DCAA – The Hidden Cost of Audits

Where does DCAA’s View of the Contractor and their Role in Acquisition Come From?

DCAA Auditor Training

DCAA website provides that new auditors receive in-depth professional training from DCAA’s Defense Contract Audit Institute (DCAI), along with on-the-job training at their assigned field audit office. DCAI is located in Atlanta, GA and provides auditors with an excellent basis on which to start their careers in contract audit. Many at Redstone GCI can speak from personal experience that, once you get past the exciting MARTA ride from the airport, the instructors at DCAI provide a good hands-on learning environment. However, we are not sure if it is a subliminal message piped into the classroom or local indoctrination at assigned field offices, but the auditors are coming away with the impression that no contractors can be trusted, and a good audit opinion has to include questioned cost.

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Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Incurred Cost Submission, Defense Contractors, DOD IG, Government Compliance Training, DFARS Business Systems, Incurred Cost Proposals, Cost-Type Contracts, DCAA Audit Support, FAR, Government Regulations, DOD Contractors, Cost Accounting Standards (CAS)

Cost Accounting Standards Disclosure Statement Tips

In previous blogs, we have recommended preparing a CAS Disclosure Statement (DS) soon after emerging from small business status. We also recommended reviewing your cost accounting practices prior to preparing a Disclosure Statement to prevent having to change afterwards and ending up requiring a cost impact statement. So, by now you are probably wondering what this mythical beast is and what is the big deal about preparing it.

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Topics: Compliant Accounting Infrastructure, Cost Accounting Standards (CAS)

Unanet: Maximizing Your Planning

Unanet’s robust project management and budgeting features are primary reasons some of our clients choose Unanet as their accounting system of choice. One of our main goals during an Unanet implementation is to utilize as many of the project management features in the system as possible and train our clients on maintaining the correct information to manage their work properly. What are your project management and budgeting needs? The following options are available in Unanet:

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Topics: Compliant Accounting Infrastructure, Unanet

The Perils of Cost Accounting Practice Changes

Previously, we discussed how a company ends up with CAS covered contracts.  This month we are going to talk about some of the further fun with CAS.  We recommended preparing a CAS Disclosure Statement soon after emerging from small business status,

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Topics: Compliant Accounting Infrastructure, Cost Accounting Standards (CAS)

The Path to Cost Accounting Standards (CAS)

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?

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Topics: Compliant Accounting Infrastructure, Cost Accounting Standards (CAS)

Limitation of Cost or Funds – The Burden Falls on You

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:

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

Control Environment – The Expectations are Huge

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:

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

Direct Costs in Government Contracts – Then and Now

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.” 

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

The Power of Pay Codes in Unanet

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.

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Topics: Compliant Accounting Infrastructure, Accounting & Billing System, Unanet

DFARS Cybersecurity Costs are Allowable, So What?

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.

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Topics: Compliant Accounting Infrastructure, DFARS Business Systems