Cost Accounting Standard (CAS) 415 – Accounting for the Cost of Deferred Compensation

For cost accounting under Federal government contracts, including your contracts that are not CAS covered, deferred compensation must be measured based on the requirements of CAS 415. FAR 31.205-6(k) requires that the cost of all deferred compensation, other than pension costs, be measured, assigned, and allocated in accordance with CAS 415, Accounting for the Cost of Deferred Compensation.

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Topics: Compliant Accounting Infrastructure, Employee & Contractor Compensation, Human Resources, Government Regulations, Cost Accounting Standards (CAS)

Cost Accounting for The Federal Risk and Authorization Management Program (FedRAMP)

If you want to provide cloud-based services to Federal Agencies, you will need to get your service approved through the Federal Risk and Authorization Management Program (FedRAMP) managed by the FedRAMP Program Management Office.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Cost Accounting Standard (CAS) 420 – Accounting for IR&D Costs and Bid & Proposal B&P Costs

Cost Accounting Standard (CAS) 420 outlines accounting standards for Independent Research and Development (IR&D) and Bid & Proposal (B&P) costs incurred by government contractors, ensuring consistent and transparent reporting.

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Topics: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

Cost Accounting Standard (CAS) 408 - Accounting for Costs of Compensated Person Absence

Cost Accounting Standard (CAS) 408 was put in place to provide consistency in the measurement and allocation of vacation, sick leave, holiday, and other compensated personal absences. Today, many contractors refer to all paid time off as “PTO.”

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

Is Construction for the Federal Government Commercial?

How does the Government define construction? We need to consider some of the definitions in FAR part 2:

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Commercial Item Determination, Federal Construction Contracting

Cost Accounting Standard (CAS) 403 - Allocation of Home Office Expenses to Segments

So, you have a contract with the clause FAR 52.230-2 Cost Accounting Standards, subject to full CAS coverage. If you receive allocations from a home office, the home office must comply with CAS 403, Allocation of home office expenses to segments. A home office has the responsibility for directing or managing two or more segments of an organization and includes intermediate home offices or a corporate office.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

DCAA Finally Takes a Step in the Right Direction with Cost Impact Guidance

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.

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Topics: Contracts & Subcontracts Administration, Government Regulations, Cost Accounting Standards (CAS)

What are the Different Types of CAS Accounting Practice Changes?

Most contractors that have contracts/subcontracts subject to full CAS coverage will eventually want to make a change to a cost accounting practice because there is a “better” allocation method or a change is required to remain in compliance with CAS.

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

Grant Regulations are Going to be Updated Soon – Get Your Comments Ready

Suppose your company is working on a grant or cooperative agreement or planning to submit a proposal in response to a funding opportunity announcement. In that case, the regulations that apply will be Code of Federal Regulations (CFR) Title 2 Grants and Agreements. The problem is, when you receive a grant, generally, the award agreement says to comply with 2 CFR. There are no specific clauses or wording; basically, you are responsible for reading the entire regulation to see what applies to your award. 2 CFR includes inconsistent language and terms.

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Topics: Government Regulations, Cost Accounting Standards (CAS), Grants & Cooperative Agreements (2 CFR 200)

Interest is Unallowable – How is That Possible?

FAR 31.205-20 provides that interest is unallowable on Federal Government contracts, no matter how it is calculated or presented in your financial books and records. This means you cannot propose, bill, or claim your interest expense.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)