Cherry Bekaert: Government Contractors Guidance

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

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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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.

View all Government Contracting Podcasts

Contractors with the Federal Acquisition Regulation (FAR) Clause 52.216-7, Allowable Cost and Payment included 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

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: 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

View all Government Contracting Podcasts

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

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.

View all Government Contracting Podcasts

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

View All Podcasts from this Series. 

View all Government Contracting Podcasts

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 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

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.

View all Government Contracting Podcasts

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

View all Government Contracting Podcasts

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 and Information Technology Audit Group, 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.

View all Government Contracting Podcasts