Fiscal Year 2019 GSA Per Diem Rates Released

RCGI-Fiscal Year 2019 GSA Per Diem Rates Released

On August 14, 2018 the U.S. General Services Administration (GSA) released the Fiscal Year 2019 travel per diem rates, taking effect October 1, 2018. These represent the maximum reimbursable amounts allowed for expenses incurred by federal employees. Making adjustments based on the current economy is important, as well as taking into consideration local price variations  in what is termed “Non-Standard Areas.”

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

Clarifying Costs: Bid & Proposal and Independent Research & Development

RCGI- Clarifying Costs-Bid & Proposal and Independent Research & Development

Quite often, in practice, we see contractors classifying too much cost as IR&D or more commonly, B&P expense.  In a proposal setting, experts from across your company support the development of a compliant proposal.  The question we see frequently is: “Who should be charging to B&P Projects?”  While a business may want to capture the total cost of a proposal effort, including administrative support from G&A staff, it is not wise to have these personnel charge to a B&P project where their labor will absorb overhead. 

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

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

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

Possible Recoveries from a WD (Wage Determination) Increase/Decrease

Wage Determination Fact Finding

In ASBCA Case No. 61040, 61101, Sonoran Technology appeals their claim for an equitable adjustment due to an increase in the Service Contract Act Wage Determination after contract award.  The solicitation that controlled this contract award included a SCA wage determination and a Collective Bargaining Agreement (CBA). The bidders were required to use the current SCA wage determination (at the time of the bid) in the formulation of their proposals submitted to the Government.  For future increases in SCA wages and/or benefits, the FAR and the contract have provisions/clauses which cover a contract price change for a wage determination for a multi-year contract.  The issue here whether a new wage determination, incorporated into the contract, prompted a responsibility for the government to adjust the contract price to compensate Sonoran for a corollary increase in its state gross receipts taxes.

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

What to Expect from a DCAA Floor Check

The objectives of a timekeeping system are to ensure that labor costs are accurately and timely identified as either direct or indirect in the accounting system.  For certain contract types (e.g. cost-type), these accumulated labor costs are reported and billed to the customer.  It is the contractor’s responsibility to ensure that the labor costs posted in the timekeeping system are proper and reliable. 

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

Travel Reimbursement Expenses – Did You Know?

 

Having a well-defined travel policy is important to your employees, managers, accounting staff, contract customers, and auditors. A one-size-fits-all policy may be suitable for some companies, while others may benefit from having multiple policies focused on the business base and/or contract requirements

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