Josef Kamara CPA, CISSP, CISA, ACCA

What a CMMC assessment costs at each level, whether the fee is allowable under FAR 31.201-2, and how to recover it on cost-plus and fixed-price contracts.

The TINA compliance threshold rose to $2.5M on October 1, 2025, and jumps to $10M for contracts after June 30, 2026. This guide maps all three active thresholds, explains the four exceptions, and delivers the seven-step pre-certification sweep that protects contractors from defective pricing claims.

The OBBBA Section 174A catch-up election lets eligible small federal contractors recover unamortized 2022-2024 domestic R&D before the July 6, 2026 deadline. The §481(a) catch-up adjustment also lands on FAR 31.205-18 indirect cost pool reporting, which most general-practice CPAs miss.

DCAA audits the incurred cost submission. DCMA negotiates the final indirect rate agreement. This guide covers Form 1 response, quick-closeout thresholds under FAR 42.708 and DFARS 242.708, penalty waiver mechanics, and the dispute escalation path to ASBCA for GovCon contractors reaching post-audit settlement.

FAR 31.205-18 lets you recover every reasonable dollar of bid and proposal effort through your indirect rates. This guide covers the allowability test, the B&P vs. marketing decision boundary, CAS 9904.420 project-level accumulation, and the DFARS 231.205-18 major-contractor reporting threshold that most small contractors never see coming.

DCAA defective pricing audits arrive years after contract award. Learn the three-prong test auditors use, what triggers a TINA sweep, and the pre-certification checklist that protects your pricing position.

A 5-point reduction in your overhead rate on a $3M direct labor base saves $150,000 per year. Most small contractors carry 10-30 points of excess rate from bookkeeping problems, not business problems. Seven DCAA-compliant strategies to lower your rates and win more contracts.

Phase I lets you operate with a basic bookkeeping system. Phase II demands DCAA-compliant accounting, daily timekeeping, documented indirect rates, and a system that passes an SF 1408 pre-award survey. The financial leap between phases catches most first-time awardees off guard.

In 2026, SBA suspended 1,091 firms that couldn’t produce three years of records in 30 days. The contractors who shipped documents in 48 hours had a monthly compliance workflow. Here is that workflow: a 12-month checklist that makes annual reviews and data calls a non-event.

You filed your incurred cost submission by the deadline. Now what? DCAA has a defined process for reviewing your submission, selecting it for audit, and finalizing your indirect rates. Here is every step, from adequacy review to final rate agreement.