DCAA Publishes the 2025 Compensation Cap

Again, this year our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2025 compensation cap amount is $671,000. Below we have provided the compensation caps going back to 2019.

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Topics: Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Timekeeping and Compliance in Unanet for Government Contractors

Unanet provides a comprehensive suite of features tailored to help government contractors efficiently manage people and projects. These features are designed not only to enhance cost control and profitability but also to improve overall performance while ensuring compliance with complex government regulations. At Redstone GCI, we’ve seen firsthand how proper implementation of Unanet can streamline operations, significantly reducing processing costs compared to outdated or manual systems. With its robust capabilities, Unanet is built to meet the stringent requirements of federal government timekeeping and expense reimbursement, making it a valuable tool for contractors aiming to maintain compliance and improve operational efficiency. Our team specializes in helping government contractors unlock the full potential of Unanet, ensuring it is implemented and utilized effectively to deliver maximum value.

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Topics: Compliant Accounting Infrastructure, DCAA Audit Support, Unanet

FASB Proposed Change Impacting Cost Accounting for Software

Normally, I make numerous references to the Federal Acquisition Regulations (FAR) when writing. However, there is only one FAR reference for this topic, and then we must turn to the Accounting Standards Codification (ASC). In this case, that single FAR reference is FAR 31.201-2(a)(3).

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

Cost Accounting Standard (CAS) 411 – Accounting for Acquisition of Material Cost

CAS 411 provides criteria for accounting for the measurement and assignment of material costs to cost objectives and follows generally accepted accounting principles (GAAP).

What is the Purpose of CAS 411?

If you don’t have contracts subject to full CAS, then FAR 31.205-26 Material costs requires contractors to implement GAAP when accounting for material. Material costs can either be charged direct to a contract or assigned to contracts through inventory accounts. Material that is charged direct should be identified on the purchase order and material assigned through an inventory account should be consistently applied by category of material. While CAS 411 requires written policies for accounting for material, it is a best practice to establish written policies whether CAS 411 is applicable or not.

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management and Accounting System (MMAS)

New DCAA Director Appointment Brings Potential Opportunities

The Department of Defense (DoD) Comptroller announced the new Defense Contract Audit Agency (DCAA) Director on October 21, 2024, as Ms. Jennifer Desautel. Ms. Desautel was previously the Assistant Director, Policy and Quality was responsible for the formation, development and issuance of contract audit policy and quality assurance within DCAA and its over 4,000 employees in nearly 300 locations. The DoD Comptroller in his announcement sited her extensive experience with DCAA operations and mission as well as her strong alliances across DoD and industry made her ideally suited to lead DCAA.

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Topics: Contracts & Subcontracts Administration, Government Compliance Training, DCAA Audit Support, Government Regulations

Don’t Forget the Government Property During Contract Closure

So, the title is maybe a little misleading, and don’t worry – DCMA won’t let you forget the Government property during contract closure. Government property closeouts are only a singular piece to the contract closeout process. And like with all things Government property, the closeout process takes teamwork from both the contractor side and the Government side to be successful.

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Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Government Property Management, Federal Acquisition Regulation (FAR)

Small Business Reality vs. DCAA Accounting System Expectations

Every small business that receives a Federal Government cost reimbursable contract is expected, by the Defense Contract Audit Agency (DCAA), to have a “sound internal control environment, accounting framework, and organizational structure.”

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

Cost Accounting Standards (CAS 414 and 417) for Cost of Money as an Element of Cost

FAR 31.205-20 makes interest unallowable, however, cost of money is not interest based on the CAS Board and is allowable (see our article Interest is Unallowable – How is That Possible). Cost of money is an imputed cost that is provided to contractors to recover the time value of money invested in facilities and equipment that benefit government contracts. Contractors that do not have contracts subject to full CAS, follow FAR 31.205-10 Cost of money which incorporates CAS 414 (Cost of Money as an Element of the Cost of Facilities Capital) and CAS 417 (Cost of Money as an Element of the Cost of Capital Assets Under Construction) and allows cost of money as a cost as long as it is measured, assigned and allocated in accordance with the standard. Cost of money must be specifically identified and proposed in cost proposals to be claimed or billed. Let’s discuss the requirements of CAS 414 and 417.

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

CBCA and Court of Appeals Found that Taxes Paid by Parent were NOT Cost Incurred by Subsidiary

The Court of Appeals decision came out on June 26, 2024, and I have been trying work it through my head how they got to their decision. I for sure do not have an answer but I have come up with some ideas and concerns. International Development Solutions, LLC v. Secretary of State, U.S. Court of Appeals, Federal Circuit, 68 CCF ¶82,658, (Jun. 26, 2024)

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Topics: Compliant Accounting Infrastructure, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)

DCAA Wants to Re-Connect with Government Contractors

The Defense Contract Audit Agency (DCAA) wants to re-connect with you. About four years ago, DCAA was looking around and evaluating its workload and saw a problem: it was going away. With a previously perennial favorite of the incurred cost backlog finally going away and few incurred cost audits due to sampling, DCAA had to look for how it can still be important to the acquisition community.

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Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, DCAA Audit Support