Redstone Government Consulting Blog | Contracts & Subcontracts Administration (5)

Contractors are required to keep their System of Award Management (SAM) registration up to date. FAR 52.204-7(b)(1) requires an offeror to be registered in the System of Award Management (SAM) when submitting an offer/quote, registered until the time of award, during performance, and through final payment. Sounds pretty easy. However, contractors are not always registering or updating their registration, resulting in ineligible awards, as noted in recent court cases (See our blog: SAM Registrations: Check Often and Never Let it Lapse!).

The Defense Contract Audit Agency (DCAA) issued a memorandum to its leadership – and ultimately its auditors in the field – addressing a revision to its audit guidance related to the audit of contractor cost impact calculations for unilateral cost accounting practice changes (23-PAC-009(R) Revised Audit Guidance on the Cost Impact Calculation for a Unilateral Cost Accounting Practice Change – dated October 3, 2023). Well, it is about time.

If this were only a simple question. The most straightforward answer is that it is a good idea for any company to have policies and procedures. If that company is going to do business with the US Government those policies and procedures are going to have to be expanded as each contract may present additional requirements. To help you understand the complex level of requirements we will address the major business systems and other key areas.

Well – besides being the first thing your friendly DCAA auditor will ask you for, they should be something your employees use and rely on daily. The last thing you want is one of your employees telling an auditor they have never seen or read the company’s policies and procedures. The joy that will come across the auditor’s face will be truly shocking – and – the sadness that will come across your face when the Business System Deficiency Reports start to arrive, requiring endless responses and corrective action plans, will be just as shocking. This fairytale has no happy ending, at least not for you and your company – just a drain on your resources and more audit oversight.

Basic Requirements

CAS 410 provides the criteria for allocating business unit general and administrative (G&A) expenses to final cost objectives based on their causal beneficial relationship. The standard requires that one of three cost input bases must be used unless there is a special allocation to a particular final cost objective. Contractors should select the cost input base which best represents the total activity of a typical cost accounting period for the production of goods and services for the business unit.

Basic Requirements

This standard vastly expands on the FAR requirements related to direct and indirect costs. FAR 31.202 and FAR 31.203 give a basic definition of each, but little else. CAS 418 provides guidance on accumulating indirect cost pools, including service centers and overhead costs. Furthermore, it requires the costs be allocated on the causal or beneficial relationship between the indirect cost pool and the related cost objective. In addition, CAS 418 requires each business unit to have written policies and practices for classifying costs as direct or indirect.

As the Government approaches yet another potential shutdown, we wanted to bring our reader’s attention to the information we have previously provided on this topic and some just-in-case planning suggestions. While unfortunate, the shutdown battles have become a perennial occurrence for most of the last two decades. We began writing on the topic prior to 2010, and our blog archives go back to 2012. The advice from these older blogs is just as relevant to contractors now as when initially published. Below are a few blogs we’ve published on the government shutdown topic:

Any company receiving a government contract for the first time will have lots of questions and changes to their operations as a result of that contract. The question is, will the accounting structure and approach to the company’s accounting practices have to change?

If you are awarded a fixed priced contract or a commercial FAR part 12 contract with the Federal Government with payment on delivery, you should not need to make any changes to your accounting practices based on US Generally Accepted Accounting Practices (GAAP). However, even a fixed priced contract or a commercial (FAR part 12) contract can become complex and require specific accounting be applied should the Government make changes to that contract after award, which they often do, during performance, or terminate the contract for the Government’s convenience.

As the fiscal year draws to a close, government contractors are gearing up to meet their year-end reporting requirements. Navigating the maze of regulations and clauses can be daunting, but with a clear understanding, the process becomes manageable. This article aims to shed light on the major contract reporting requirements for all government contracts.

We have discussed recently how DoD has an increased interest in government property, especially the property that contractor’s control and maintain. RGCI has helped clients with government property issues more in the past four years than the previous ten years combined.