changes at the DoD
Impact on small and medium businesses
What should I be doing now?

If you haven’t already, catch up on the series:

Part 4: How to Prepare for a CMMC C3PAO Assessment for Certification
Part 3: What to Expect in an Upcoming CMMC C3PAO Assessment & How to Prepare
Part 2: CMMC and the DFARS Clause
Part 1: Current State of CMMC

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Join Cherry Bekaert’s Government Contractor Services Group for part one of a new podcast series discussing various aspects of the Small Business Administration’s (SBA) 8(a) Business Development Program. The 8(a) program is a business assistance program that was created to help small disadvantaged businesses wanting to do business with the Federal government gain a foothold in Federal government contracting.

In this first episode, Susan Moser, Partner and Leader of Cherry Bekaert’s Government Contracting practice and John Ure, Tax Partner and member of the Firm’s GovCon practice discuss the basics of the 8(a) program:

What is the 8(a) program
What are the opportunities, and
What are the requirements to apply for the 8(a) program

In future segments, we will discuss the requirements to stay in the program, winning sole source and competitive contracts and how to be successful.

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Listen to Eric Poppe, Senior Manager in Cherry Bekaert’s Government Contracting practice and Rich Wilkinson, Director of Product Marketing at Unanet discuss the importance of indirect rates. Indirect rates are more than just a math exercise. Having rates isn’t the objective. It’s having something you can use to figure out what your costs are. This is part one of a four-part series on indirect rates that Cherry Bekaert and Unanet will explore. In this episode we discuss:

Why do government contracting firms need indirect rates?

For pricing, estimating and forecasting
For managing project costs to the total cost line
If the firm has cost-type contracts, for billing the costs
If the firm has T&M contracts with G&A applied to non-labor, for billing the non-labor costs
If the firm has fixed price contracts with potential for increase(s) in scope, for pricing/negotiating the mods

Where do you start?

Well before the beginning of the fiscal year, prepare a budget for the coming year
Develop indirect rates from that budget
Submit the rates and support to your cognizant Administrative Contracting Officer (ACO) or the Defense Contract Audit Agency (DCAA)

Once approved by the government, use the rates for managing projects and forecasting costs and revenue (internal) and for billing and pricing (external).

But that’s not the end. Developing rates and getting them approved is just the beginning of the cycle. In the next segment, we will discuss monitoring your rates during the year and what to do if your indirect rates aren’t what you thought they would be.

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President Biden signed an Executive Order (“EO”) on May 12th aimed at improving and preparing for cybersecurity defenses for public and private sector companies. The EO is aimed at improving protective measures to federal networks, information-sharing between the U.S. government and the private sector on cyber issues and the collective ability to respond when incidents occur. The EO addresses initiatives and directives in many areas, which Cherry Bekaert summarized in a recent alert.

Susan Moser, leader of Cherry Bekaert’s Government Contractor Services Group, John Ford, a senior consultant in the Firm’s GovCon Group and Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice discuss the impacts and timing of the EO, including a general discussion on the authority of Executive Orders, how the EO impacts the Department of Defense’s (“DoD”) Cybersecurity Maturity Model Certification (“CMMC”) program, and what companies should be doing now to protect their systems and data.

Cherry Bekaert will continue to keep contractors updated in future podcasts on the EO and CMMC as circumstances and timelines change.

Never has the protection of data been more important, and the threats against it more present. Cyber breaches not only affect an organization’s bottom line but can negatively impact its reputation and brand. We help strengthen your organization with a comprehensive program of security technology, services and insurance. We customize your solution based on your specific needs and risks, as well as your line of business, industry and budget.

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Recent Court Cases that Impact Government Contractors: Pre-Award Bid Protests, Monitoring Compliance with Small Business Set-Aside Programs and Vetting Potential Business Partners

Eric Poppe, a senior manager in Cherry Bekaert’s Government Contracting Industry practice and Ryan Bradel, a partner and leader of Ward & Berry’s Government Contracts practice, discuss recent court cases that impact government contractors. Eric & Ryan walk through cases pertaining to protests and solicitations requirements, discussing each ruling, its impacts and lessons learned, so that contractors can gain a better understanding of the rulings and how to better navigate these situations.

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Listen to Susan Moser, leader of Cherry Bekaert’s Government Contractor Services practice and Brendan Halloran, a new member of our team discuss best practices when working with Contracting Officers, including what contractors may be surprised to know.

Before to joining Cherry Bekaert, Brendan spent 10 years at the Defense Contract Management Agency (DCMA) as a Divisional Administrative Contracting Officer (DACO) and supervisory contract specialist focused on cost and pricing. He was the Cognizant Federal Agency Official for multiple major defense contractor business divisions, responsible for ensuring compliance with FAR, Defense Federal Acquisition Regulation Supplement and CAS, including business systems requirements, and brings a unique perspective to the Firm’s government contracting advisory team.

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Part IV: How to Prepare for a CMMC C3PAO Assessment for Certification

Join Cherry Bekaert, a Registered Practitioner Organization (“RPO”) and one of the first Certified Third-Party Assessment Organizations (C3PAO) accredited to perform certification assessments for the Department of Defense’s (“DoD”) new Cybersecurity Maturity Model Certification (“CMMC”) program, for part four of our podcast series discussing the various elements of CMMC.

Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, leads the series along with Eric Poppe from the Firm’s Government Contractor Services Group, to provide contractors with the latest information on CMMC and navigating its impact on the government contracting community.

In part four of the series, Neal and Eric discuss how best to prepare for a CMMC C3PAO assessment for certification. As part of this podcast they discuss:

Current Status & Estimated Timeline
Preparing for Assessments: Three-Phased Approach
Types of evidence needed to obtain a certification
Independence Considerations

If you haven’t already, catch up on the series:

Part 1: Current State of CMMC
Part 2: CMMC and the DFARS Clause
Part 3: What to Expect in an Upcoming CMMC C3PAO Assessment & How to Prepare

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Part Three - What to Expect in an Upcoming CMMC C3PAO Assessment & How to PrepareJoin Cherry Bekaert’s Government Contractor Services Group for part three of our podcast series discussing the Department of Defense’s (“DoD”) new Cybersecurity Maturity Model Certification (“CMMC”).

Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, leads the series along with Eric Poppe from the Firm’s Government Contractor Services Group, to provide contractors with the latest information on CMMC and navigating its impact on the government contracting community.

In part three of the series, Neal and Eric continue their discussion on what you can expect in an upcoming CMMC Certified Third Party Assessment Organization (“C3PAO”) assessment for certification and how best to prepare now. As part of this podcast they will:

Provide an overview of the assessment process
Discuss types of evidence needed to obtain a certification
Walk through the process of remediating findings
Discuss the dispute resolution process put in place by the CMMC-AB

If you haven’t already, catch up on part one and two of the series:

Part 1: Current State of CMMC
Part 2: CMMC and the DFARS Clause

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Part Two - CMMC and the DFARS Clause

Join Cherry Bekaert’s Government Contractor Services Group for part two of a new podcast series discussing the Department of Defense’s (“DoD”) new Cybersecurity Maturity Model Certification (“CMMC”).

Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of the first Provisional Assessors nationwide by the CMMC Accreditation Body, leads the series along with Eric Poppe from the Firm’s Government Contractor Services Group, to provide contractors with the latest information on CMMC and navigating its impact on the government contracting community.

In part two of the series, Neal and Eric continue their discussion on the recent Defense Federal Acquisition Regulation Supplement (“DFARS”) interim rule, Assessing Contractor Implementation of Cybersecurity Requirements, breaking down the components of the rule and the level of assessments, as well as providing some insight into assessors and a discussion of potential next steps.

If you haven’t already, catch up on part one of the series:

Part 1: Current State of CMMC

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For government contractors, timekeeping is more than an administrative headache. It is one of the core processes to ensure proper compliance, collection and allocation of labor when performing work on a government contract. Eric Poppe, Senior Manager and Javier Diaz, Manager in Cherry Bekaert’s Government Contractor Services group discusses timekeeping best practices, controls and why a proper timekeeping system is essential for doing business with the Federal government.

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Part One - Current State of CMMC

Join Cherry Bekaert’s Government Contractor Services Group for part one of a new podcast series discussing the Department of Defense’s (“DoD”) new Cybersecurity Maturity Model Certification (“CMMC”). The CMMC landscape has been taking shape and changing over the past few years and is approaching the finish line.

Neal Beggan, a Principal in Cherry Bekaert’s Information Assurance & Cybersecurity Practice, selected as one of 72 Provisional Assessors in the country by the CMMC Accreditation Body, will lead this series along with Eric Poppe from the Firm’s Government Contractor Services Group, to provide contractors with the latest information on CMMC and navigating its impact on the government contracting community.

In part one of the series, Neal and Eric will discuss:

Current state of CMMC
Interim Rule Change
Current state of CMMC assessments
Tips and advice to government contractors hoping to become certified

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Are you thinking about an Employee Stock Ownership Plan (ESOP) or wondering how they work? Susan Moser, Partner, and John Carpenter, Principal, in Cherry Bekaert’s Government Contractor Services Group discuss ESOPs, including the top 5 reasons an ESOP makes sense, the challenges in becoming an ESOP and common myths and questions asked from government contractors considering an ESOP.

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Contracting officers have been known for incorrectly including clauses into contracts. John Carpenter and John Ford, members of Cherry Bekaert’s Government Contractor Services Group, discuss the clauses that should be (and should not be) included in contracts for Commercial Items.

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Each Agency and Contracting Officer is unique. However, there are common issues that continuously pop up and may delay responses/actions from Contracting Officers. In this podcast, Eric Poppe, Senior Manager and Javier Diaz, Manager in Cherry Bekaert’s Government Contractor Services Group discuss some of these issues.

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On March 27, 2020, the Department of Defense (“DoD”) issued a class deviation in response to Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which allows agencies to reimburse, at the minimum applicable contract billing rates for government contractors to be at a ‘ready state.’ Recently, DoD issued a draft checklist outlining the requirements to seek reimbursement.

Eric Poppe, Senior Manager in Cherry Bekaert’s Government Contractor Services Group is joined by Ryan Bradel, Partner at Ward & Berry for a discussion the draft checklist and reimbursement, and the implications on direct and indirect rates, how to communicate with your contracting officer and other items government contractors should consider.

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As May wraps up, there is a deadline looming for many government contractors. Eric Poppe and Javier Diaz, members of Cherry Bekaert's Government Contractor Services Group talk about preparing and submitting your annual Incurred Cost Submissions (ICS). An ICS is due six months after the end of your fiscal year and is based on the requirement of the Allowable Cost and Payment Clause. Discussion includes items required to compile your indirect rates, documents needed to prepare the submission, the submission process and potential pitfalls so you are on the lookout prior to submission to DCAA.

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A basis of estimate is that backbone to every price estimate submitted to the government. In this Cherry Bekaert GovCon podcast, Eric Poppe, Senior Manager and Javier Diaz, Manager in Cherry Bekaert’s Government Contractor Services Group discuss the common methodologies and basis of estimates used for various cost elements normally included in proposals.

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The new Cybersecurity Maturity Model Certification (“CMMC”) that will be required for ALL DoD contractors is quickly approaching!

This new certification will require all Department of Defense (“DoD”) contractors, both contractors and suppliers, to meet a certain level of cybersecurity controls from the CMMC framework in order to respond to any DoD RFP. The full Version 1.0 is scheduled to go live in January and CMMC requirements will start showing up in RFIs as early as next May and then in RFPs next Fall.

DoD issued the first publicly released version of the framework for comment in September 2019. Draft, Version 0.6, was publicly released in November and it is anticipated that version 0.7 will be released this month as well as formation of the CMMC Accreditation Body.

Neal Beggan, Principal in Cherry Bekaert’s Cybersecurity Services Practice, joins Eric Poppe in the Firm’s Government Contracting Services Practice, for a discussion on what the CMMC requirement is, who it applies to and what companies can do now to prepare.

We have already started helping clients get ahead of CMMC and are scheduled to host a webinar on the topic on January 8th. Click here to learn more about the webinar and/or to register. Please contact Neal Beggan nbeggan@cbh.com with any questions.

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John Carpenter and Curt Smith discuss some of the most common reasons contractors are not successful in getting their accounting system deemed adequate when going through a DCAA audit.

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If you are a contractor or subcontractor dealing with the DoD, listen to Susan Moser and Neil Beggan from Risk Advisory discuss NIST 800-171 requirement, who it applies to and when companies need to be in compliance.

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Danielle DeSonia joins a roundtable of govcon consultants including John Carpenter, Curt Smith, Eric Poppe, and Javier Diaz, to discuss signs you have outgrown your accounting system. If you have a more basic system, increasing organizational complexity or contract types, a switch may be worth it in the end.

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Craig Hunter and John Carpenter discuss some of the changes to Veterans Preference program. Recent streamlined requirements now make it easier to remain compliant. Listen now to gain insight on changes that may affect your business.

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The Wayfair decision overturned the need for physical presence in collection of state tax. How does this impact government contractors? This decision has consequences outside of what you may think. Partners Susan Moser and Cathie Stanton weigh in on how Wayfair can impact your government contracting and sales.

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Due to unforeseen compliance audit requirements, for-profits companies are having their provisional and final rates held by the government. Why does a for-profit entity need to conduct a single or compliance audit? Partner Brynn McNeil explains why the government requires certain for-profits to conduct program-specific or compliance audits. Tune in to determine whether your company could be affected.

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Is your business in growth-mode? John Carpenter and Susan Moser discuss financial and other challenges companies encounter when experiencing growth. Remain competitive and stay abreast of new topics and considerations with this podcast.

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Now is a great time to consider incurred cost submissions for government contractors. In the first of our government contracting podcasts, senior manager Eric Poppe and manager Javier Diaz share valuable insight to help accountants handle incurred cost submission requests.

Cherry Bekaert: Government Contractors Guidance: Recent Episodes

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