The Perils of Cost Accounting Practice Changes

Previously, we discussed how a company ends up with CAS covered contracts.  This month we are going to talk about some of the further fun with CAS.  We recommended preparing a CAS Disclosure Statement soon after emerging from small business status,

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Topics: Compliant Accounting Infrastructure, Cost Accounting Standards (CAS)

The Path to Cost Accounting Standards (CAS)

The most common CAS (Cost Accounting Standards) exemption for most businesses is the small business exemption.  Most contractors understand that as long as they’re small, CAS is a non-issue.  What happens when you’re approaching your NAICS cap and headed toward the dreaded “other than small” status?

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Topics: Compliant Accounting Infrastructure, Small Business Compliance, Cost Accounting Standards (CAS)

What is the Focus of a Billing System Audit Coverage?

Back in the days of DCAA ICAPS audits, the billing system was a standalone audit program.  Even DCAA’s first pass at auditing for compliance with DFARS 252.242-7006 provided a standalone sub-assignment for the coverage of contractor billing systems.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Government Regulations

1099’s in Unanet: Year-End Process Made Simple!

Each year’s end brings a set of additional financial close tasks to our desks. The deadline to file 1099’s is January 31st, leaving a lot of companies scrambling to file these forms in time. Let me tell you how Unanet has automated the process for our clients using their software:

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Topics: Compliant Accounting Infrastructure, Unanet

Limitation of Cost or Funds – The Burden Falls on You

UPDATED – June 18, 2024

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Federal Acquisition Regulation (FAR)

Control Environment – The Expectations are Huge


As we outlined in Applicability of DFARS Business System Rules to Small Businesses, small businesses are exempt from Cost Accounting Standards and therefore are not subject to the business system rules, based on the requirements for inclusion in the Business System Clauses as set out in DFARS.  DFARS Case 2009-D038 – Defense Federal Acquisition Regulation Supplement; Business Systems-Definition and Administration, final rule issue February 24, 2013 in the Federal Register specifically stated: “DoD does not expect this rule to have a significant economic impact on a substantial number of small entities within the meaning of the Regulatory Flexibility Act, 5 U.S.C. 601, et seq., because contracts and subcontracts with small businesses are exempt from Cost Accounting Standards (CAS) requirements.”

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

Direct Costs in Government Contracts – Then and Now

In 1948 the Armed Services Procurement Regulations (ASPR) was issued as a result of the Armed Services Procurement Act, remaining in place until 1978.  ASPR defined direct cost as “any cost that is specifically identified with a particular final cost objective, but not necessarily limited to items that are incorporated in the end product as material or labor.”  This is a fairly broad definition and clearly establishes that direct cost includes more than direct material and direct labor.  The APSR also discussed Other Direct Costs (ODC), which were costs that were not material nor labor and provided examples, such as “travel and subsistence, consultants, telephone, computer costs and report reproduction.” 

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support

DOL Announces New Overtime Rule

After over three years of waiting, on September 24th, 2019 the Department of Labor released its long-awaited final overtime rule,  increasing the standard salary threshold for exempt status to $684 per week (up from the current $455 per week floor), or $35,568 per year on an annual basis. The new rule takes effect on January 1st, 2020, providing the first overtime salary adjustment in more than 10 years.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Human Resources, Government Regulations, Service Contract Act

New GSA FY 2020 Per Diem Reimbursement Rates

GSA establishes the per diem rates for the lower 48 Continental United States (CONUS), which are the maximum allowances that federal employees are reimbursed for expenses incurred while on official travel.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Government Regulations

The Power of Pay Codes in Unanet

Have you ever considered the power of the Pay Code function in Unanet? Pay Codes are the earnings and leave categories your organization uses to track and classify reported hours on employees’/subcontractors’ timesheets.

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Topics: Compliant Accounting Infrastructure, Unanet