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Category Archives: Cost Accounting

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DoD White Paper Takes Aim at IR&D Costs

Posted in Cost Accounting
While DOD’s August 26 white paper “Enhancing the Effectiveness of Independent Research and Development” explains that the intent of new requirements announced in the white paper is “not to reduce the independence of IR&D investment selection, nor to establish a bureaucratic requirement for government approval prior to initiating an IR&D project,” contactors have good reason to doubt… Continue Reading

Bad News for Contractors: ASBCA Decision Bars Offsets of Simultaneous Accounting Changes Under FAR 30.606

Posted in Claims, Cost Accounting
In Raytheon Co., ASBCA Nos. 57801 et al. (May 7, 2015), the Board held that under FAR 30.606 contractors may not offset cost impacts from simultaneous accounting changes within the same business segment, which if not reversed on appeal will cause major disruptions when contractors make multiple changes in cost accounting practices made after 2005 (the date of the FAR change),… Continue Reading

DCAA Issues (Mis)Guidance on Expressly Unallowable Costs

Posted in Cost Accounting
On January 7, 2015, DCAA issued guidance to auditors for determining whether certain costs are “expressly unallowable” – and therefore subject to penalties – even when the regulations “do not state in direct terms that the cost is unallowable.” This guidance, which is intended to “enhance” the equally troubling December 18 guidance to similar effect,… Continue Reading

Join Us for a Legal and Accounting Webinar

Posted in Cost Accounting
On Wednesday, July 23rd from 11:30 am -1:30 pm, Cathy Kunz will join Rubino & Company to discuss critical issues in cost law. As contractors face more scrutiny and review of their cost and accounting practices, we will address recent cost-related court decisions and legal changes including the new caps on executive compensation, application of… Continue Reading

Join Us For a Cost and Accounting Roundtable

Posted in Cost Accounting
On April 2nd, Cathy Kunz joins Paul Calabrese of Rubino & Company for an important roundtable for government contractors. During this ½ day presentation sponsored by Bank of America and Merrill Lynch, participants will get both the legal and accounting perspective. From the legal side, Cathy will review recent cost-related court decisions and legal changes,… Continue Reading

Applicable Statute of Limitations for CAS Violations Comes into Focus

Posted in Claims, Cost Accounting
The Contract Disputes Act, 41 U.S.C. §§ 7101-7109, sets forth certain prerequisites for the exercise of jurisdiction over claims. Among these prerequisites is a six-year statute of limitations, which is applicable to Government and contractor claims alike. With few exceptions, claims submitted more than six years after “accrual” are not valid and cognizable under the… Continue Reading

Interim Business Systems Rule Issued

Posted in Cost Accounting
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

Expanded Definition of Allowable IR&D Costs

Posted in Cost Accounting
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