Yes, they are! Did your company make it through its year-end and closing of last year’s books? If so, hooray! But is it really over for those that have Government cost-type contract billings? Not really. OK, as the Federal Acquisition Regulation (FAR) 42.704, Billing rates, allows interim payments through contract performance with the intent of making the contracting officer or contract auditor approved provisional billings rates as close as possible to the expected final indirect rates. This allows you to bill your costs throughout the year of your cost-type Government contract billings. Now that you know what the year-end indirect rates really are, there is one more thing to do: adjust the provisional indirect billing rates to actual rates in a Public Voucher (Standard Form 1034). Those year-end indirect rates should be net of any unallowable costs in FAR Part 31, Contract Cost Principles and Procedures. Sounds easy. It really should not be that difficult.
Topics: Business Systems Review, Compliant Accounting Infrastructure, Contracts Administration, Defense Contractors, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, Government Regulations, Federal Acquisition Regulation (FAR)
Have you considered populating the contracts module in Unanet with your data, but haven’t taken the time to do it yet? Let’s talk through the benefits of using the Contracts module.
At the end of each of the DCAA audit programs for contractor business systems, DCAA discusses what it refers to as “Less Severe Significant Deficiencies.” These are clearly deficiencies which do not meet the DFARS definition of a “Significant deficiency.” As a result, the withhold requirement provided for in DFARS 252.242-7005 cannot be applied.
Topics: Business Systems Review, Compliant Accounting Infrastructure, Contracts Administration, Defense Contractors, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
Deltek Costpoint Planning provides access to up-to-date, accurate information for developing, adjusting, auditing, approving, and re-forecasting project budgets and annual operating plans. We usually see three types of users in the Planning module: Business Development, Project Managers, and Project Control/Financial Analysts. Business Development users have access to develop new business budgets. Project Managers can create project budgets and run meaningful reports allowing them to make real time decisions and properly manage their programs. Project control/financial analysts can develop organization budgets and reconcile corporate and project budgets more accurately to better forecast their indirect rates.
On July 9th, 2021, the Department of Defense (DoD)issued a final rule in the Federal Register to implement 10 U.S.C. 2330a which requires the DoD to establish a data collection system to provide certain management information about an awarded contract or task order that is valued in excess of $3 million. This new rule is applicable for the following service acquisition portfolio groups:
- logistics management services
- equipment-related services
- knowledge-based services
- electronics and communications services
You may read the entire rule here.
Topics: Compliant Accounting Infrastructure, Small Business Compliance, Contracts Administration, Defense Contractors, Government Compliance Training, DFARS Business Systems, Cost-Type Contracts, DCAA Audit Support, Accounting & Billing System, System Award Management (SAM), Government Regulations
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.
Topics: Compliant Accounting Infrastructure, Incurred Cost Submission, Defense Contractors, Incurred Cost Proposals, DCAA Audit Support, Accounting & Billing System, Government Regulations, Federal Acquisition Regulation (FAR)
What is CUI, CDI and CTI?
CUI is Controlled Unclassified Information and encompasses all Covered Defense Information (CDI) and Controlled Technical Information (CTI). CUI requires the safeguarding or dissemination of controls pursuant to applicable laws, regulations, and government-wide policies.
- Covered Defense Information (CDI) is unclassified controlled technical information or other information described in the Controlled Unclassified Information (CUI) Registry found
- Controlled Technical Information (CTI) is technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination. It does not include information that is lawfully publicly available without restrictions.
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.
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, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
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.
Unanet’s robust project management and budgeting features are primary reasons some of our clients choose Unanet as their accounting system of choice. One of our main goals during an Unanet implementation is to utilize as many of the project management features in the system as possible and train our clients on maintaining the correct information to manage their work properly. What are your project management and budgeting needs? The following options are available in Unanet: