As you know, the NACM Government Business Group will wind down its activities on December 31, 2012 which means that the time has come for me to bid you farewell, as this is our last newsletter. I have enjoyed working with so many of you through our workshops and helpline. The Government Business Group was always there for me when I needed help to understand how to get paid by Uncle Sam, so this goodbye is bittersweet. Through the years, the Government Business Group has done so much to help change the way the government sees contractors and has helped guide the government in adopting regulations and rules to improve the way businesses sell to it. I am proud to have been a part of such a great organization as NACM and hope that all of you will continue to seek out NACM membership through a local NACM affiliate.
This may not be the last you hear from me as I will continue to monitor government alerts and provide articles and resources for Business Credit magazine as topics warrant.
So long my dear friends,
Subcontractor Pay Finally Sees FAR Help
During the past several years, there has been heightened activity and oversight regarding contractor late payments or non-payments to subcontractors. In a November 5, letter from the American Subcontractors Association to the General Services Administration, the organization justified their concern about the issues of payments from prime contractors. The proposed FAR changes to Subpart 42.15 require that all federal agencies "prepare an evaluation of contractor performance for each contract that exceeds the simplified acquisition threshold at the time work under the contract is completed." Moreover, FAR 42.1503(c) requires federal agencies to share this information when requested by another agency. The evaluation on prime contractors covers the following areas:
For the first time, the evaluation will also include payments to subcontractors. This is a win-win for both subcontractors and prime contractors. If you are a prime contractor that pays your subcontractors on time, this will help with the Contractor Performance Assessment Reporting evaluations from the government.
Who is the DCAA?
The Defense Contract Audit Agency performs all needed contract audits for the Department of Defense. The DCAA also provides accounting and financial advisory services regarding contracts and subcontracts to DoD. DCAA identifies and evaluates contractors' financial policies, procedures and internal controls. They perform audits that identify opportunities for contractors to reduce or avoid costs. According to FAR 15.40, DCAA may request data for active DoD vendors for the purpose of review or audit. It is important that the contractor be familiar with DoD audit procedures. More information can be found on the DCAA website www.dcaa.mil.
MOCAS WAWF Reject Request
If a contractor decides an invoice was incorrectly sent through WAWF (MOCAS invoices only), the contractor can request for the invoice to be rejected by emailing CCO-DFAS-CS-MOCAS-REJECTS@DFAS.MIL">CCO-DFAS-CS-MOCAS-REJECTS@DFAS.MIL.All requests should include the pay office, contract number and delivery order numbers, if applicable, on the subject line. The shipment number and the actual rejection request should be keyed into the body of the email request. It must match WAWF, otherwise DFAS will not be able to retrieve the information.