Government contract regulatory comment letters

Baker Tilly’s government contracting professionals play active roles in bringing (or trying to bring) common sense and fair dealing to the Government’s rule making process. In their capacity as leaders and participants in several professional or government contracting industry associations, Baker Tilly professionals either lead or meaningfully contribute to comment letters. We have tried to shape some of the most impactful rulemaking of the last decade (click on the title to view comment letter):

DOD Implementation of CARES Act Sec. 3610 | May 22, 2020 
Draft DOD Process Guidance & Checklist for Section 3610 Reimbursement
American Bar Association, Public Contract Law Section (ABA PCLS)

DOD CARES Act Sec. 3610 FAQs #9 & #10 | April 24, 2020
Proposed Guidance to Clarify Direct vs. Indirect Accounting for Paid Leave
N/A – Baker Tilly commented directly

DOD CARES Act Sec. 3610 FAQ #23 | April 24, 2020
Proposed Clarification and Correction of the term “Credits”
N/A – Baker Tilly commented directly

DOD Implementation of CARES Act Sec. 3610 | April 7, 2020
Proposed Implementing Clause & Prefatory Comments
N/A – Baker Tilly commented directly

Guidance for Grants and Agreements (Public Disclosure of Indirect Cost Rates) | March 24, 2020
OMB Proposed Guidance (Docket no. 2019-OMB-0005)
National Defense Industrial Association (NDIA)

Market Research and Value Analysis for the Determination of Price Reasonableness | December 5, 2019
DFARS Proposed Rule (DFARS Case 2019-D027)
American Bar Association, Public Contract Law Section (ABA PCLS)

Conformance of the Cost Accounting Standards to Generally Accepted Accounting Principles (CAS 408 & 409) | June 7, 2019
CASB Staff Discussion Paper (CASB Case 2019–01)
American Bar Association, Public Contract Law Section (ABA PCLS)

Department of Defense Guidebook for the Acquisition of Commercial Items, Part A Commercial Item Determination and Part B Commercial Pricing | May 1, 2017
DOD Draft Policy Guidance
American Bar Association, Public Contract Law Section (ABA PCLS)

Procurement of Commercial Items | October 12, 2016
DFARS Proposed Rule (DFARS Case 2016-D006)
American Bar Association, Public Contract Law Section (ABA PCLS)

Cost Accounting Standards Administration | April 11, 2016
GSA Information Collection 9000-0129
National Defense Industrial Association (NDIA)

Department of Defense Contractor Business Systems Audits Performed by Independent Public Accounting Firms | September 15, 2014
DFARS Proposed Rule (DFARS Case 2012-D042)
American Institute of Certified Public Accountants (AICPA)

Department of Defense Contractor Business Systems (Accounting, Estimating, MMAS, Government Property, EVMS, Purchasing) | January 10, 2011
DFARS Proposed Rule [Revised] (DFARS Case 2009-D038)
Council of Defense and Space Industry Associations (CODSIA)

Elimination of the CAS exemption for contracts executed and performed entirely outside of the United States | December 20, 2010
CASB Notice of Proposed Rulemaking
National Defense Industrial Association (NDIA)

Department of Defense Contractor Business Systems (Accounting, Estimating, MMAS, Government Property, EVMS, Purchasing) | March 16, 2010
DFARS Proposed Rule (DFARS Case 2009-D038)
Council of Defense and Space Industry Associations (CODSIA)

Elimination of the CAS exemption for contracts executed and performed entirely outside of the United States | December 9, 2009
CASB Request for Information
National Defense Industrial Association (NDIA)

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