DCAA Accounting System Adequacy Are Accruals Required-1

In my years as a CPA and consultant I’ve worked with many small businesses that have asked for input on what they need to be doing to get more reliable financial data. Usually, it’s business owners looking for ways to be able to make important decisions faster, but lately it’s often companies new to government contracting that are trying to figure out what they need to be doing to keep clear of problems with DCAA. In either scenario, one of my first suggestions is a formal monthly close process. When I say “formal”, that doesn’t mean that it has to be cumbersome and complicated. If the business financials are relatively simple, then that close process can also be fairly simple and still be effective. But it needs to be structured, with a specific checklist in place as to the procedures that are to be performed, the order in which they are to be done, who is responsible for each task, and target deadlines for each. That recommendation then raises the next question – what do you mean by “close”?

What Is a Close?

A lot of businesses think they are closing the books each month, but what they’re really doing is reconciling the bank accounts and reviewing the Income Statement for accuracy. Unfortunately, that is just a small part of what even a simple close should entail. Many of the business owners I’ve worked with spend all their time focusing on the Income Statement – and for good reason. Ultimately, it’s revenues, profitability, margins, etc. that they are trying to drive, all of which are found on the Income Statement. However, I would argue that the Balance Sheet is more important than the Income Statement. Some might say that doesn’t make any sense – after all, I just agreed that many of the metrics for focus are on the Income Statement. However, if the Balance Sheet isn’t accurate, then neither are any of the numbers or metrics on that Income Statement. Ultimately, if everything is correctly represented on the Balance Sheet, then the Income Statement, at least at the bottom line, must be correct. It’s possible that some revenues or expenses might be shown in an incorrect Income Statement account and the Balance Sheet still be correct but moving those revenue or expense items to the correct account would not have any impact on bottom line net income. Ensuring that all assets and liabilities are reflected on the Balance Sheet with correct balances as of the end of the period is the only way to ensure that all activity is reflected on the Income Statement. As a result, my suggestion for the close process is to start with the Balance Sheet and work your way down through the accounts reconciling them individually. Bank account, credit cards, and loans are the easiest and most obvious. These are the things that most companies are getting right. The things I see most often missed are accounts such as Inventory, Prepaid Expenses, and Accrued Expenses. These are the areas that many companies are only really doing a hard reconciliation on quarterly or at year-end, if that. In doing that though, they are risking material errors that may be significantly skewing the results of the Income Statements they’re looking at on a monthly basis.

Why Monthly Make Sense

Once I provide some examples of the sorts of accruals that should be done, how to determine them, and how to document them, the next questions I get are - Is this really necessary? Do we really need to do this monthly? Well…ultimately, my answer is yes. I’ve seen plenty of companies just record accruals on an annual basis because they think it’s going to be too much trouble monthly. From a practical standpoint, the biggest problem with that approach is that the December and January numbers each year are going to look really off, so it becomes difficult to perform any sort of monthly financial analysis. With the proper procedures and templates in place, monthly accruals are often pretty straightforward and don’t have to be time consuming.

Compliance Requirements

Further, there are DCAA requirements that support the process of monthly adjustments. The SF1408 Pre-Award Survey is the checklist that DCAA follows to determine whether a prospective contractor’s accounting system is acceptable for award of a prospective contract, and it is one of the very first interactions that many contractors have with DCAA.

Per SF1408 Pre-Award Survey, item 1:

  • EXCEPT AS STATED IN SECTION I NARRATIVE, IS THE ACCOUNTING SYSTEM IN ACCORD WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES APPLICABLE IN THE CIRCUMSTANCES?

While there are certainly cost / benefit and Materiality Principle considerations to be made here, the Matching Principle is one of the cornerstones of accounting and is supported by the Principle of Periodicity in Generally Accepted Accounting Principles (GAAP). It requires that businesses use the accrual basis of accounting and match business income to business expenses in a given time period. Accrual basis accounting means that expenses should be booked in the period incurred. Consistency is also a requirement of GAAP, which is technically violated if accruals are performed in some months but not others. DCAA Auditors will often ask to see wage and other accruals as evidence of GAAP accounting as part of this survey.

Per SF1408 Pre-Award Survey, item (g):

  • Interim (at least monthly) determination of costs charged to a contract through routine posting of books on account.

Since contract costs are required to be determined on at least a monthly basis (including indirect costs), it makes sense to perform adjustments and reconciliations of account monthly as well to ensure that the costs charged to any given contract are accurate. When it comes time for your pre-award survey, the DCAA auditor is likely to ask for monthly GAAP financial statements as evidence of interim reporting. Clearly, this monthly process is most critical for cost-type contracts, but it is best practice across the board, regardless of whether there are any cost-type contracts in place. Having that structure already in place can go a long way toward a smooth transition when you do find yourself on the verge of starting a cost-type effort. In addition, it will provide a solid financial foundation for business management and execution both for any T&M or FFP contracts that you have in place, and the business as a whole.

How Redstone GCI can Help

Redstone GCI has a Collaborative Accounting team with extensive experience available to assist contractors with all manner of GL accounting support. We provide ongoing real-time accounting services, periodic review, establishment of close processes, client training, and more. Our team would be happy to discuss any potential issues or concerns facing your organization as it relates to these areas.

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Written by Amanda L. White, CPA

Amanda L. White, CPA Amanda White is a Senior Managing Consultant within Redstone GCI’s Collaborative Accounting Solutions Group based in Huntsville, AL. She is a Certified Public Accountant with almost two decades of progressive experience in the accounting and government contracting industry. Her experience includes a combination of internal and external accounting support where she has assisted both government contractors, as well as a diverse range of other industries. Her unique collection of experience and knowledge on a wide range of accounting software, coupled with her practical experience and focus on process improvement and efficiency provides a strong skillset for support of our government contractor clients. Her role includes leadership of ongoing collaborative accounting engagements where she provides controllership support of Redstone GCI clients. She additionally serves as a subject matter expert on accounting process improvement, implementation of internal controls and other areas as part of the firm’s support of the DFARS Business Systems. Professional Experience Amanda first started working in industry accounting for a large commercial service provider while in college. She gained early experience as a regional billing manager and managed payroll for hundreds of employees, while also handling a dual role as an operations manager. After completing her bachelor’s degree, she went to work in public accounting where she gained additional exposure in GL accounting, as well as tax, audit, and consulting. Following her initial time in public accounting, Amanda served as the Business Operations Manager for an engineering services company supporting the defense and aerospace industry. She wore many hats in that position and not only maintained and closed the books, but also handled all CFO‐level financial reporting and budgeting, indirect rate calculations, provided bid and proposal support, implemented internal controls, developed processes and procedures to help ensure DCAA‐compliance, etc. Although she left that role to start her own practice in 2011, she has continued to work with that company as a contractor and has now supported them for more than 10 years. Amanda spent the next 6 years building her own local practice supporting local small businesses. Her team provided startup support, ongoing accounting, income tax planning and preparation, and consulting to both commercial entities and small government contractors. In addition to completing her MBA during this time, she successfully grew that business, and her practice was acquired by a local CPA firm in 2017. She then took over the task of heading that firm’s Accounting Services Dept, and most recently served as a Senior Manager. In that role, Amanda managed a team of accountants providing all levels of GL accounting support to clients across the country in numerous industries. In addition to providing review and oversight to her team of 12 accounting staff members, Amanda was responsible for developing and delivering training content not only to the team but also for clients, implementing processes and procedures both internally and externally, and functioning as a subject matter expert. In this capacity, she executed process improvement projects to help clients maximize accounting efficiency, leverage their accounting systems to provide accurate and effective financial data to facilitate management decision‐making, and increased profitability. Amanda’s operations exposure, and extensive background in GL accounting in numerous industries, combined with her experience starting and growing her own business enables her to provide robust guidance and support to our clients. Education Amanda earned an Associate of Science in Entrepreneurial Management from Calhoun Community College. In addition, she earned a Bachelor of Science in Accounting degree and a Master of Business Administration degree from The University of Alabama in Huntsville. Affiliations Certified Public Accountant – State of Alabama QuickBooks Pro Advisor Alabama Society of CPA’s (ASCPA) American Institute of Certified Public Accountants (AICPA)

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Compliant Accounting Infrastructure, DCAA Audit Support