Are Work Authorizations Required by DCAA for an Adequate Accounting System?

Redstone GCI-Are Work Authorizations Required by DCAA for an Adequate Accounting System.jpg

As incurred cost audits are becoming more prevalent and voucher audits are taking off like wildfire, there is emphasis placed on the use of work authorizations by government contractors.  There is no specific regulatory authority that can be cited which requires work authorizations as a part of a contractor’s Labor/Timekeeping System.  This argument, although accurate, is not the rationale which will be used by a DCAA auditor when “disclosing” deficiencies in a contractor’s labor system and ultimately rendering an inadequate opinion with respect to the accounting system, when the work authorization process is absent. 

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Topics: DCAA Audit Support

DCAA’s 2018 New Year Resolutions

As we near the end of calendar year 2017, many will be thinking of some resolutions for the upcoming “Year of the Dog” (the 2018 animal per the Chinese Calendar). In fact, we’ve discovered that Government agencies sometimes consider similar resolutions, and in the case of DCAA (Defense Contract Audit Agency), we’ve accidentally been copied on one of the unofficial versions of its 2018 New Year’s resolutions (which are three months late, given the government fiscal year started October 1, 2017).

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Topics: Defense Contractors, DCAA Audit Support

Wishing You a Joyous Holiday Season

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Topics: Redstone GCI

Elusive Answer: Contracting Officer Actions to Disposition DCAA Audits

It seems like there are a lot of agencies being audited on what they are doing with DCAA audit findings.  In September, the DoD-IG announced an audit of 26 contracts issued from FY 2014-2017 by Navy, DLA, Army and Air Force contracting officers. It’s stated objective is “to determine whether contracting officer actions during contract negotiations complied with acquisition regulations when contractor proposals were deemed inadequate by the Defense Contract Audit Agency (DCAA).”  At the same time, they announced an audit of DCMA with an audit objective “to determine the appropriateness of contracting officer actions to resolve and disposition compensation costs that the Defense Contract Audit Agency (DCAA) has questioned in audits of DoD contractor incurred cost claims submitted to the Government.

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Topics: Contracts Administration, DCAA Audit Support

Organizational Conflicts of Interest (OCI) for Government Contractors

Organizational Conflicts of interest have increasingly gained attention from the Government and Government contractors.  Organizational Conflicts of Interest (OCI) are discussed in the Federal Acquisition Regulation (FAR) subpart 9.5.  OCI rules are meant to prevent conflicting roles or unfair competitive advantage in government contracting.  Assessment of OCI is very fact specific, and mitigations should be sculpted to fit your contracts and situation. 

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration

Why Thanksgiving 2017 is More Meaningful Than Ever

Every year I write a Thanksgiving blog, reflecting on the growth of our firm, how awesome our employees and customers are, and the privilege we have every day to be able to serve and truly make a difference in the lives of our clients. As founder and CEO, I have been solely focused and driven to meet our targets, budgets, goals and have worked as hard as ever. 

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Topics: Redstone GCI

Employee Stock Ownership Plans, Cost Allowability and DCAA Audit Risks (Part II)

We have received a number of inquiries from clients related to cost allowability for Employee Stock Ownership Plans (ESOPs). In this Part II, we focus on the cost allowability rules and regulations for government contractors (Part I provided a more general description of ESOPs).

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Human Resources

Employee Stock Ownership Plans (ESOP) and Government Contracting (Part I)

Many small and medium sized companies wonder if having an Employee Stock Ownership Plan (ESOP) is right for their company’s compensation and ownership structure.  Studies show that employee-owned companies benefit from higher worker productivity and certain tax advantages which ultimately result in improved cash flow.  These and other potential advantages could apply to government contractors; however, if you are considering implementing an ESOP, consider engaging someone (or an entity) familiar with ESOPs, as well as someone familiar with the cost allowability (regulations) and DCAA interpretations.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Human Resources

Seminar, Government Employees and Gratuities

As we (Redstone Government Consulting, Inc.) began to plan our September 21, 2017 Redstone Edge, we sought out speakers and potential attendees from government agencies, including those from DCAA (Defense Contract Audit Agency) and DCMA (Defense Contract Management Agency). In both cases, their potential speakers had a list of questions which seemed to be unnecessary, but related to OGE (Office of Government Ethics) regulations and interpretations, to identify and otherwise prohibit anything which might be an illegal (or at least unethical) gratuity. Although we might not be a “government contractor”, for those who are, there is another regulation in play; FAR 52.203-3 prohibits government contractors from offering gratuities to government employees.

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Topics: Redstone GCI, Compliant Accounting Infrastructure, Cost and Pricing and Budgeting, Small Business Compliance, Contracts Administration, DCAA Audit Support

Training Costs on Government Contracts

Companies that incur significant costs for training and education of their workforce should have formal policies and procedures in place to ensure reimbursement on their government contracts and subcontracts.  As with all types of costs, there are three major components to consider: allowability, allocability and reasonableness.

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration, DCAA Audit Support, Human Resources