As the defense contracting landscape continues to evolve, one recent legislative change is expected to have a significant impact on procurement teams across the industry. The FY2026 National Defense Authorization Act (NDAA) introduced statutory exemptions for qualifying Nontraditional Defense Contractors (NDCs), creating new opportunities for commercial suppliers while shifting additional responsibilities onto prime contractors. For […]
DFARS Business Systems Reviews
Get the Insight You Need to Evaluate, Improve, and Maintain DFARS-Compliant Systems. We assist with cost estimation, DFARS, CPSR, and more!
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DFARS Compliance Services
For businesses pursuing or managing government contracts, DFARS compliance can feel overwhelming. From understanding what’s required to preparing for reviews, the process involves many moving parts. That’s where RKI comes in. We work with contractors to help them interpret DFARS requirements, assess their internal systems, and take practical steps to improve compliance
RKI provides a variety of services relating to a contractor’s cost estimating practices including:
- Design of a DFARS Estimating System, including policies, procedures, standardized forms, and training
- Evaluation of a contractor’s estimating business system for potential compliance gaps
- Guidance on remediation or corrective actions for any deficiencies identified by DCAA or internal management
- Support with preparing cost proposals that align with DFARS Estimating System requirements
- Additional services related to best practices in U.S. Government estimating
DFARS Business Systems & Review Support
Government contractors working with the Department of Defense may be subject to DFARS business system requirements—standards designed to ensure accountability and consistency in how contractors manage costs, proposals, and procurement. There are six primary systems covered under DFARS: accounting, estimating, purchasing, EVMS, MMAS, and property management.
When a contractor is selected for a DFARS Business Systems Review, it means one or more of these systems will be evaluated by a government agency (often the DCAA or DCMA) to ensure they meet regulatory standards. These reviews can be detailed and time-consuming, and findings can impact contract eligibility, billing, and more.
Whether you’re anticipating a review or want to proactively assess your systems, RKI offers practical, experienced support to help you move forward with confidence.
DFARS Services
Our team is skilled and experienced in navigating DFARS awards and the potential pitfalls they present. From business system readiness assessments to policy development and review assistance, our team works alongside yours to strengthen compliance and reduce risk.
Accounting
RKI routinely performs pre-award and post-award accounting system evaluations. Our reports identify significant deficiencies, material weaknesses, and areas for process improvement. Clients often request these evaluations to satisfy management or internal audit requirements, or to include our findings as part of a proposal package demonstrating to the U.S. Government or prime contractor that they have an accounting system suitable for the award of a contract or subcontract.
Estimating
RKI can help you develop a DFARS Estimating System with policies, procedures, standardized forms, and training for your team.
CPSR
RKI can perform reviews of your Purchasing System Administration to help prepare your organization for a formal Contractor Purchasing System Review (CPSR). We will analyze your purchasing and subcontracting processes—including make-or-buy decisions, vendor selection, and price analysis—against applicable purchasing system requirements.
MMAS
RKI can perform reviews of your Material Management and Accounting System (MMAS) to assess alignment with defined criteria and help develop appropriate remediation plans, if necessary, to maintain a compliant system.
USG Property
RKI can perform reviews of your Property Management System to assess how it handles the acquisition, management, and disposal of U.S. Government property under contract. We can assist with appropriate remediation plans, as necessary, to maintain a compliant system and reduce the likelihood of “significant deficiencies.”
EVMS
RKI can review your Earned Value Management System (EVMS) to assess its alignment with defined criteria and help develop appropriate remediation plans, if necessary, to maintain a compliant system.
DFARS Business Systems
Frequently Asked Questions
Our team is skilled and experienced in navigating DFARS, Cost estimating, and associated issues.
Requirements of your accounting system for U.S. Government contracts differ between contract-types. Not all contracts, and hence contractors, require the same level of accounting system capabilities. Per FAR 16.103, “Before agreeing on a contract type other than firm-fixed-price, the contracting officer shall ensure that the contractor’s accounting system will permit timely development of all necessary cost data in the form required by the proposed contract type.” Translated, this means that Contracting Officers must satisfy themselves that a contractor’s accounting system can meet the contract vehicle’s needs to protect the U.S. Government financial interests. In its simplest sense, any contractor performing work under cost-type contracts including Cost Plus Fixed Fee (CPFF) and Time and Materials (T&M) will be required to have an adequate accounting system, as determined by DCAA.
Prior to award of applicable contracts and after award of that contract. The Defense Contract Audit Agency (DCAA) audits your accounting for adequacy prior to award during a pre-award accounting system audit focused on the design of your accounting system and post award accounting system audit focused on the operating effectiveness of your accounting system including reviews of labor charging, project cost accumulation, indirect cost rate methodology, invoicing, and similar. Not having an adequate accounting system is a barrier to entry for a contractor looking to be awarded a cost-type contract.
What Are the Accounting System Requirements?
While a Contracting Officer must satisfy itself that an accounting system meets the requirements of its contract-type, generally there are 2 sets of Accounting System requirements contractors are held to:
1. Pre-Award Accounting System criteria (SF-1408) (Link:
2. Post-Award Accounting System criteria (DFARS 252.244-7001 https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration)
While a Contracting Officer must satisfy itself that an accounting system meets the requirements of its contract-type, generally there are 2 sets of Accounting System requirements contractors are held to:
1. Pre-Award Accounting System criteria (SF-1408) (Link:
2. Post-Award Accounting System criteria (DFARS 252.244-7001 https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration)
While formally defined at DFARS 252.215-7002 (Cost Estimating System Requirements), its intention is provide consistent and reliable cost estimating practices for preparation and negotiation of fair and reasonable prices with the U.S. Government. It focuses primarily on those proposals subject to certified cost or pricing (e.g, Truthful Cost or Pricing, Truth in Negotiations, TINA). The DFARS Estimating business system clause provides the applicable criteria to which a U.S. Government contractor is held during a Estimating System review.
Yes, if you have contracts subject to certified cost or pricing. While DFARS provisions are specific to DoD contractors, DCAA and other U.S. Government audit interests have designed their audit programs around the DFARS criteria. As a result, even if you’re not “required” to comply with the DFARS Estimating business system criteria, they are the criteria to which you would be held under most U.S. Government audits on cost proposals and estimating system reviews.
STEPS TO SUCCESS
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Call our team and establish your business's unique needs.
1
Make A Plan
We'll work with you to make a plan that will ensure total federal compliance.
2
Get Contract Success
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3
Get The Help You Need
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We collaborate with you to help maintain compliance with your contracts, establishing a strong foundation for a long-term, profitable partnership with the U.S. government.