Federal compliance for contractors

Your FAR compliance system: operated,
audit-ready
.

We build and run the systems, workbooks, dashboards, and audit-ready records small-to-mid federal contractors rely on to satisfy FAR, DFARS, DCAA, and CAS — across the full contract lifecycle. You run the business on top of that foundation.

FAR · DFARS DCAAM 7641.90 SF-1408 CAS 2 CFR 200
How it works

Build, document, review, defend.

Four phases, one operating system. Every obligation has a named owner and a due date. No junior handoffs, no surprises.

01

Build

Accounting system, workbooks, and policies — designed to FAR and DCAA spec from day one.

02

Document

Written procedures and evidence files auditors can follow end-to-end — not a PDF that sits on a drive.

03

Review

Human compliance review on every submission — judgment, not just a portal.

04

Defend

DCAA-ready packages the moment the request arrives, traceable back to the underlying evidence.

The compliance landscape

What needs compliance, what triggers audit exposure, and when DCAA shows up.

A working reference drawn from FAR Part 16, DCAAM 7641.90, and CAS Public Law 100-679 — the terrain every FAR contractor is operating on.

01 · Foundation

What every FAR contractor needs

  • Adequate accounting system SF-1408 · FAR Part 31

    The pre-award gateway for cost-reimbursable awards. Segregates direct from indirect costs, identifies unallowables per FAR Part 31.

  • Timekeeping controls Daily recording · supervisor approval

    Daily recording, employee certification, supervisor approval. The single most-cited area in DCAA findings.

  • Indirect cost rate structure FAR 31.203

    Documented allocation of overhead, fringe, and G&A pools. Logical, consistent, applied the same way every contract.

  • Subcontractor flow-down FAR 52.244-6

    Required clauses passed down, oversight files maintained. The prime carries liability for sub non-compliance.

02 · Threshold

Triggered as you scale

  • Purchasing system (CPSR) FAR 44.302 · $25M+

    Required at $25M+ subcontract sales. DCMA-led review every three years.

  • Estimating system DFARS 252.215-7002 · $50M+

    Documented basis for proposal estimates. Required for major DoD contractors at $50M+.

  • Earned Value Management DFARS 252.234-7002

    Cost or incentive contracts at $20M+ (compliance), $50M+ (validation).

  • Material Management (MMAS) DFARS 252.242-7004 · $40M+

    Required at $40M+ on qualifying contracts.

  • CAS coverage CAS PL 100-679

    $7.5M+ Modified (4 standards) · $50M+ Full (all 19) + DS-1 disclosure.

03 · Domain-specific

When the contract demands more

  • Cybersecurity / CMMC DFARS 252.204-7012

    NIST SP 800-171 controls for CUI. CMMC Level 2 certification for most DoD CUI contracts.

  • Property management FAR 52.245-1

    Tracking government-furnished property. Annual self-assessment and DCMA Property Management System Analysis.

  • Incurred Cost Proposal FAR 52.216-7

    Annual ICP within 6 months of FY-end for any flexibly priced contract.

  • Truth in Negotiations Act FAR 15.403 · $2M+

    Certified cost or pricing data on negotiated awards above $2M.

04 · Contract types & audit exposure Per FAR Part 16
Firm-Fixed-Price
FFP · FAR 16.202
Pre-award
Fixed-Price Incentive
FPI · FAR 16.403
Cost data
Cost-Plus-Fixed-Fee
CPFF · FAR 16.306
Annual ICP
Cost-Plus-Incentive-Fee
CPIF · FAR 16.405-1
Annual ICP
Time & Materials
T&M · FAR 16.601
Labor audit
IDIQ
FAR 16.504
Order-based
High Moderate Lower
05 · When DCAA shows up Per DCAAM 7641.90
SF-1408 · Pre-award
Pre-award survey

Determines whether your accounting system is acceptable for award. Required before any cost-reimbursable contract.

Pre-award · Proposal
Forward pricing audit

DCAA evaluates your estimate of project cost. Tied to proposal submission on negotiated awards.

Annual · Cost-type / T&M
Incurred Cost Proposal

Required submission within 6 months of FY-end for any flexibly priced contract held during the fiscal year.

Unannounced
Floor check (timekeeping)

Unannounced labor compliance check on contracts with reimbursable labor — typically T&M or cost-type.

Post-award
Defective pricing (TINA)

Reviews whether certified cost or pricing data was accurate, complete, and current at the date of agreement.

Risk-based · Periodic
Business system review

Initiated when risk is indicated or systems were previously flagged. Covers accounting, estimating, purchasing, EVMS, MMAS.

KPI & metric dashboards

From reactive to real-time.

Ho‘okele replaces point-in-time readiness checks with continuous compliance monitoring — constant visibility into the health of every contract, every obligation, every control. When a DCAA request arrives, every passing control is already live on your Metrics dashboard.

The full contract lifecycle

From pre-award readiness to closeout — one thread.

We meet contractors at every stage and carry the compliance record forward. The infrastructure that passes today's audit also supports your next contract.

STAGE 01

Pre-award readiness

SF-1408 posture, cost-proposal review, and preaward accounting-system evidence.

STAGE 02

Onboarding & gap

Mapping current state to FAR / DFARS / DCAA requirements, with a remediation plan.

STAGE 03

System build

SF-1408, NICRA, timekeeping, labor, and the written policies that hold them together.

STAGE 04

Operations

Running the Incurred Cost Submission, reviewing drafts, flagging risk in real time.

STAGE 05

Advanced matters

CAS applicability, forward pricing, and contract modifications with documented rationale.

STAGE 06

Monitoring & closeout

Continuous monitoring through closeout — evidence packaged so the file survives the auditor.

Why Ho‘okele

Ho‘okele means to navigate.
We run the compliance machinery so you don't have to.

Built for small-to-mid federal contractors pursuing, executing, and defending prime and subcontract awards.

01 · Operated, not advised

System, not memos

You get the workbook, the dashboard, and the documented procedure — operated, not sold as a PDF that sits on a drive.

02 · Judgment on every submission

Human review layer

Portals miss context — we sit behind the portal and catch what it can't, on every single submission.

03 · No junior handoffs

Named accountability

Every obligation has an owner and a due date. Nothing lives in someone's head, and nothing quietly slips.

04 · Scales with awards

Built to compound

The infrastructure that passes today's audit also supports your next contract. The record compounds across awards.

Common questions

Straight answers, before the first call.

Are you an advisory firm?

No. Ho‘okele Compliance is an operator. We build and run the compliance infrastructure — the systems, workbooks, dashboards, and audit-ready records — not a binder of recommendations. When the DCAA request arrives, the evidence is already assembled.

Who do you work with?

Small-to-mid federal contractors across the full lifecycle: pre-award readiness, onboarding and gap assessment, system build (SF-1408, NICRA, policies), operations (ICS, review and flag), advanced matters (CAS, forward pricing, modifications), and continuous monitoring through closeout.

Which frameworks do you cover?

FAR / DFARS, DCAA (DCAAM 7641.90), SF-1408 Preaward Accounting System, Cost Accounting Standards (CAS), 2 CFR 200 Uniform Guidance, and agency supplements.

Do you replace our accountant or our portal?

No — we sit alongside them. Your accountant keeps the books; your portal holds submissions. We own the compliance layer connecting the two, so the artifacts a DCAA auditor asks for are already traceable back to source.

How do engagements start?

A short consult to understand the contracts you're running, the awards you're pursuing, and the state of the record today. From there we scope a build — usually a pre-award readiness package or a system-build engagement — with named deliverables and owners.

Book a consult

Let's see what your compliance record actually looks like.

Tell us about the contracts you're running or pursuing. We'll respond with a short read on where you sit against FAR, DFARS, and DCAA — and what a first engagement would cover.

Or email directly: kaitlinnakano@gmail.com