Redstone Government Consulting Blog (3)

On August 9, 2023, DCAA issued guidance to its auditors revising the real-time labor and material testing requirements. DCAA historically referred to these procedures as Mandatory Annual Audit Requirements (MAARs) 6 and 13. DCAA states in its guidance what its auditors need to know is that “[l]abor and material are two of the most significant cost elements billed under government contracts. As such, one of the primary reasons … [DCAA] audit[s] labor and material costs incurred is to determine the accuracy of the charges. The real-time verification of these costs as they are incurred provides valuable confirmation of the accuracy of the charges and can only be accomplished during the accounting period to which they apply.” I cannot really argue with this statement.

The year 2023 was a great one for the Unanet Community. I ended the year attending the 4^th Quarter Huntsville Unanet Users Group (HUUG) Meeting, where there was an Ugly Christmas Sweater Competition that I didn’t win. HUUG is such a unique group of Unanet Users in the Huntsville Community. If you are a Unanet user in the Huntsville area and have not already joined, I recommend you do. Reach out to me, and I can provide you with the contact information to get added to the group. If you are outside of the Huntsville area, look for Unanet user groups near you to connect with a peer group for a sense of community, networking and support. I think you will find it beneficial.

Our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2024 cap amount is $646,000. Below, we have provided the compensation caps going back to 2016.

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.

The FAR Council issued an interim rule, effective December 4, 2023, which implements the requirements of the Federal Acquisition Supply Chain Security Act (FASCSA). This included three new FAR clauses which prohibit the delivery or use of “covered articles” subject to a FASCSA order in the performance of a government contract.

The Government can terminate its contracts, in whole or in part, through special contract clauses referred to as “termination clauses.” Terminations can be frequent occurrences and can happen for numerous reasons, such as lack of funding, bid protests, changes in military strategy, technological advancement, federal operations, or national political agendas that change the government’s needs. FAR 49.201(a) [Termination of Contracts] states, “…A settlement should compensate the contractor fairly for the work done and the preparations made for the terminated portions of the contract, including a reasonable allowance for profit….” This compensation decision, unfortunately, is made through the government’s lens. A contractor must be focused on telling their story and providing proof through adequate documentation of claimed costs.

QuickBooks is considered a government-compliant accounting system and can definitely get the job done for a lot of small government contractors. However, there may come a time when you need to change your accounting system to something that is designed with government contractors in mind.

Mandatory Annual Audit Requirements (MAARs) 6 (labor) and 13 (material purchases) are two of DCAA’s mandatory annual audit requirements performed for incurred cost audits. These MAARs, established decades ago, have customarily been performed on a “real-time” basis within the year in which the costs were incurred. However, DCAA has recently revised their audit guidance in a Memorandum for Regional Directors (MRD) titled “Revised Procedures for Real-Time Audits of Labor and Purchase Existence and Consumption.”

New Rule for Filing 1099s: The IRS rule TFA 23O1 reduces the electronic filing requirement from a threshold of 250 Information Returns down to 10.

Yes, you read that correctly. If you file more than 10 Information Returns after January 1, 2024, you are now required to submit those forms electronically. Employers must calculate the total number of Information Returns to determine if they meet the threshold, including 1099s, W-2s, 1098s, etc.

This means if you have a total of 4 Form 1098s and a total of 6 Form 1099-NEC, you must file electronically. All forms must be submitted to the appropriate party and through the IRS site utilizing IRIS or the “Information Returns Intake System” by the due date.