The most common CAS (Cost Accounting Standards) exemption for most businesses is the small business exemption. Most contractors understand that as long as they’re small, CAS is a non-issue. What happens when you’re approaching your NAICS cap and headed toward the dreaded “other than small” status?
When you accept a fully funded cost-reimbursable government contract, it comes along with the FAR contract clause 52.232-20, Limitation of Cost. This clause places a requirement on you to notify the Government when:
As we outlined in Applicability of DFARS Business System Rules to Small Businesses, small businesses are exempt from Cost Accounting Standards and therefore are not subject to the business system rules, based on the requirements for inclusion in the Business System Clauses as set out in DFARS. DFARS Case 2009-D038 – Defense Federal Acquisition Regulation Supplement; Business Systems-Definition and Administration, final rule issue February 24, 2013 in the Federal Register specifically stated:
In 1948 the Armed Services Procurement Regulations (ASPR) was issued as a result of the Armed Services Procurement Act, remaining in place until 1978. ASPR defined direct cost as “any cost that is specifically identified with a particular final cost objective, but not necessarily limited to items that are incorporated in the end product as material or labor.” This is a fairly broad definition and clearly establishes that direct cost includes more than direct material and direct labor. The APSR also discussed Other Direct Costs (ODC), which were costs that were not material nor labor and provided examples, such as “travel and subsistence, consultants, telephone, computer costs and report reproduction.”
Have you ever considered the power of the Pay Code function in Unanet? Pay Codes are the earnings and leave categories your organization uses to track and classify reported hours on employees’/subcontractors’ timesheets.
Recently, there has been much discussion around comments made by Katie Arrington, the special assistant to the Assistant Secretary of Defense for Acquisition for Cyber in the Office of the Under Secretary of Acquisition and Sustainment in DoD. She made the following statement before a roomful of vendors at the PSC meeting in Arlington, VA.
FAR Part 31.205 -1 – Public Relations and Advertising Costs
“Marketing is the activity, set of institutions, and processes for creating, communicating, delivering, and exchanging offerings that have value for customers, clients, partners, and society at large.” (American Marketing Association)
“Advertising is the action of calling something to the attention of the public especially by paid announcements.” (Merriam-Webster)
“Public relations (PR) is a strategic communication process that builds mutually beneficial relationships between organizations and their publics.” (Public Relations Society of America (PRSA))
The budgeting process for any company can be a daunting process. But, like most things, hard work pays off, and establishing a detailed budget is a critical element to ensure a healthy and profitable company.
It’s everyone’s least favorite time of year. That’s right, tax season. For those of us who no longer work in public accounting, this time of year is now a welcome reprieve; although for us, it also marks the start of incurred cost season. If you’re not sure what an Incurred Cost Submission is or have questions about that topic, visit our website for a variety of resources.
Unless you have undergone a DCAA Accounting System audit under the criteria in DFARS 252.242-7006 (a.k.a. DFARS Accounting System Audit), you do not know what a comprehensive audit is. To start with there are eighteen criteria, some of which are as broad as “Accounting practices in accordance with standard promulgated by the Cost Accounting Standards Board, if applicable, otherwise, Generally Accepted Accounting Principles.” This leaves the door open to pretty much endless questions. But don’t worry, DCAA has narrowed it down to only 27 questions.