DoD-IG has two Opposing Views on DCAA

DoD-IG goes after DCMA for not supporting DCAA Findings

On February 26, 2021, the DoD-IG issued an audit report raising significant concern about the actions taken by DCMA Administrative Contracting Officers (ACOs) in relation to DCAA audit findings. The Finding section of the DoD-IG report found that out of 30 DCAA audit reports at two of the largest DoD contractors, 14 were not properly addressed per Federal Acquisition Regulation requirements by the cognizant ACO. Our guess and POGO believes the large DoD contractors are Lockheed Martin and Boeing – but this is only our guess. The DoD-IG report goes on to state that: “As a result, DCMA contracting officer actions on the eight audit reports may have resulted in improperly reimbursing DoD contractors up to $97 million in unallowable costs on Government contracts. In addition, because DCMA contracting officers did not take timely action on six audit reports, they delayed the correction of CAS noncompliances and the recovery of any increased costs due to the Government.” The report goes on to state that: “The Defense Contract Management Agency Director agreed with all five recommendations,” including reviewing ACO decisions to “Disallow and recoup any unallowable costs not previously disallowed.” (Evaluation of Defense Contract Management Agency Actions Taken on Defense Contract Audit Agency Report Findings Involving Two of the Largest Department of Defense Contractors – DoD-IG-2021-056, Dated February 26, 2021)

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Topics: Litigation Consulting Support, Contracts Administration, Defense Contractors, DOD IG, DCAA Audit Support, Government Regulations, DOD Contractors, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

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, Government Regulations, DOD Contractors, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Oh, My Goodness I Think We Are CAS Covered! Life Changing? Maybe Not.

Let’s Set the Stage

So as a contractor you have received several cost-based contracts (i.e., subject to FAR part 31), however they have all been less than $7.5M. You are flying under the Cost Accounting Standards (CAS) radar. You get a $9M cost-based contract that does not meet any of the exceptions to CAS covered listed at 9903.201-1(b) – categories of contracts and subcontracts exempt from all CAS requirements. The dreaded “trigger contract.”

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Topics: Defense Contractors, Cost-Type Contracts, Government Regulations, DOD Contractors, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Does Your Company Qualify as a “Major Contractor” for IR&D Reporting?

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)?

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Topics: Incurred Cost Submission, Incurred Cost Proposals, Accounting & Billing System, Cost Accounting Standards (CAS)

FASB 842 Lease Accounting – What is the Impact on Government Cost Accounting?

The Financial Accounting Standards Board (FASB) issued Topic 842, Leases, in February 2016 effective for fiscal years beginning after December 15, 2018. The change was “to increase transparency and comparability among organizations by recognizing lease assets and lease liabilities on the balance sheet and disclosing key information about leasing arrangements.” For the past 40 years or so, operating leases were only required to be presented in the disclosure and were off-balance sheet transactions. Other than the new asset (Right to Use asset) and a related liability on the balance sheet, the impact on the income statement (a single line item for lease expense) and cash flow are unchanged, at least under GAAP. International Financial Reporting Standards (IFRS) now requires all leases be treated similar to capital leases (Topic 842 calls these finance leases). So, under IFRS there will be more unallowable interest to properly account for on Government proposals and contracts incorporating FAR Part 31.

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Topics: Non-US government contractor, Cost and Pricing and Budgeting, Contracts Administration, Cost-Type Contracts, Accounting & Billing System, DOD Contractors, Cost Accounting Standards (CAS)

CARES Act Section 3610, DPC DFARS Class Deviation and Guidance

On August 17, 2020; Acting Principal Director for Defense Pricing and Contracting issued two memos providing guidance in support of DFARS Class Deviation 2020-O0013 and 2020-O0021 – CARES Act Section 3610 Implementation. There is also a memo providing contracting officers with a template for a Memorandum for Record to document the file for the issuance of the Section 3610 related contract modification.

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Topics: Contracts Administration, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, Defense Procurement and Acquisition Policy (DPAP), Accounting & Billing System, DOD Contractors, Cost Accounting Standards (CAS), COVID-19

DCAA COVID-19 Guidance – Still in a Wait and See, Holding Pattern

We Lifted the Vail

A few months back we submitted a request to DCAA under Freedom of Information Act. Based on the DPC guidance referencing both DCAA and DCMA as playing a key role in support of the rest of the DoD Acquisition Community, we expected DCAA would have a significant number of documents disclosing this key role. Turns out, not so much. All we got was a single document listing 13 frequently asked questions (FAQs) DCAA has been fielding from their auditors, dated July 31, 2020.

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Topics: Cost and Pricing and Budgeting, Contracts Administration, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, Defense Procurement and Acquisition Policy (DPAP), DOD Contractors, Cost Accounting Standards (CAS), COVID-19

Deltek Costpoint 8 is Coming: 5 Things You Need to Know

5 Things You Need to Know Before Your Update

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Topics: Business Systems Review, Cost and Pricing and Budgeting, Defense Contractors, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, DOD Contractors, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

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)

Why Bid and Proposal Cost is so Confusing to Government Contractors

Accounting for Bid and Proposal (B&P) Explained

Bid and Proposal is a topic that comes up with our contractor clients on a regular basis. Most questions surrounding this topic involve: whom at the contractor should be charging B&P, especially, contractor personnel that typically charge overhead or G&A. We understand why this is confusing. It is our opinion that the guidance per FAR (Federal Acquisition Regulations) and CAS (Cost Accounting Standards) regarding this topic is unclear and leaves contractors scratching their heads trying to be compliant.

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Topics: Defense Contractors, Incurred Cost Proposals, Accounting & Billing System, Cost Accounting Standards (CAS)