Redstone Government Consulting Blog | DCAA Audit Support (16)

Although the COVID-19 Pandemic and its impact on everyone is absolutely serious business, the nature of this “special day” blog is not necessarily serious business.   At times like these we hope that an element of levity will be accepted for what it is and not be misinterpreted as diminishing the serious nature of the pandemic. We also hope that everyone reading this is safe, healthy and adhering to the federal guidelines to limit the spread of COVID-19.

UPDATED – June 18, 2024

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.”

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.” 

Believe it or not, getting DCAA to show up and complete a “Paid Voucher Review” is “Good News.”

To understand where I’m coming from with this statement, let’s start with a little history.  The way DCAA dug itself out of its incurred cost backlog hole was with low risk sampling, provided for under FAR Class Deviation (2012-O0013) – DCAA Policy and Procedure for Sampling Low-Risk Incurred Cost Proposals, issued July 24, 2012.

After over three years of waiting, on September 24^th, 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 1^st, 2020, providing the first overtime salary adjustment in more than 10 years.

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.

DCAA’s July 19^th AGM or Audit Guidance Memorandum (19-PAS-003(R)) implemented the Section 803 requirement of the 2018 NDAA (National Defense Authorization Act) that DoD/DCAA adopts commercially accepted standards of materiality (in application) to incurred cost audits.  This requirement is in the broader context of continuing Congressional interest in the incurred cost backlog and performance of incurred cost audits.   More specifically, the subsection which requires commercially accepted standards of materiality is designed to improve the efficiency of the contract auditing process.

As a follow-up to our recent blog post, My CPA Audited My Financial Statements. Does That Mean My Accounting System is Adequate?  where we covered some differences between a financial statement audit and an adequate accounting system, we received several great questions from our readers.  We thought it might be beneficial to address them via a new blog post for the benefit of all our readers.  We welcome discussion on our blogs, though we do so in private via email.  In this case, though, these questions are ones we see frequently and impact all companies doing business with the U.S. Government.

The topic of accounting system adequacy seems to be a recurring issue for many in the government contracting community.  Earlier this month in the ongoing “process of elimination”, GAO weighed in again on what is NOT considered a determination of accounting system adequacy.  In Shivoy B-413104.36, GAO rightfully denied a protest for unequal treatment in eliminating a proposed offeror due to lack of verification of a proposed subcontractor’s accounting system as adequate.