Posts by Jennifer Eubanks

Summary of Keypoints A Forward Pricing Rate Proposal (FPRP) establishes pre-reviewed indirect rates for future proposals and billing, allowing contractors to avoid rebuilding rate justifications for every bid and giving contracting officers confidence in pricing for cost-reimbursement, T&M, and IDIQ contracts. An FPRP is built on verifiable historical cost data adjusted for documented future changes,…

Summary of Keypoints FAR and CAS compliance governs nearly every financial aspect of government contracting, including allowable costs, indirect rate structures, proposal pricing, billing practices, audit standards, and accounting system design, making it the foundation of whether and how contractors get paid. Contractors often treat compliance as an afterthought, delaying attention until audits, questioned costs,…

Summary of Keypoints Cost proposals and pricing proposals are not interchangeable, and submitting the wrong one is a common reason for proposal rejection, even when the numbers themselves are reasonable. Cost proposals require full cost transparency and detailed buildup, including labor by category and hour, fully supported indirect rates, subcontractor cost data, other direct costs…

Summary of Keypoints Historical cost data is the foundation of defensible forward pricing, because FAR 15.404-1 requires agencies to assess cost realism by comparing proposed costs to verifiable past performance, not estimates or intuition. Well-maintained historical costs reveal true cost behavior, including actual labor productivity, indirect rate trends, differences between contract types, and subcontractor or…

Summary of Keypoints The most common proposal pricing failures stem from misunderstanding what DCAA evaluates, not from bad math, and include unsupported indirect rates, labor rates that don’t match payroll data, weak subcontractor cost analysis, inclusion of unallowable costs, and missing or vague bases of estimate. DCAA expects proposed costs to reconcile to real accounting…

Summary of Keypoints Year-end (October–November) is the optimal window for audit readiness, allowing contractors to reconcile provisional billing rates to actuals, document variances, and correct issues before DCAA or IRS scrutiny begins. Key compliance focus areas include indirect rate accuracy and FAR Part 31 allowability, requiring contractors to review fringe, overhead, and G&A recovery, segregate…

Summary of Keypoints Underpricing proposals creates long-term business risk, often leading to collapsed profit margins, staffing instability, degraded performance, and damaged past performance records, even when the low price initially wins the contract. Government evaluators assess price realism, not just lowest price, especially for cost-reimbursement and certain fixed-price contracts, to determine whether proposed costs are…

Summary of Keypoints Forward pricing rates can be fully approved yet still undermine competitiveness, because DCAA approval confirms adequacy and compliance—not whether rates position a contractor to win best-value awards. Overstated or outdated indirect rates inflate fully burdened labor costs, leading to uncompetitive cost volumes, inconsistent win rates, and contracts that strain margins despite strong…

Summary of Keypoints Compliance readiness is a proactive operating state, not a one-time audit event, requiring embedded financial controls, FAR-aligned policies, consistent accounting practices, and systems that are always prepared for DCAA, DCMA, or IRS review. SF1408, ICE, and CAS are interconnected pillars of audit readiness, relying on the same core foundations: job costing by…