In August of 2023, the Defense Contract Audit Agency (DCAA) changed what is used to refer to as Mandatory Annual Audit Requirements (MAARS) 13 audits to Real-Time Audits of Purchase Existence and Consumption. This change was to eliminate the mandatory part of the requirement and introduce greater flexibility based on the auditor’s risk assessment of the contractor.
In August of 2023, the Defense Contract Audit Agency (DCAA) changed what it called Mandatory Annual Audit Requirements (MAARS) 6 audits to Real-Time Audits of Labor. This change was to eliminate the mandatory part of the requirement and introduce greater flexibility based on the auditor’s risk assessment of the contractor.
CAS 410 provides the criteria for allocating business unit general and administrative (G&A) expenses to final cost objectives based on their causal beneficial relationship. The standard requires that one of three cost input bases must be used unless there is a special allocation to a particular final cost objective. Contractors should select the cost input base which best represents the total activity of a typical cost accounting period for the production of goods and services for the business unit.
This standard vastly expands on the FAR requirements related to direct and indirect costs. FAR 31.202 and FAR 31.203 give a basic definition of each, but little else. CAS 418 provides guidance on accumulating indirect cost pools, including service centers and overhead costs. Furthermore, it requires the costs be allocated on the causal or beneficial relationship between the indirect cost pool and the related cost objective. In addition, CAS 418 requires each business unit to have written policies and practices for classifying costs as direct or indirect.
Being a government contractor, whether you’re a novice or a veteran, comes with its own unique set of challenges. One of the most significant is the constant need to optimize indirect rates. These rates can be the deciding factor between securing new contracts and expanding your business or remaining static and missing out on opportunities. As your business grows and evolves, your indirect rates should follow suit. Regularly evaluating your rates to ensure they align with your company’s strategic plan and maximize the recovery of your allowable costs is crucial to building a thriving company.
In government contracting, three critical sets of guidelines govern the recognition of expenses for financial reporting and cost accounting practices: Generally Accepted Accounting Principles (GAAP) govern financial reporting, and Federal contracts require Federal Acquisition Regulations (FAR) part 31 and Cost Accounting Standards (CAS). While both frameworks are focused on assigning expenses to the appropriate accounting period, they have distinct roles and implications for government contractors. This article explores the key differences between CAS and GAAP, focusing on their significance and application in government contracting.
When contracting with the Federal Government on a cost reimbursement basis, the Government will need to ensure that your accounting system will support the complexity of this type of government contract. To achieve this, the U.S. Government has established various regulations and procedures to assess the accounting systems of prospective contractors. The main instrument is the SF1408: Pre-Award Survey of Prospective Contractor Accounting System. This article provides a comprehensive overview and explanation of the SF1408, its purpose, and its significance in the pre-award process.
Comparison to FAR
Like CAS 401, CAS 402, and CAS 405, CAS 406 is part of modified CAS coverage and is one of the first CAS standards a company encounters. It likely will not call for any changes to the company’s cost accounting system if you are compliant with FAR 31.203(g)(2) (Indirect costs). FAR states that for contracts not subject to CAS:
Does a Government default due to the debt ceiling result in a Government shutdown? Well maybe. It all depends on how the Government reacts or directs its contracting officers to react. A default is different than the – shall we say it – normal – yes, we said it – Government shutdowns we have been dealing with for the past decade or so.
Comparison to FAR
Like CAS 401 and CAS 402 (see previous blog posts on these CAS Standards), CAS 405 is part of modified CAS coverage and is one of the first CAS standards a company encounters. Compliance with this standard will likely not call for any changes to the company’s cost accounting system if the company is compliant with FAR 31.201-6 (Accounting for Unallowable Costs) because the FAR clause has more requirements than CAS 405.