The Redstone GCI Costpoint group finalized participation in the Early Adopter 8.1 testing program at the end of June. In this wrap-up we want to focus on the Projects and Contracts modules of Costpoint, as well as some additional highlights for Time and Expense. We are thankful for the opportunity to partner with Deltek on this program and are excited to see the new release of the update in the future.
On July 9th, 2021, the Department of Defense (DoD)issued a final rule in the Federal Register to implement 10 U.S.C. 2330a which requires the DoD to establish a data collection system to provide certain management information about an awarded contract or task order that is valued in excess of $3 million. This new rule is applicable for the following service acquisition portfolio groups:
- logistics management services
- equipment-related services
- knowledge-based services
- electronics and communications services
You may read the entire rule here.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration, Government Compliance Training, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, System Award Management (SAM), Government Regulations, DOD Contractors
ASC 606, Revenue from Contracts with Customers, had an impact on the way many contractors recognized revenue related to contracts with the Federal Government. Redstone has covered this topic a couple of times (January 26, 2021 Government Contractor Challenges in 2021 Webinar and May 6, 2021 MossAdam/Redstone Webinar Compliance Changes for Government Contractors). ASC 606 also impacts the recognition of sales commissions. The overarching GAAP matching principle requires that the expense of sales be matched to the recognition of the related revenue.
Topics: Compliant Accounting Infrastructure, Incurred Cost Submission, Defense Contractors, Incurred Cost Proposals, DCAA Audit Support, Accounting & Billing System, Government Regulations, DOD Contractors, Federal Acquisition Regulation (FAR)
Redstone GCI has been pleased to be a part of the Early Adopter testing program for Costpoint version 8.1. There have been numerous changes and improvements within the system in all modules, but we would like to highlight the below areas that our consultants found most useful.
The focus of fraud used to be primarily on defense contractors, health care providers and health care suppliers. However, other companies are now being exposed to the Federal Claims Act (FCA) including software companies, private equity financiers, insurance companies, and educational institutions. Additionally, fraud is not just related to companies receiving the funds.
Are You SURE All of Your Workers Are Properly Classified?
In January of this year (2021), we told you that the United States Department of Labor (DOL) under the Trump administration announced a final rule clarifying the standard for whether a worker is an employee or an independent contractor under the Fair Labor Standards Act (FLSA). This rule reaffirmed the “economic reality” test as the primary factor for determining employee status. The final rule was published in the Federal Register on January 7, 2021 and the Rule was set to have an effective date of March 8, 2021.
If having unbilled receivables is a new concept based on your experience with other software systems, you may find it a relief that having an unbilled balance is not necessarily bad or wrong. Unbilled Receivables is the offsetting account for billing and revenue postings in Deltek Costpoint. When a billing is posted, the Billed Receivables account is debited, and Unbilled Receivables account is credited. For the revenue posting, the Unbilled Receivables account is debited and Revenue account credited. Hence, if the billing and revenue posting amounts are the same, the offsetting Unbilled Receivables account will be zero. That sounds great, however, there may be situations where billing and revenue do not or should not match, which then creates a balance in the Unbilled Receivables account. So, when is it okay to see an Unbilled Receivables balance?
DCAA’s Authority for Interim Vouchers
DCAA is given the authority under DFARS 242.803(b) to approve interim vouchers for DoD. DFARS 242.803(b) states DCAA will approve interim vouchers using sampling methodology for provisional payment after a prepayment review. This also includes reviewing completion/final vouchers and issuing a DCAA Form 1, Notice of Contracts Costs Suspended and/or Disapproved when DCAA questions the allowability of costs.
The calendar year ended December 31st and you are closing your books and gathering information for your incurred cost submission that is due June 30th. There is one more requirement you should consider that may have been overlooked. Does your company meet the requirement to input IR&D costs into the Defense Technical Information Center (DTIC)?
DFARS Class Deviation 2020-O0021 Revision
On January 15, 2021, the Principal Director at Defense Pricing and Contracting (DPC) issued a memorandum on the CARES Act Section 3610 Reimbursement Requests, DFARS Class Deviation 2020-O0021, Revision 2. This memorandum revises and supersedes the DFARS Class Deviation 2020-O0021 Revision 1 issued on October 14, 2020. The only revision is to extend the period for which paid leave must be taken from March 27, 2020 through December 11, 2020 to March 27, 2020 through March 31, 2021. The remainder of the memorandum remains unchanged and details are included in Redstone GCI’s blog.