Redstone Government Consulting Blog (33)

ASC 606, Revenue from Contracts with Customers, had an impact on the way many contractors recognized revenue related to contracts with the Federal Government. Redstone has covered this topic a couple of times (January 26, 2021 Government Contractor Challenges in 2021 Webinar and May 6, 2021 MossAdam/Redstone Webinar Compliance Changes for Government Contractors). ASC 606 also impacts the recognition of sales commissions. The overarching GAAP matching principle requires that the expense of sales be matched to the recognition of the related revenue.

Overview:

• EEO-1 reporting has been extended once again. The deadline is now August 23rd. Additionally, they have made an improvement to the reports feature on the website to help users have a better experience. 
• EEO Tabulation data from 2014 to 2018 is now available. 
• Biden's new Executive Order (EO) takes aim at noncompete agreements.
• A potential major challenge at the OFCCP could impact the 2020 Final Rule "Procedures to Resolve Potential Discrimination."
• I-9 flexibility is extended until August 31, 2021.
• The US Department of Labor (DOL) announced a Notice of Proposed Rulemaking to create standards and procedures to implement and enforce President Biden's earlier Executive Order 14026 that will increase the federal contractor minimum wage to $15 per hour.
• Department of Labor issued All Agency Memorandum 237 increasing the Health and Welfare benefit applicable to SCA-covered contracts.

This short video and article provide insights into FAR Part 31 – the Cost Principles. We explain what FAR Part 31 cost principles are, when they apply, and why they are important. We also discuss what contracts are subject to the cost principles, how they cannot apply to only some of your contracts and not others, and the impact on your accounting system to accommodate the cost principles.

In my years as a CPA and consultant I’ve worked with many small businesses that have asked for input on what they need to be doing to get more reliable financial data. Usually, it’s business owners looking for ways to be able to make important decisions faster, but lately it’s often companies new to government contracting that are trying to figure out what they need to be doing to keep clear of problems with DCAA. In either scenario, one of my first suggestions is a formal monthly close process. When I say “formal”, that doesn’t mean that it has to be cumbersome and complicated. If the business financials are relatively simple, then that close process can also be fairly simple and still be effective. But it needs to be structured, with a specific checklist in place as to the procedures that are to be performed, the order in which they are to be done, who is responsible for each task, and target deadlines for each. That recommendation then raises the next question – what do you mean by “close”?

Redstone GCI has been pleased to be a part of the Early Adopter testing program for Costpoint version 8.1. There have been numerous changes and improvements within the system in all modules, but we would like to highlight the below areas that our consultants found most useful.

The focus of fraud used to be primarily on defense contractors, health care providers and health care suppliers. However, other companies are now being exposed to the Federal Claims Act (FCA) including software companies, private equity financiers, insurance companies, and educational institutions. Additionally, fraud is not just related to companies receiving the funds.

In January of this year (2021), we told you that the United States Department of Labor (DOL) under the Trump administration announced a final rule clarifying the standard for whether a worker is an employee or an independent contractor under the Fair Labor Standards Act (FLSA). This rule reaffirmed the “economic reality” test as the primary factor for determining employee status. The final rule was published in the Federal Register on January 7, 2021 and the Rule was set to have an effective date of March 8, 2021.

If having unbilled receivables is a new concept based on your experience with other software systems, you may find it a relief that having an unbilled balance is not necessarily bad or wrong. Unbilled Receivables is the offsetting account for billing and revenue postings in Deltek Costpoint. When a billing is posted, the Billed Receivables account is debited, and Unbilled Receivables account is credited. For the revenue posting, the Unbilled Receivables account is debited and Revenue account credited. Hence, if the billing and revenue posting amounts are the same, the offsetting Unbilled Receivables account will be zero. That sounds great, however, there may be situations where billing and revenue do not or should not match, which then creates a balance in the Unbilled Receivables account. So, when is it okay to see an Unbilled Receivables balance?

Overview:

• EEOC launches new landing page that is a one-stop-shop for information regarding sexual orientation and gender identity workplace rights.
• The White House seeks to continue providing remote work opportunities for federal employees.
• The DOL makes plans to update the DBA and Related Acts Regulations.
• EEO-1 data collection is now open and due July 19^th.
• US Supreme Court upholds the Affordable Care Act in California v. Texas.
• Juneteenth is now a federal holiday.

Have questions regarding what travel costs are allowable? Do you think the travel regulations say you can never have first-class airfare reimbursed? Or do you think the regulation says you are restricted to a compact rental car? For the answer to these questions and more, check out our video on travel regulations and myths!