FAR and Beyond Blog
This week the FAR & Beyond blog is dedicated to the Fourth of July. The blog highlights a speech given by President Abraham Lincoln during the Civil War.
On July 4th, 1863, Confederate forces at Vicksburg, Mississippi surrendered to the Union Army of the Potomac, a major military victory for the North during the Civil War. Word of Vicksburg’s surrender did not reach Washington until the day of July 7th. The news quickly spread throughout the District, and a military parade to the White House was organized by officers of the Massachusetts Thirty-Fourth Regiment, accompanied by a crowd numbering in the thousands. President Lincoln, who had refrained from publicly celebrating Independence Day on the Fourth while the fate of Vicksburg was uncertain, felt compelled to address the assembled citizens, bands and soldiers. Around 8:30 PM, Lincoln appeared at the window of the portico of the White House, and issued this speech (as reported by the Washington Evening Star, July 8, 1863):
“Fellow-citizens: I am very glad to see you to-night. But yet I will not say I thank you for this call. But I do most sincerely thank Almighty God for the occasion on which you have called. How long ago is it? Eighty odd years since, upon the Fourth day of July, for the first time in the world, a union body of representatives was assembled to declare as a self-evident truth that all men were created equal.
That was the birthday of the United States of America. Since then the fourth day of July has had several very peculiar recognitions. The two most distinguished men who framed and supported that paper, including the particular declaration I have mentioned, Thomas Jefferson and John Adams, the one having framed it, and the other sustained it most ably in debate, the only two of the fifty-five or fifty-six who signed it, I believe, who were ever President of the United States, precisely fifty years after they put their hands to that paper it pleased the Almighty God to take away from this stage of action on the Fourth of July. This extraordinary coincidence we can understand to be a dispensation of the Almighty Ruler of Events.
Another of our Presidents, five years afterwards, was called from this stage of existence on the same day of the month, and now on this Fourth of July just past, when a gigantic rebellion has risen in the land, precisely at the bottom of which is an effort to overthrow that principle “that all men are created equal,” we have a surrender of one of their most powerful positions and powerful armies forced upon them on that very day. And I see in the succession of battles in Pennsylvania, which continued three days, so rapidly following each other as to be justly called one great battle, fought on the first, second and third of July; on the fourth the enemies of the declaration that all men are created equal had to turn tail and run.
Gentlemen, this is a glorious theme and a glorious occasion for a speech, but I am not prepared to make one worthy of the theme and worthy of the occasion. I would like to speak in all praise that is due to the the [sic] many brave officers and soldiers who have fought in the cause of the Union and liberties of this country from the beginning of this war, not on occasions of success, but upon the more trying occasions of the want of success. I say I would like to speak in praise of these men, particularizing their deeds, but I am unprepared. I should dislike to mention the name of a single officer, lest in doing so I wrong some other one whose name may not occur to me.
Recent events bring up certain names, gallantly prominent, but I do not want to particularly name them at the expense of others, who are as justly entitled to our gratitude as they. I therefore do not upon this occasion name a single man. And now I have said about as much as I ought to say in this impromptu manner, and if you please, I’ll take the music.”
– President Abraham Lincoln
How will teaming, strategic sourcing and proposed changes to the federal small business programs impact your business? This forum is excellent way for small businesses and small business program managers within large companies to get up to date on key initiatives impacting performance in the federal market. The speakers include key players from the Hill and government agencies, as well as companies with real world experience selling to federal agencies. See below for more details!
Keynote: On the Hill – How the legislative agenda will affect strategic sourcing and other federal initiatives impacting the small business community
- Emily Murphy, Senior Counsel, House Committee on Small Business
Panel: Contractor Teaming Arrangements and Joint Ventures, from Formation to Payment – what they are; how they really work; what’s the benefit. Have your questions answered by a panel with hands on experience
- Kenneth Dodds, Director, Small Business Administration
- Joseph Hornyak, Partner, Holland and Knight, LLP
- Mark Lee, Deputy Director, GSA, Office of Governmentwide Policy
- Marian Morley, Vice President, Government Sales & Operations, Allsteel
- Jim Connal, Vice President, Contracts and Compliance – Red River Computing (Moderator)
- Tom Walker, Government Manager – Nucraft, Furniture (Moderator)
Time: 8:00AM – 11:30AM
8000 Towers Crescent Dr #1700, Vienna, VA 22182
Keystone Member: Complimentary
Premier Member: $65
Click HERE to Register!
Join the FSSI HR Services and Training (HRST) Working Group
The Coalition will provide feedback to GSA on the FSSI acquisition strategy for Human Resources and Training and Capital Management. This is a joint GSA/OPM initiative which will replace OPM’s existing Training and Management Assistance (TMA) contract vehicle. If you are interested in participating in the Coalition’s working group, please send an email to Aubrey at email@example.com.
On June 30th, President Obama nominated former Proctor and Gamble CEO Robert McDonald to become the next Secretary of the Department of Veterans Affairs (VA). McDonald, a graduate of West Point, served as P&G’s CEO until his resignation in 2012. McDonald is expected to face a relatively easy Senate confirmation hearing, as both parties have urged to quickly fill the vacancy caused by General Eric Shinseki’s resignation as Secretary.
McDonald’s experience as a business leader sets him apart from other VA Secretaries, whom usually have a military or healthcare background. McDonald’s nomination has already brought much praise from members of Congress and outside organizations, who say that his skill set as a business executive can help the VA undergo what is expected to be a significant top-to-bottom overhaul.
The Facilities Maintenance and Hardware Acquisition Center (FMHAC) has released a newsletter containing some important updates for members. FMHAC Director Debbie Harms noted that the move to consolidate three program areas—Schedules, FSSI, and Supply—is continuing in accordance with the new FSA strategy category management. The category for FMHAC is the Integrated Facilities Management and Industrial Products Solutions (IFMIPS) category. IFMIPS covers all the products and services of a vendor’s current 51V and 03FAC Schedules, the Heartland Supply Operations Center offerings, and the Maintenance Repair and Operations (MRO) Products and Building Maintenance and Operations (BMO) Strategic Sourcing Initiatives. According to Debbie Harms, vendors will have continued opportunities out of the same office they currently have a contract in and will be positioned for new opportunities as category offerings are fully developed.
Additionally, the latest refresh to the Schedule 51V solicitation and MASS Mod A366, issued May 12, 2014 now requires contractors to be in compliance with Military Standard 129. This means that any military activity who receives an order should receive it with MIL 129 Marking. GSA also noted that in recent conversations with DoD, suppliers/contractors are not always meeting this requirement. GSA urges vendors to speak with their Contracting Officer about this matter immediately to ensure that shipments to military activities are marked appropriately.
DAPA Holders are Caught in the Middle of a Disagreement between the VA and DLA over the Application of the IFF to DAPA Sales
By Jack Horan, Partner, McKenna Long & Aldridge LLP
Sales to the Department of Defense under its Distribution and Pricing Agreement program are very important to many VA FSS contractors. The VA, itself, views DAPA sales as integral to the success of VA Schedule contracts, telling contractors that “success of your VA FSS contract requires the development of a strong federal customer base and active promotion of your business to these customers” and “[p]articipation in the Defense Logistics Agency’s (DLA) Troop Support Distribution and Pricing Agreements (DAPA) program is a surefire way to penetrate the federal healthcare marketplace.” See VA FSS eNewsletter, No. 55 (March 2014) at 1
Despite the importance of these sales to VA FSS contractors, DOD and the VA are in the midst of a disagreement over whether VA FSS contractors are required to pay the industrial funding fee on sales of items through the DAPA when those items are also listed on the contractor’s VA Schedule Contract. The VA’s position is explicitly set forth in a somewhat unusual appendage to the standard Industrial Funding Fee and Sales Reporting Clause, GSAR 552.238-74, included in VA Schedule contracts:
NOTICE REGARDING DISTRIBUTION AND PRICING AGREEMENTS (DAPA)
If your firm has a DAPA with the Department of Defense, items available therein that are also awarded under FSS contract must, during the course of the FSS contract, be reported as FSS sales and included in quarterly FSS Sales Reports and Industrial Funding Fee (IFF) remittance.
See, e.g. RFP 797-FSS-99-0025-R9, Solicitation Document at 38.
The VA recently confirmed (and justified) its position that FSS Contractors must pay the IFF on DAPA sales in its FSS eNewsletter:
One of the questions we most often receive is “I have a DAPA, do I need to report those sales on my quarterly sales report?” In 1999, DoD and the VA signed a memorandum of understanding indicating that FSS pricing is the preferred method of pricing for products identified on DAPAs and as such sales for items awarded under a VA FSS contract that are also available under a DAPA must be reported as FSS sales.
Any delivery/task order placed against a VA Schedule contract – whether for a base contract item, blanket purchase agreement, or DAPA, is a reportable sale and must be included in the quarterly sales report & IFF payment. Additionally, all sales made to agencies other than the VA, state & local governments, and through prime vendor programs & direct-to-patient distribution must be reported. Direct all FSS sales reporting & IFF remittance questions to the VA Sales Desk.
See VA FSS eNewsletter, No. 55 (March 2014) at 5 (emphasis in original).
So the VA’s answer is a firm “yes” – VA Schedule contractors must pay the IFF on DAPA sales. Based on the VA’s eNewsletter, the VA appears to believe it has two justifications for the requirement: (1) a 1999 memorandum of understanding with DOD; and (2) its apparent view that items purchased under a DAPA is “placed against a VA Schedule contract.” Id.
A major problem with the VA’s position is that DOD apparently does not agree. The Defense Logistics Agency, the DOD Executive Agent for Medical Material. responsible for administration of DAPAs, is instructing its DAPA holders not to pay the IFF for sales to prime vendors under a DAPA:
The following is specific DAPA guidance:
• There is no direct relationship between a Federal Supply Schedule (FSS) and DAPA.
• A DAPA does not require a vendor to establish or have a FSS.
• Prime Vendor contracts are separate acquisitions and sales thereunder using the DAPA catalogue do not require reporting or payment through the Department of Veterans Affairs (DVA) Industrial Funding Fee (IFF) process.
Any DAPA holder given contrary guidance should immediately contact DLA.
See DLA Memorandum to Prime Vendor DAPA Program, found at https://www.medical.dla.mil/Portal/.
DLA views DAPAs as “DLA pricing vehicles used to establish and manage pricing with manufacturers and/or distributors for medical material purchased under DLA’s Prime Vendor contracts” rather than orders “placed against a VA Schedule contract,” Compare, id and VA FSS eNewsletter at 5. DLA also sees its Prime Vendor contracts – “FAR Par 12 acquisitions that use pricing vehicles such as DAPA under FAR Part 16 as single source awards within a region” — as separate from VA’s FSS contracts. Id. Thus, these opposite views on the IFF grow out of a fundamentally different view of the role of VA Schedule contracts in DAPA orders. VA views the DAPA orders as “placed against” Schedule contracts while DLA views them as placed under DLA’s Prime Vendor contracts independent of the VA’s Schedule contracts. In its instruction to DAPA holders, DLA does not address the 1999 memorandum referenced in the VA’s eNewsletter.
So, FSS contractors with a DAPA, at least for now, are caught between the conflicting views of the VA and DLA – one telling them that they have to pay the IFF and the other telling them that they should not. Each relying on a fundamentally different view of the status of orders placed through DLA Prime Vendors based on DAPA pricing.
Moreover, a contractor faces risk in following either position. By excluding DAPA sales from the IFF, as instructed by DLA, the contractor risks a claim by the VA that it is not complying with its FSS contract, or worse, a potential claim under the False Claims Act. By paying the IFF, the contractor faces at least the financial risk of paying a fee that it is not obligated to pay. To the extent the fee is included in the cost in its DAPA, the DAPA holder also faces a potential request for a price reduction under the DAPA to eliminate the IFF. Given these risks, the VA and DLA have an obligation to their contractors to resolve this issue.
VA and DLA are involved in a discussion of these issues and we hope to report a resolution soon.
Important Decision Impacting Government Contractors
IN RE: KELLOGG BROWN &ROOT, INC., (KBR) (D.C. Circuit June 27, 2014)
This week the court decided a significant case for government contractors. The case is important because a contrary ruling would have eliminated the attorney-client privilege in connection with internal investigations conducted by companies required by law to maintain compliance programs. Given the requirements for compliance plans and mandatory disclosure of FAR Subpart 3.10, Contractor Code of Business Ethics and Conduct, many contractors would have been affected. Because of the potential impact, a number of organizations, including The Coalition for Government Procurement, submitted an amicus brief in support of KBR. The court cited the amicus brief as demonstrating the depth of industry concern with this issue. The following is an analysis of the case from McKenna Long & Aldridge. We suggest that you share it with your corporate attorneys and internal audit staff.
D.C. Circuit Upholds the Attorney-Client Privilege for Corporate Internal Investigations
By: Kwamina Thomas Williford, Partner, McKenna Long & Aldridge and Robert Tompkins, Partner, McKenna Long & Aldridge
On June 27, 2014, the U.S. Court of Appeals for the D.C. Circuit granted Kellogg Brown & Root’s (KBR) petition for a writ of mandamus and vacated the District Court’s order in United States ex rel. Barko v. Halliburton Co., No. 05-cv-1276, 2014 WL 1016784 (D.D.C Mar. 5, 2014) compelling KBR to produce internal investigation documents. In Re: Kellogg Brown & Root, Inc., No. 1:05-cv-1276 (D.C. Cir. June 27, 2014). The D.C. Circuit’s ruling has upheld important protections for companies conducting internal investigations pursuant to statute or regulation, and affirmed the continued vitality of the Supreme Court’s decision in Upjohn Co. v. United States, 449 U.S. 383, 389 (1981) for companies claiming the attorney-client privilege.
District Court Proceedings
In Barko, the relator sought documents created by KBR during its internal investigation of the allegations that are the basis for the relator’s qui tam case. KBR’s legal department oversaw the investigation, which was conducted pursuant to KBR’s Code of Business Conduct. KBR asserted the attorney-client privilege over the investigation, arguing that KBR created the documents so that KBR’s internal lawyers could provide legal advice to the company. The relator argued that the documents were not privileged because they were ordinary business records. The District Court applied a “but for” test for determining whether the purpose of the documents was to obtain legal advice – analyzing whether the documents would have been created “but for” the need for legal advice. The District Court reasoned that because regulations and KBR’s own corporate policy required KBR to conduct the investigation, KBR had not created the documents solely to obtain legal advice. The Court concluded that the documents were not privileged because KBR created them to satisfy regulatory and corporate requirements.
KBR immediately requested that the District Court certify the privilege question for interlocutory appeal and to stay its order compelling production pending a petition for a writ of mandamus from the D.C. Circuit. The District Court denied those requests. Left with no other choice, KBR took the extraordinary action of filing a petition for writ of mandamus with the D.C. Circuit. The D.C. Circuit stayed the District Court’s order pending a ruling on the mandamus petition.
D.C. Circuit’s Analysis
KBR had two difficult hurdles to clear to prevail on mandamus – it had to show legal error and that the error justified the extraordinary writ of mandamus. It cleared both of them.
The Circuit found two fundamental legal errors. First, the District Court improperly used a “but for” causation analysis when applying the “primary purpose test.” The correct formulation of the “primary purpose” test requires legal advice to be a significant purpose of the communication. The significant purpose of legal advice is not undermined simply because the internal investigation is also required by statute, regulation or a company’s compliance program.
Second, the District Court misinterpreted Upjohn. The D.C. Circuit noted that Upjohn does not require any of the following for the privilege to apply: (1) the involvement of outside counsel to claim the attorney-client privilege; (2) that attorneys personally conduct employee interviews when the investigation is conducted at the direction of counsel; or (3) the use “magic words” informing employees of the purpose of the interview.
The D.C. Circuit noted that KBR’s assertion of the privilege was “materially indistinguishable” from the basis upheld in Upjohn. As in Upjohn, KBR initiated an internal investigation in response to reports of potential misconduct and as part of a concerted effort to gather facts and ensure compliance with applicable laws and regulations. As in Upjohn, KBR’s in-house legal counsel coordinated the investigation. In short, the Circuit confirmed the continuing validity of Upjohn procedures in establishing the attorney-client privilege.
After finding clear legal error, the D.C Circuit applied the three factors required for mandamus as set forth in Cheney v. U.S. District Court for the District of Columbia, 542, U.S. 367, 380 (2004): (1) no other adequate means to secure the desired relief; (2) the right to relief must be clear and indisputable; and (3) the writ is appropriate under the circumstances. KBR easily met the first two factors. Mandamus provided KBR with the only meaningful remedy. The District Court had denied KBR’s motion for interlocutory appeal, and an interlocutory appeal under the collateral order doctrine is not available for attorney-client privilege orders. An appeal after final judgment would be too late to protect the documents that KBR was ordered to produce. The DC Circuit’s finding of clear legal error itself made KBR’s right to relief clear and indisputable.
The third factor, “a relatively broad and amorphous totality of the circumstances consideration”, also favored KBR. The potential for grave harm to the attorney-client privilege if the District Court’s decision remained in effect made mandamus “appropriate under the circumstances.” Left in place, the District Court’s decision could “work a sea change in the well-settled rules governing internal corporate investigations”:
Because defense contractors are subject to regulatory requirements of the sort cited by the District Court, the logic of the ruling would seemingly prevent any defense contractor from invoking the attorney-client privilege to protect internal investigations undertaken as part of a mandatory compliance program. See 48 C.F.R. § 52.203-13 (2010). And because a variety of other federal laws require similar internal controls or compliance programs, many other companies likewise would not be able to assert the privilege to protect the records of their internal investigations. See, e.g., 15 U.S.C. §§ 78m(b)(2), 7262; 41 U.S.C. § 8703. As KBR explained, the District Court’s decision “would disable most public companies from undertaking confidential internal investigations.” KBR Pet. 19.
Id. at 15. Thus, although not binding, the incorrect “but for” analysis could gain traction in other district courts. To protect against these harms to both KBR and the attorney-client privilege more broadly, the D.C. Circuit granted KBR’s petition for a writ of mandamus.
Government contractors (and the many other companies subject to statutory and regulatory requirements to conduct internal investigations) can now breathe a sigh of relief – the application of the attorney-client privilege to corporate internal investigations required by law or regulation has been vindicated and upheld. Companies following Upjohn procedures can conduct their internal investigations with the assurance that the attorney-client privilege will protect candid and full communications.
DHS S&T: $95M for Cyber Research, Development
According to Federal News Radio, the Department of Homeland Security (DHS) recently released a Broad Agency Announcement (BAA) that provides research and development funds for cybersecurity technologies for the next 3-5 years. The BAA puts up $95 million for R&D, replacing the last BAA that was issued in 2011. The first four cybersecurity areas that DHS’s Science and Technology Directorate (S&T) will focus on are:
- Data Privacy – for federated search, secure messaging, compliance with federal directives and mobile integration.
- Denial of Service – develop metrics for how the government is implementing its Best Common Practice 38 (BCP) for denial of service technologies.
- Mobile Security – add new capabilities on top of commercial devices and other technologies, as well as develop tools to improve the government’s understanding of the security of mobile apps.
- Cyber and Physical System Security Integration – build new securities capabilities, focused primarily on emergency first responder, transportation and healthcare systems.
OMB Call to Eliminate Duplicative Reporting
On June 25th, the Office of Management and Budget (OMB) issued a blog post that asks Congress to continue working on legislation that eliminates unnecessary reporting and planning requirements for a variety of federal agencies. These reporting requirements are either duplicative, pertain to federal programs that don’t exist anymore, or require gathering data that changes little on a year-to-year basis. The Government Performance and Results Modernization Act of 2010 requires the Administration to issue a list to Congress each year of reporting requirements that should be eliminated or somehow modified to promote efficiency and resource savings.
Beth Cobert, OMB Deputy Director for Management writes that Congress agreed to eliminate about half of the 150 reporting requirements recommended by the Department of Defense in the National Defense Authorization Act of 2011 along with additional requirements in the Administration’s 2012 list. OMB released a list to Congress and the public of 74 reporting requirements that they recommend for elimination, consolidation, modification or reduced frequency for Fiscal Year 2015. The list can be viewed here.
GAO on DoD Contract Payments
A recent report from the Government Accountability Office (GAO) has found that the Department of Defense’s Finance and Accounting Service (DFAS) has not implemented guidance to achieve audit readiness. The DFAS is responsible for $200 billion in annual contract payments. The report notes that while the office recognized the importance of implementing a Financial Improvement Plan (FIP) and performed steps required by DoD’s Financial Improvement and Audit Readiness (FIAR), DFAS has not fully implement the steps required by the FIAR Guidance.
GAO found numerous deficiencies in the implementation of DFAS’s contract pay FIP, including:
- DFAS did not adequately perform certain planning activities for its contract pay FIP as required by the FIAR Guidance. For example, DFAS did not obtain sufficient assurance that the contract disbursements are accurately recorded and maintained and that the status of DoD’s contract obligations is accurate and up-to-date.
- DFAS did not adequately perform required testing of its contract pay controls, processes, and balances.
- DFAS did not provide adequate documentation to support that it had remediated all of the identified control deficiencies that DFAS stated had been corrected.
The GAO is recommending that DFAS fully implement the requirements in the FIAR Guidance in the areas of planning, testing and corrective actions. DoD concurred with recommendations.
Sweeping Counterfeit Reporting Proposed Rule
The FAR Council published a proposed rule on June 10th extending certain reporting requirements for contractors beyond what is already required for counterfeit electronic parts to a broader scope of products and services. The proposed rule, titled “Extending Reporting of Nonconforming Items”, is intended to reduce the risk of counterfeit items entering the supply chain by ensuring that contractors report suspect items to a government database. According to an article by Crowell & Moring, “a contractor would be required to report to the contracting officer within 30 days of becoming aware that any ‘end item, component, subassembly, part or material contained in supplies purchased by the Contractor for delivery to, or for the Government is counterfeit or suspect counterfeit’”. It would also require that the contractor report the incidence to the Government-Industry Data Exchange Program (GIDEP) and monitor this site regularly to avoid delivery of any reported items to the government. For more details on the proposed rule, access Crowell & Moring’s article here. Comments on the rule are due August 11, 2014. Members who would like to provide feedback on the rule to the Coalition, please contact Aubrey Woolley at firstname.lastname@example.org.
Two-Part Webinar Series for GSA Schedule Contractors
The Coalition for Government Procurement, in conjunction with Baker Tilly, is pleased to announce an upcoming Two-Part Webinar Series for GSA Schedule Contractors:
The landscape for GSA Schedule contractors has become increasingly difficult. Both products and services contractors are facing new challenges as they negotiate new GSA Schedule contracts or administer their existing GSA Schedule contracts. Pricing, contract terms and conditions, and post-award compliance have all come under the microscope, and contractors must be ready to respond. This two part series will address some of GSA’s and GSA OIG’s recent focal points so that contractors can consider potential impacts to their business and how they can best prepare.
Part 2: Challenges Facing Products Contractors
Thursday, August 14th, at Noon EDT
Presented by Jeff Clayton and Steven Brewer
GSA is facing immense pressure to achieve lower prices for its federal government customers. This has impacted the government’s negotiation tactics and in turn it has impacted, and will continue to impact, products contractors. Prices paid data is being tracked and horizontal pricing comparisons are becoming the norm. Federal Strategic Sourcing Initiatives, an increasingly popular tool for GSA, continue their march across the supply side of the Schedules program. The presentation will discuss all of this and more, including best practices, so that contractors can prepare themselves to respond to these issues.
The Coalition’s Second Annual Joseph P. Caggiano Memorial Golf Tournament
Please join us for The Coalition’s 2nd Annual Joseph P. Caggiano Memorial Golf Tournament on August 27th at Whiskey Creek Golf Club! This charity tournament is to honor our good friend and colleague, Joe Caggiano, who was not only a 23-year veteran of the federal contracting marketplace but a naval veteran as well.
We believe Joe would be proud of the fact this year’s tournament proceeds are going to a brand new cause that will continue to support our nation’s veterans. In honor of the 35th Anniversary of The Coalition for Government Procurement, and in conjunction with The George Washington University, we are creating a scholarship/fellowship to provide financial support to a veteran. Specifically, qualified veterans concentrating their studies in the field of US Government procurement and pursuing the JD or LLM degree in Government Procurement Law or the interdisciplinary Masters of Science in Government Contracting degree (MSGC) at The George Washington University will benefit from the fund as we count on them to become the next generation of skilled professionals leading this critically important sector of the US economy.
Registration will begin at 9:30am with an 11:00am shotgun start, followed by a 4:30 pm post-tournament reception. The tournament will consists of a 4 player scramble with 144 maximum players. Please click here to register your foursome or as an individual golfer!
We have several exciting sponsorships available from title sponsors to beverage cart sponsors to hole sponsors, and also a wide range in pricing so no matter what your budget, you will still have an opportunity to support this wonderful cause. Please click here to review sponsorship opportunities and contact Matt Cahill at email@example.com or 202-315-1054 with any questions or sponsor commitments.
We look forward to your support and a fun and rewarding day for everyone!
DCAA & DCMA Audit & Compliance Boot Camp, July 21-22
American Conference Institute’s 4th
DCAA & DCMA Audit and Compliance Boot Camp
A Practical Course on How to Comply with Strict Cost and Pricing Data Requirements and Prepare for Rigorous Audits
Monday, July 21 to Tuesday, July 22, 2014
InterContinental Chicago Hotel on the Magnificent Mile, Chicago, IL
For 2014, this program has moved to Chicago in response to numerous requests to hold this program in the Midwest. In an era of backlog and government spending cuts, staying current on the latest developments is more important than ever. Unlike other training programs, participants will have the opportunity to delve into cost, pricing and audit requirements, and learn from government and leading companies in a highly interactive setting. The 2014 program has evolved in response to industry feedback and recent developments, with more in-depth sections on the most critical DCAA audit and compliance challenges affecting your business.
ACI Boot Camps are different. This program is advanced and rigorous – designed to provide up to date information through case studies, war stories and best practices. The sessions are at an advanced level but the amount of time dedicated to each topic is longer so you will leave with a much greater understanding of the issues and a plan of action to strengthen your operations when you get back to the office.
DCAA and DCMA have also offered their robust support of this event. There is no replacement for face-to-face discussion and Q & A with key agency decision-makers. Few events offer you the opportunity to hear directly DCAA and DCMA.
You can also benchmark and network with industry leaders, who have track records of successfully navigating DCAA audits and meeting the agency’s compliance expectations: DRS Technologies, The Boeing Company, FLIR Services, Oshkosh Defense, Rolls-Royce North America, The Louis Berger Group, and ULA Launch.
Group pricing is available. Send your entire team and register early as seats at this event are expected to fill to capacity.
Registrations will be taken on a first come, first served basis. Call 1-888-224-2480; fax your registration form to 1-877-927-1563 or register online at www.AmericanConference.com/DCAABootCamp.