Redstone Government Consulting Blog | Compliant Accounting Infrastructure (22)

The Bipartisan Budget Act of 2013 (BBA) has changed the game for executive compensation limitations yet again. Before 2012, US Government contracts subject to the FAR Part 31 Cost Principles were subject to the applicable fiscal year (FY) Compensation Cap established by the OMB (Office of Management and Budget) on the five most highly compensated employees in management positions. This changed again for contracts awarded from January 1, 2012 through June 23, 2014 to apply to all contractor employees performing DoD, NASA, and Coast Guard contracts, but apply only to the top five executives for remaining agencies. Every year the Office of Management and Budget publishes a memorandum to the Heads of Executive Departments and Agencies announcing the “benchmark compensation amount” for certain executives and contractor employees. During contractor’s fiscal years 2013 and 2014 the executive compensation dollar limitation was $980,796 and $1,144,888, respectively. Now, the BBA limits how much a contractor could charge the federal government for an employee’s compensation to $487,000 to all contractor employees for new contracts subject to FAR 31.2 awarded on or after June 24, 2014. This provision limitation change within a fiscal year has caused a contractor to be subject to multiple employee compensation caps (FAR 31.205-6(p)) within the same fiscal year.

Over the course of 2015, one of our accounting services consultants, Katie Donnell, made four week long trips to Unanet Headquarters in Dulles, VA for training classes to implement and operate Unanet software.

Updated October 26, 2016

In our blog “Blended Compensation Rate Guidance: Steps to Success”, posted on March 4, 2016, we provided the steps a contractor should take to determine if and how the compensation cap applies.  The reference is FAR 31.205-6(p) which establishes a statutory cap on allowable compensation, notably the methodology for determining the cap was changed as was the cap (reduced to $487,000) effective on contracts executed on or after June 24, 2014.  The reference to blended rates pertains to a contractor incurring costs in 2014 on contracts executed before June 24, 2014, as well as on contracts executed on or after June 24, 2014.   The “old” contracts subject to the previous (more contractor-friendly) regulation with a 2014 cap of $1,144,888 and the “new” contracts subject to the artificially low (and highly political) cap of $487,000.

DCMA and DCAA have issued guidance on how to deal with the impact of the $487,000 rate cap that applies to contracts subject to FAR 31.2 and awarded on or after June 24, 2014. If you have not read this document, see DCAA’s MRD 16-PSP-005(R), dated February 19, 2016. It includes the DCMA guidance also. You have flexibly priced contracts that require an annual incurred cost submission. Now what, exactly, are you supposed to do with this guidance?

As a small (or potential) government contractor or subcontractor, one question you will frequently encounter is if you have a “Job Cost Accounting System.” This may sound like a specific type of software, but it is not. Many different accounting software systems can provide job cost accounting if properly configured. The questions on the SF 1408, Pre-award Survey of Prospective Contractor Accounting System, are designed to discover if you have a job cost accounting system. This still doesn’t tell the non-accounting person what a job cost accounting system is or why it is important (other than to get the right answers on the SF 1408 to qualify for a government cost-reimbursable contract).

Outsourcing certain administration functions within an organization has become a trending practice among government contractors. In fact, we have seen a noticeable uptick in outsourced accounting, human resources and contracts administration functions over the past year.

Whether a company chooses to outsource a certain administrative function to fill a temporary void or a permanent one, looking to subcontractors for help makes sense for a number of reasons.

For government contractors your indirect rate structure is critical to your competitiveness, perhaps more so than any other element of the proposal.  In today’s LPTA environment, most offerors are going to be very similar when it comes to technical capabilities and past performance, so almost always award decisions come down to cost.  For the select few companies that have a technical edge or a differentiator in the way of performance that outweighs the cost to your government customer you can stop reading now.  The vast majority of companies working with the federal government don’t have this luxury, so what are they doing to set themselves apart when it comes to developing their indirect rates and overall wrap rates (wrap rates are a function of total direct and indirect costs for a labor hour divided by the direct labor hourly rate); hence, a lower wrap rate is perceived to be a more competitive overall cost structure)?

Our partnership with Unanet has benefited a lot of our clients in a multitude of different ways. Not only are our consultants trained and certified to implement the software for our clients, we can also provide a variety of other types of Unanet software support to add value to the software system, accounting environment, and project management. Below are a few examples.

In today’s budgets constrained environment U.S. Government contracting officers are seeking every opportunity to obtain discounted or reduced prices for services and materials, and as a tax payer that should make us all happy. However, for those of us who work in the government contracting industry the sight of LPTA solicitations, and enhanced scrutiny of proposals does make work life more challenging. One of the areas that we see challenged by contracting officers either during the proposal process or after award is the application of G&A on direct travel associated with the contract. This might be a solicitation provision, a Government expectation for contractor concessions during negotiations or a Government interpretation after contract award.