On May 18, 2011, the DoD released an interim Business Systems rule with request for comments. 76 Fed. Reg. 28856. Comments are due July 18, 2011. The current version of the rule reflects comments received on the prior two proposed Business Systems rules (published January 15, 2010 and December 3, 2010), requirements in the National … Continue Reading
Due to the scrutiny and criticism DCAA received from the Government Accountability Office in 2008 and 2009, DCAA took a number of steps to address the problems identified by GAO, many of which were intended to address the finding that DCAA auditors lacked independence. The emphasis in resulting DCAA audit guidance on auditor independence has created … Continue Reading
The Federal Circuit in its March 19, 2010 decision in ATK Thiokol, Inc. v. United States (.PDF), expanded the definition of allowable Independent Research and Development (IR&D) costs. Now, research and development costs are allowable as IR&D costs unless specifically required by the contract. In ATK, the Federal Circuit addressed the “required in the performance … Continue Reading
