Article by Dentons

The Department of Defense (DOD) earlier today issued an interim rule, effective immediately, that significantly increases existing cybersecurity requirements for DOD contractors. The requirements in the interim rule, available here, have broad applicability to DOD contractors at both the prime and subcontract levels, including commercial item and small business contractors. Contractors can expect these requirements to begin showing up in new DOD contracts immediately and should begin taking steps to ensure compliance.

The interim rule contains a number of new and revised DOD cybersecurity requirements. The key issues are summarized below.

Scope of the DOD requirements

The interim rule significantly expands the scope of the prior unclassified c...

FAR compliance is important regardless of DCAA being involved, as it is still required by your contract, and good accounting is inherent to good business practices.

Ensuring compliance related to DCAA requirements will allow your business to continue a successful relationship with the government, while avoiding: repayments, penalties, delay or loss of contract and wasted resources on administrative duties.

Arrowhead can help on an as-needed basis for:

Important Update

52.237-10 -- Identification of Uncompensated Overtime.

As prescribed in  37.115-3 , insert the following provision:

Identification of Uncompensated Overtime (Mar 2015)

(a)  Definitions . As used in this provision --

“Adjusted hourly rate (including uncompensated overtime)” is the rate that results from multiplying the hourly rate for a 40-hour work week by 40, and then dividing by the proposed hours per week which includes uncompensated overtime hours over and above the standard 40-hour work week. For example, 45 hours proposed on a 40-hour work week basis at $20 per hour would be converted to an uncompensated overtime rate of $17.78 per hour ($20.00 x 40 divided by 45 = $17.78).

“Uncompensated overtime” means th...

Most likely, your answer to this question is, “I don’t know”.

It's often the case that a company thinks maybe they could be ready for a DCAA audit, but has little confidence that they would pass. On the other end of the spectrum, are you a company who thinks you're definitely ready for DCAA because you have an expensive or robust accounting and/or timekeeping system?

Unfortunately, if you never had DCAA in your office before, then you probably are not ready, regardless of your systems.

Contrary to what you may have heard, you cannot “buy” a DCAA-approved accounting system. No accounting or timekeeping system has ever, or will ever, receive DCAA’s stamp of approval. As a government agency, they will not endorse a product in that manner. In a...