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Did Boeing Rip-Off US Army on Spare Part Pricing?

Nick Sanders
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On June 28, 2011, the Project on Government Oversight (POGO) reported that, “taxpayers were massively overcharged in dozens of transactions between the Army and Boeing for helicopter spare parts,” based on a DOD Inspector General audit report that POGO had obtained. The DOD IG report had been issued in redacted (edited) form on the IG website, but POGO had obtained a 154-page unredacted version which it published at this link. POGO reported that—

Overall, for 18 of 24 parts reviewed, the DoD OIG found that the Army should have only paid $10 million instead of the nearly $23 million it paid to Boeing for these parts—overall, taxpayers were overpaying 131.5 percent above “fair and reasonable” prices. The audit says Boeing needs to refund approximately $13 million Boeing overcharged for the 18 parts. Boeing had, as of the issuance of the audit, refunded approximately $1.3 million after the DoD OIG issued the draft version of its report. Boeing also provided a ‘credit’ to the Army for another part for $324,616.

That sounds pretty bad, doesn’t it? If the above paragraph weren’t damning enough, POGO also provided another link to even more examples of “spare parts ripoffs” allegedly perpetrated by Boeing. Examples reported by POGO included—

  • A “straight pin” (NSN 5315-00-823-8682) which the Defense Logistics Agency (DLA) would have charged the Army $0.04 each, but for which Boeing charged the Army $71.01.

  • A “spur gear” used in a Chinook helicopter (NSN not provided) which the DLA would have provided to the Army for $12.51 each, but for which Boeing charged $623.74.

Et cetera, et cetera. As the POGO article summarized—

… in case after case examined by the DoD OIG, the Army was buying parts for much more money from Boeing that DLA already had in its inventory at significantly lower prices. In some cases, Boeing bought parts from DLA (one part of DoD) and resold them at a higher price to the Army (another part of DoD). From 2007 to 2009, Boeing bought $3.1 million in parts from DLA and sold them to the Army for $4.2 million.  ‘[B]ased on the data Boeing provided us, Boeing made a 35 percent profit on the parts that it bought from DLA,’ the audit report states.

Certainly, the POGO report sounded pretty bad. We decided to first review the (redacted) DOD IG report that was intended to be made available to the public, a copy of which we provide here.

The first thing we noticed was that the DOD IG aimed much of its criticism at the Army itself, and not at Boeing. The audit report stated—

AMCOM officials did not effectively use $339.7 million of existing DoD inventory before procuring the same parts from Boeing because DoD had inadequate policies and procedures addressing inventory use. We identified $242.8 million to $277.8 million of excess inventory that AMCOM could use to satisfy CCAD contract requirements.

The DOD IG report continued—

AMCOM officials did not effectively negotiate prices for 18 of 24 high-dollar parts reviewed because neither AMCOM officials nor Boeing officials performed adequate cost or price analyses, and Boeing officials submitted cost or pricing data that were not current, complete, and accurate … . [Because of those lapses] [w]e calculated that Boeing charged the Army about $13 million or 131.5 percent more ($23 million versus $10 million) than fair and reasonable prices for the 18 parts.

The DOD IG audit report also stated—

… AMCOM officials did not use the most cost-effective source of supply for consumable items because DoD had not developed an effective material management strategy. We identified that the Defense Logistics Agency (DLA) had sufficient inventory to satisfy annual contract requirements for 1,635 parts on the follow-on contract, and the Boeing contract price for those items was $8.0 million, or 51.2 percent, higher than the DLA price.

Okay. From the foregoing we can see that Boeing’s conduct was far from perfect and that its actions deserve criticism. But from what we saw, the DOD IG’s target was AMCOM and the findings centered on AMCOM’s ineffective management of its contractor. It seems to us that the POGO allegations treated the DOD IG’s report as if it were a DCAA report—i.e., an audit of Boeing’s contract—instead of being an audit of the Army’s contractor management. In support of our assertion, we noted that the DOD IG’s recommendations for process improvement were largely focused on AMCOM and not on Boeing.

So the real story is not that Boeing “ripped-off” the U.S. Army. No, the real story is that AMCOM didn’t effectively manage Boeing and, more specifically, AMCOM didn’t source—or direct Boeing to source—parts from internal DLA stockpiles, and permitted Boeing to reprocure items at a higher (and completely unnecessary) cost.

That said—and as we noted previously—Boeing’s conduct was apparently far from being above reproach. The unredacted DOD IG report asserted that—

  • Boeing did not use adequate cost or price analysis to establish the reasonableness of proposed subcontractor prices.

  • Boeing’s pricing data was based on low-volume quantities—e.g., quantities of one or two or three items, which were allegedly based on “outdated” historical use data that had “no relationship to the quantities [actually] required or the actual price Boeing negotiated with its subcontractors.” Allegedly, Boeing routinely failed to share pricing/quantity discounts that it obtained from subcontractor negotiations with its customer.

  • For seven parts audited, Boeing’s cost or pricing data allegedly was not accurate, current, or complete—resulting in “defective pricing” for those parts.

As the result of such alleged behavior, the DOD IG concluded that “Boeing charged the Army about $13 million … more than the fair and reasonable prices” for 18 parts audited.

A couple of concluding thoughts on this matter.

First, defective pricing is a serious concern and, where Boeing was subject to the Truth-in-Negotiations Act (TINA) then its AMCOM customer has recourse to obtain unilateral price reductions plus interest on any overpayments. That said, we don’t know all the circumstances. For example, what quantities was Boeing told to bid on? If AMCOM told Boeing to bid on quantities of one or two or three items each, then that’s what Boeing was required to do. And if Boeing had the business acumen to negotiate volume pricing discounts with its subcontractors then (assuming no defective pricing) there was absolutely no requirement for Boeing to pass on those savings. If AMCOM wanted to share in savings Boeing negotiated, then it shouldn’t have awarded a Firm, Fixed-Price (FFP) contract type to Beoing.

Second, we were interested in the DOD IG methodology for determining what prices Boeing should have charged AMCOM. In the unredacted report, the DOD IG states that its methodology was to add 34 percent to Boeing’s actual direct costs incurred, so as to account for “overhead, general and administrative costs, and the negotiated profit rate.” Well. We certainly don’t know Boeing’s business model, but that strikes us as a ludicrously low number. Take away 15 percent for profit and you have 19 percent to cover overhead (including payroll taxes, fringe benefits, facilities and utilities, etc.) and G&A (including allocations from local, sector, and corporate management. We would be very, very surprised to learn that those values represented Boeing’s true indirect cost rates for this effort.

So to conclude, there seems to be quite a bit of blame to throw at the various entities. As the DOD IG did. We didn’t even mention the IG’s criticism of DCMA’s Contractor Purchasing System Review (CPSR) of Boeing’s Philadelphia operation or the fact that one of the recommendations from the IG audit report was that DCMA should categorize Boeing’s purchasing system as “high risk”. And we didn’t get into the IG’s criticism of the Contracting Officer for failing to heed DCAA’s problems with Boeing’s proposal(s).

Glossing over the DOD IG’s questionable methodology, it seems pretty clear that AMCOM did not have much of a clue. Boeing apparently submitted a (partially) defectively priced proposal—either by customer direction or through its own lax procedures. But as usual, the situation was more complex and nuanced that POGO’s “knee-jerk” headline would lead the casual reader to believe.

 

DCAA Continues Tradition of Inflating Taxpayer Savings

Nick Sanders
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We often wish DCAA leaders and taxpayer “advocates” testifying before Congress would stop inflating the amounts of “taxpayer savings” and the “return on the taxpayer dollar” they report. To say the values are inflated is an exercise in understatement.

Agency costs are understated by unknown—but very large—amounts. This is because many contractors are forced to provide office space for the auditors that are assigned to “resident” offices, branch offices and other “FAO” locations that are actually located on-site at the contractors’ facilities. In addition to office space, contractors must also provide desks, phones, copy machines, file cabinets, office supplies, and other items of tangible value. One larger defense contractor we know provides its DCAA auditors with roughly $1 million worth of office space alone—and that’s just for a subsidiary operation. Another contractor was directed to provide special access to its cafeteria to accommodate DCAA auditor schedules.

And it’s not just DCAA, of course. Other Government agencies—including DCMA—require the same treatment. Contractors often have to forego facility reductions (with concomitant taxpayer savings) because they need to house their Government oversight officials.

Contractors who object to acting as the Government’s unofficial landlord and office supply provider are told to pass it back to the Government in their indirect cost rates—with the implicit threat that a failure to go along with the Government’s “request” will lead to additional audit findings. And so every contractor we know of goes along with the request, passing the additional costs back to their Government customers and, by extension, the U.S. taxpayers.

We don’t know the value of this largesse but we bet the DOD could reduce its weapon system spend if its oversight officials made use of GSA facilities instead of contractor facilities, allowing the contractors to pass along the reduced facility costs to its customers.

We also wish somebody would point out that much of DCAA’s claimed “taxpayer savings” is illusory. DCAA claims savings associated with every audit finding, with every questioned dollar—regardless of whether those questioned costs are sustained by a Contracting Officer or by the Courts. More to the point, DCAA claims savings associated with every questioned dollar on every contractor proposal submitted for consideration. We all know that’s a flawed methodology.

The fact of the matter is that, generally speaking, in a competitive procurement only one contractor receives a contract. The other contractors receive nothing. So the only “savings” that counts to the taxpayers is the one associated with the contract award. “Savings” associated with proposals that did not result in a contract award simply count for nothing.

There are no savings where the taxpayer doesn’t spend any money. It’s too bad DCAA has chosen to inflate the “taxpayer savings” it generates through such a flawed methodology. And it’s too bad nobody has pointed this flawed methodology out to Congress, or that no Congress person has ever challenged DCAA leadership for promulgating such a charade and testifying about sham savings.

Recent DCAA audit guidance (MRD 11-OTS-024(R), issued June 2, 2011, continues this tradition of inflating reported taxpayer savings. The new audit guidance discusses how auditors are to calculate “cost avoidance” (also known as “achievable savings”) when performing Operations Audits.

Operations Audits, for those who may not be familiar with that term, these are DCAA audits that focus on management’s decision-making and the efficiency of contractor operations. (See DCAA Contract Audit Manual at 14-500.) According to DCAA—

… the total audit concept places major emphasis on the degree of prudence exercised by management in establishing policies and making management decisions, methods of controlling costs, and the extent of reliance that can be placed on the accounting information and other financial data. …

The audit plan for major contractor operations is primarily designed to seek out and identify those areas where the contractor's practices are wasteful, careless, inefficient and result or may result in unreasonable costs and unsatisfactory conditions in performing Government contracts; and to report such matters to those responsible for taking action to correct or improve the condition.

According to the DCAA audit guidance (link above), when reporting cost savings from Operations Audits the historical practice was to use one year’s worth of costs. In other words, when the DCAA auditors found inefficiencies or unreasonable costs that the contractor was supposed to correct, the value of those costs was based on what the contractor had incurred (or would incur) over a one year period. But the audit guidance announced that, “The DCAA Director has approved a major policy change that will allow estimation of cost savings over an extended period of time that more logically reflects the impact of audit findings and conclusions up to a maximum period of six years.”

Let’s repeat that. Instead of using one year’s worth of costs when reporting savings available to the contractor, DCAA will now be reporting up to six years’ worth of costs.

Is this a big deal? Well, it might be.

Readers may recall our discussion of Shay Assad’s new job at the Defense Department. Mr. Assad will be focusing on what programs “should cost” as opposed to merely accepting what contractors report they will cost. Part of that responsibility is addressing contractor overhead and other indirect costs, which Mr. Assad called “fair game” in his efforts to reduce Defense spending.

So when DCAA reports “achievable savings” in contractor operations, we think Mr. Assad will tend to use that data in his efforts to reduce weapon system prices. And now, because of this new audit guidance, his cost reduction goal will be six times higher than it would have otherwise been.


 

Should “Shell Companies” Receive Federal Contracts?

Nick Sanders
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Shell_Company

Most folks normally think it’s sufficient simply to review the Excluded Party List before making a contract award, in order to make sure their awardee isn’t suspended or debarred. In fact, that’s a mandatory step even if you’re a prime contractor, and one that’s checked in almost every Contractor Purchasing System Review (CPSR) performed by DCMA functional specialists. Woe to the Government Contracting Officer or to the prime contractor’s contract administrator who awards work to a suspended or debarred entity!

But is that review good enough?

Recently, we came across this article that discussed the State of Wyoming’s “liberal incorporation laws” that permit entities to incorporate using an “alias” in order to preserve “corporate anonymity”. Wyoming Corporate Services was named in the article as the provider of such services. According to the entity’s website, it offers the following benefits to companies interested in incorporating anonymously in Wyoming:

  • No State Income Taxes

  • No information collected to be shared with IRS

  • Privacy allowed

  • Shareholders are not listed with the state

  • Best Asset Protection Laws

  • Nominee officers are legal

  • Citizenship not required

  • State tax not being considered

  • Wyoming draws little attention

  • No Nevada "Stigma"

  • Lower Startup Costs

There’s nothing illegal in incorporating in Wyoming, nor in using the services of Wyoming Corporate Services—at least, as far as we can tell. However, problems seem to arise when an unscrupulous corporation uses its corporate anonymity to misrepresent itself when bidding on a Federal contract. We’re talking, once again, about representation as a small or small socioeconomically disadvantaged business when the entity fails to meet the qualifications established by FAR Part 19.

According to the article—

In January, the Defense Logistics Agency (DLA) banned Eagle Logistic Solutions and Eagle Logistics Aerospace from selling components to the Pentagon for three years. The ban came after investigators found the firms, and their owners, had knowingly supplied air and fluid-filtering kits for military tractor-trailers between 2001 and 2005 that were reverse-engineered in Turkey to look like they were made by Parker Hannifin, the required manufacturer. … The parts were considered ‘critical application items,’ which the Pentagon defines as ‘essential to operating personnel.’

The article continued—

The companies were created by Atilla C. Kan, an employee of another Pentagon supplier called New York Machinery. DLA records, Wyoming incorporation data, and documents submitted by an attorney for New York Machinery in a settlement agreement in a separate federal criminal lawsuit show Kan formed the companies in Wyoming under the name John Ryan. He later used the alias, and a description of the companies as ‘minority-owned,’ ‘woman-owned’ and ‘Hispanic-owned,’ when applying to supply military parts, the documents show.

The article reported that, “Both firms listed their address as 2710 Thomes Avenue in Cheyenne, the DLA records show.” That address is—not coincidentally—the address of Wyoming Corporate Services. The article noted that—

A Reuters investigation has found that more than 2,000 companies are registered at 2710 Thomes Avenue in Cheyenne, the headquarters for Wyoming Corporate Services …


Among the firms incorporated there is a small subset that make their money from government contracts.


A Reuters review of federal contracting databases found nine firms registered at 2710 Thomes Avenue have been awarded 93 contracts worth more than $1.6 million by a half dozen government agencies, including the U.S. Department of Defense, the U.S. Treasury's Internal Revenue Service, the Centers for Disease Control, and the Department of Veterans Affairs.


More than 90 percent of the contracts were awarded by the Department of Defense.

We have previously reported on the real and present danger posed by counterfeit parts within defense program supply chains. Many contractors simply don’t know how to secure their supply chains so as to lock-out untrustworthy suppliers. Today, we are suggesting one test to check for the trustworthiness of a potential supplier.

We recommend checking the corporate address of the potential supplier. If the corporate address is 2710 Thomes Avenue, Cheyenne, Wyoming … then we recommend caution and further checking. Having that address is not evidence of a problem, but we consider it to be an indicator—a warning sign, if you will—of potential concern.

To our original question (should a contract be awarded to a shell company run by somebody using an alias?) we can only answer that we would hesitate, and run several more checks on that supplier, before doing so.


 

When Are Indirect Rates Final Billing Rates?

Nick Sanders
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One of our pet peeves is Government’s tendency to want to reopen “final” indirect cost rates—i.e., rates that have been audited and negotiated and agreed-to by both Government and contractor as suitable for closing-out flexibly priced contracts. It’s not that we are against such an occurrence in all situations. For example, the Courts have held that “finalization” of indirect cost rates is no bar to revision when a CAS 413 segment closing pension adjustment is being calculated. We’re okay with that (kind of) even though at least one attorney passionately argued that “final means final” in the original series of Teledyne decisions that framed much of how that complex adjustment is supposed to work.

But DCAA wants more. In their view—and to be fair it’s the view of the FAR Councils as well—any CAS noncompliance must address the cost impacts of all “affected contracts” regardless of whether those impacts take place in “closed” years where indirect rates have been finalized. For example, see our series of articles on how DCAA (and DCMA) wants to treat the “expressly unallowable” costs associated with ineligible healthcare plan dependents. In our view, the Government’s position is—shall we say?—extreme and untenable. We await a good legal decision that imposes rationality, equity, and plain old common sense on the patently irrational, unfair, and bizarre interpretation taken by the FAR Councils in the mid-2000’s during their poorly conceived rewrite of FAR 30.6.

Recently, the ASBCA addressed a similar problem in a decision that we want to share with our readers. The decision was entitled Kearfott Guidance and Navigation Corporation, ASBCA No. 55626, dated June 10, 2011, and it can be found here. (Readers please note that Kearfott was represented by Stephen Knight of the law firm, Smith Pachter McWhorter. We’ve mentioned Steve’s work before, with approval if not outright admiration.)

The case was summarized by Judge Freeman as follows—

Kearfott … appeals a final decision denying its claim for inclusion of mistakenly omitted allowable costs in the calculation of indirect cost rates and facilities capital cost of money (FCCOM) factors in a letter agreement. The government contends that the omission was deliberate, the costs not proven to be allowable, and the letter agreement final. We find the omission inadvertent, the costs allowable, the letter agreement reformable for mutual mistake, and sustain the appeal.

Basically, Kearfott and the DoD agreed to rates for the period 1989 through 1997 to address a previously litigated issue as to whether Kearfott could claim the costs of “writing-up” its assets. The parties executed an agreement but—quite importantly—the agreement never had the word “final” in it. It’s pretty obvious the parties understood the indirect rates in the agreement to represent the final rates for the years in question … but they never explicitly said so.

A couple of months after executing the agreement, Kearfott realized that the rates it has agreed-to omitted costs associated with its intangible assets, such as software development and a covenant not to compete. DCMA had Kearfott submit a “Final” indirect cost rate proposal for the period 1984 through 1994, which was to be audited by DCAA. (We have no idea what happened to indirect rates for 1995 – 1997.)

DCAA performed its audit and opined (via memorandum) that the costs of the intangible assets were “not allocable” to Government contracts because—

… the 12 April 2005 letter agreement was ‘negotiated in good faith and with both parties clearly aware that amortized intangible asset costs were not included’; and … ‘[Kearfott] did not mistakenly omit the amortization of intangible asset costs; they were aware of their existence and chose to exclude them from all proposals and incurred cost submissions for the subject years.’

First of all, we have a bit of a problem with DCAA’s “opinion” as quoted above. We don’t see much accounting or audit testing in that opinion; what we see is DCAA trying to do the Contracting Officer’s job. But let’s move on ….

A year later, the DCMA Administrative Contracting Officer (ACO) told Kearfott that he was not going to reopen the previously negotiated rates, “citing substantially the same reasons” as were contained in the DCAA memorandum opinion.

Our readers should focus on the DCAA logic: it was DCAA’s opinion that Kearfott did not make a mistake, and that it was the company’s established cost accounting practice to exclude such costs from its indirect rate calculations. We’ve seen that logic before and we’ve always responded that, “a mistake is not a cost accounting practice.” In his decision, Judge Freeman said the same thing. He wrote—

… we find that the bookkeeping entry assigning the identifiable intangible asset write-up amortization costs to an income deduction account and not to an operating cost account was a mistake and not an established accounting practice or otherwise a deliberate decision to omit these costs from the indirect cost rates and FCCOM factors applicable to government contracts.

The Judge also found that Kearfott’s intangible asset costs were reasonable and allowable, as well as being allocable to the company’s government contracts. Moreover, the Judge found that the indirect rate agreement was “reformable” because of a mutual mistake. To do otherwise would be to give the Government a windfall to which it was not entitled.

The Judge sustained Kearfott’s appeal.  Kearfott's indirect cost rates would be revised.


 

SAIC in Deep Curry with New York City’s “CityTime” Payroll Project

Nick Sanders
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New York City’s “CityTime” payroll project is reportedly over-budget and behind schedule. And really, should we be surprised? When’s the last time you read about a city or county or state IT project that actually came in under budget or on time or even with the originally planned functionality? Answer: it’s been awhile.

But what sets NYC’s project apart is the series of alleged ethical “lapses” that have plagued its prime contractor, Science Applications International Corporation (SAIC). SAIC, as many readers will recognize, is a major Federal contractor performing billions of dollars worth of projects each year. (SAIC’s total FY2011 revenue was $11 billion.) So we were taken aback to read about the alleged problems SAIC had with managing the CityTime project, a project on which it had reportedly received $650 in billings (against an original budget of $68 million).

According to a report by the Wall Street Journal, “Last year, following a probe by the city's Department of Investigation, federal prosecutors charged six people with stealing $80 million from CityTime. Prosecutors have since added one more defendant; one defendant has died, and one has pleaded guilty and agreed to help prosecutors with the case.”

One allegation concerns SAIC’s principal subcontractor, TechnoDyne, who reportedly received $450 million from SAIC—allegedly because it agreed to pay kick-backs to SAIC employees. According to this article, on June 20, US Attorney Preet Bharara announced that TechnoDyne’s and its two co-founders (Padma and Randy Allen) had been indicted on fraud charges. One blog site stated—

Carl Bell, a former SAIC employee and CityTime systems engineer, has pled guilty to multiple charges and claims he received at least $5 million in kickbacks from TechnoDyne and the Allens ‘to ensure the continued success of the fraudulent scheme.’ Gerard Denault, another former SAIC employee, who was recently arrested in connection with the alleged scheme, allegedly took more than $9 million in kickbacks.

The Allens have reportedly fled to India and the company has closed its doors, leaving about 200 employees jobless. The article reported—

One defendant, Mark Mazer, a principal agent and representative of the New York City Office of Payroll Administration, oversaw the project. He allegedly approved time sheets for consultants who were on leave, who had been fired, and who were working less time than was reported. The payroll office awarded more than $600 million to SAIC, which paid about $450 million to TechnoDyne.

According to the 43-page indictment, TechnoDyne gave $75 million to companies D.A. Solutions and Prime View and their executives, Dimitry Aronshtein and Victor Natanzon, and allegedly channeled $25 million to Mazer. Natanzon pleaded guilty to his role in the CityTime fraud in February 2010.

The article continued—

Prosecutors have seized over $38 million in 120 bank accounts involving shell companies in three continents used to hide transactions in the CityTime probe.

Employees at TechnoDyne learned by e-mail May 31 that their company had closed its doors effective that day. When they tried to retrieve paychecks the next day, they were shocked to find out the Allens had removed them from the payroll in mid-May. In other words, they had worked two weeks not knowing they had no jobs.

This was a sad end for a company that had, in 2010, been honored by Ernst & Young LLP as New Jersey’s Entrepreneur of the Year. But there’s more to the SAIC story than the sad end of TechnoDyne.

Reports have surfaced of alleged timekeeping irregularities by SAIC’s staff, namely one Gerard Denault, SAIC’s CityTime Project Manager. (He was also one of those who allegedly received kick-backs from TechnoDyne.) We saw one Wall Street Journal article from May 25, 2011 that asserted that SAIC had fired Mr. Denault “for allegedly violating company policy when reporting his own timekeeping.” The article continued—

According to a ‘confidential’ letter that SAIC sent to the city this week, Mr. Denault ‘routinely recorded set hours each day rather than the actual hours that he worked as we require.’


‘Mr. Denault performed extensive work on CityTime, but because he did not precisely record the hours he worked as SAIC policy requires, SAIC cannot accurately calculate the amount that should have been billed to the city,’ the letter said.


SAIC has agreed to reimburse the city for all of Mr. Denault's billed services. The reimbursement will be $2,470,522.

Quite obviously, we don’t know all the facts and the real story of this problematic project. But we wonder whether the real problem here might be that SAIC didn’t view its state and local projects as being as risky as its Federal projects. We wonder if SAIC didn’t focus its compliance efforts on its Federal contracts which, after all, would be subject to Federal False Claims Act suits if it misbilled the Federal government. We also wonder whether the notoriously decentralized and entrepreneurial company might have taken a “hands-off” approach to local project management.

Regardless of the facts, we would urge readers to review their portfolio of projects, and ask themselves whether all projects are being treated equally. Are all projects subject to the same internal control systems and compliance reviews? Or, as we suspect is the case, have some projects slipped below your compliance radar screen because they are incorrectly perceived as being “low risk”?

We bet SAIC is asking themselves those questions right now.


 
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Newsflash

Effective January 1, 2019, Nick Sanders has been named as Editor of two reference books published by LexisNexis. The first book is Matthew Bender’s Accounting for Government Contracts: The Federal Acquisition Regulation. The second book is Matthew Bender’s Accounting for Government Contracts: The Cost Accounting Standards. Nick replaces Darrell Oyer, who has edited those books for many years.