Redstone Government Consulting Blog (69)

A common misconception occurs when the term “DCAA-compliant accounting system” is used to describe a particular brand of accounting software. Sure, some accounting software systems and its components are designed specifically to address compliance with government regulatory requirements. But just because you buy it and use it does not mean you automatically have a compliant accounting system. There are several requirements of the accounting system and its environment that must be in place to ensure DCAA compliance, and there are a multitude of ways to meet these requirements without a significant investment in the purchase, implementation, training, and maintenance of a really expensive accounting system. Small businesses looking forward to bidding on prime, cost-type contracts must maintain DCAA compliance while also being as cost effective as possible to keep indirect rates at a competitive level. There are many options to choose from, and business owners must determine the best fit for their company. Be sure to consider all of the options:

In 2014 DCAA quietly rolled out its new audit report format which generated some obvious questions:

In more than a few instances, government contractors receive a DCAA inquiry which is not directly related to any particular audit. In many cases, the request involves a Contractor Survey (or a Contractor Internal Control Questionnaire) which is requested annually to facilitate DCAA’s audit planning (at least for the moment given DCAA’s propensity to routinely change audit priorities).   For repetitive annual requests which are essentially the same set of questions received every October as DCAA begins its new fiscal year, the tendency is to complete the questionnaire without asking DCAA to explain what contractual clause requires this action (don’t ask, there is none).

The judgments rendered by the ASBCA in the Raytheon Co., Space & Airborne Sys, ASBCA Nos. 57801, 57803, 58068 resulted in the resolution of a number of issues concerning CAS (Cost Accounting Standards) cost impacts associated with unilateral changes in a contractor’s cost accounting practices. There were five basic issues; the Government prevailed on three, the contractor prevailed on one, and one was undecided (to be decided in the actual trial given that the current decisions were in reference to the parties’ cross-motions for summary judgment).

Over the past few months Redstone GCI has made several significant investments in our software services practice. For many years we have supported our clients with Deltek solutions, as well as many of our small business clients with QuickBooks assistance. In July, we added a new staff member to our ranks to better support our Deltek clients. Jimmy Baker will be leading our Costpoint and GCS support services, and we are excited to introduce him to our existing clients. Jimmy has been working with Costpoint for over 20 years decades, and has a great deal of experience working with larger system implementations, as well as new implementation and design for smaller companies utilizing Costpoint. He most recently assisted a very large government contractor with worldwide integration and conversion to Deltek Costpoint.

The Fair Labor Standards Act of 1938 (FLSA), which is administered and enforced by the Wage and Hour Division (WHD) of the Department of Labor (DOL) imposes, among other things, minimum wage and overtime pay requirements. It is certainly nothing new and has been a hot topic amongst Human Resources professionals over the past months as President Obama directed the Secretary of Labor to update the regulations. With much speculation and rumblings of possible changes, all have been anxious for the impending proposed rule to be revealed.  

In compliance with 41 U.S.C 1908, adjustments were made to statutory (and non-statutory) acquisition thresholds to accommodate inflation, using the Consumer Price Index. Government Contractors should take note of the threshold changes and be prepared to accommodate the revised thresholds beginning in October 2015 by make the appropriate adjustments to respective policies, procedures, and practices.

Estimating System Deficiencies

In its recent report (DODIG 2015-139), the DOD-IG (Inspector General) found that DCMA Contracting Officers failed to comply with DFARS timing requirements related to contractor business systems (DFARS 215,407-5-70 and DFARS 252.242-7005. In this case, the IG evaluated actions (or more accurately inactions) on 18 DCAA audit reports related to contractor estimating systems which are subject to the criteria in DFARS 252.215-7002. The DFARS Business Systems rule includes no time frames concerning government audits of contractor systems; however, once a government audit report is (finally) issued, DFARS has the following time-requirements (“requirements” used loosely because due dates applicable to the government are routinely ignored as evidenced in the IG report):

On June 18, 2015, as a retired “civil servant” whose personnel records now reside with OPM, I was notified by OPM that OPM had “recently become aware of a cybersecurity incident that may have exposed my personal information”.

In its report dated March 25, 2015, DCAA issued its fourth Annual Report to Congress including a number of self-accolades for numerous accomplishments in spite of a huge disconnect between DCAA’s audits and its statutorily required audits.  DCAA provides an overview wherein it reports that its “cost-effective” approach examined $182.6 billion, issued 5,688 audit reports, identified $4.5 billion in savings with a 6.9 to 1 return on investment (ROI).   DCAA now represents that its ROI is based upon a “conservative approach” because the savings only include realized savings and not future potential savings if DCAA recommendations are implemented.   However, DCAA fails to mention that future potential savings will be reported when realized; hence, if in any given year DCAA did report future savings as well as realized savings, DCAA would be duplicating reported net savings (coincidentally an issue reported in a 2014 DOD-IG report because two different DCAA audit offices reporting the same net savings for the same audit exceptions).