DCAA COMPLIANCE CONSULTINGSUMMARY BIOGRAPHYDCAA COMPLIANT ACCOUNTING SYSTEMSDCAA COMPLIANT TIMEKEEPING AND LABOR REPORTINGINDIRECT COSTS EXPLAINED/DCAA COMPLIANCEINDIRECT COSTS RATES/DCAA COMPLIANCEIS QUICKBOOKS DCAA COMPLIANT?UNALLOWABLE COSTS, FAR 31.2GOVERNMENT CONTRACT CONSULTING SERVICESRECENT PROJECT SUMMARIES

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NEED HELP WITH:
  • DCAA Audits
  • DCAA Compliance
  • FAR, CAS and Other Regulations
  • Government Contract Accounting Systems
  • Indirect Rates and Incurred Cost Submissions
  • Certified Systems or Indirect Rates
  • Government Contract Proposals
  • Equitable Adjustments or Claims
  • Or Just Want to Understand the Rules of the Game?

BECAUSE THIS IS WHAT I DO!

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I am a DCAA/Government contract consultant and CPA with 27 years top shelf experience specializing in DCAA, the Federal Acquisition Regulation (FAR) and the Cost Accounting Standards (CAS).  I have been serving government contractors since 1986.  The scope of my services includes all subjects involving the DCAA, the FAR and government contracting in general.  My expertise encompasses practically any industry including all forms of government contracts.  Most of my work involves DoD contracts but I have worked on contracts with practically every civilian government procurement agency.  I have also worked on projects involving numerous state and municipal agencies as well.  Most common projects I perform include the following subjects:

  • DCAA audits
  • Accounting system and  DCAA compliance
  • DCAA accounting system set up and implementation
  • Compliance and cost recovery assessments
  • Refuting and resolving government actions or inactions including DCAA
  • Indirect rates, forward pricing and incurred cost submissions
  • FAR assessments and interpretations
  • Government contract proposals/GSA schedule proposals
  • Compliant systems, procedures and processes
  • Cost Accounting Standards (CAS)
  • Equitable adjustments, terminations, claims, etc.

I have expertise in the most notable government contracting accounting systems, such as Deltek GCS and Costpoint.  For small businesses I have experience with Quick Books.  I have implemented QuickBooks in a manner that is DCAA compliant and have passed objective DCAA audits on numerous occassions. 

I particularly prefer working with small and medium sized businesses helping them win contracts, overcome DCAA requirements and challenges, maximize cost recovery and cash flow.

I work with large businesses as well offering an expert resource.

DCAA/Government Contracting Experience

My 27 years of government contracting experience includes working as a "decorated" senior auditor for DCAA.  It also includes a long tenure as a Manager for KPMG, a large public accounting and consulting firm (aka Peat Marwick) in its government contracting consulting practice. In this role I helped clients resolve DCAA and government contracting challenges.  I also worked for many years in management positions for government contractors as a CFO, Controller and Contracts Manager.  This experience provides me the expertise to provide comprehensive solutions to government contracting challenges taking into account the government's regulatory oversight role and the contractor's objectives.

It is impossible to describe these 27 years of accomplishments and experience in DCAA and government contracting in a few paragraphs.  So please view the links or contact me for more detail.

If you have a government contracting problem, I most likely have a best business practices solution.

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CONTACT

Edward D. Moore
dcaaConsulting LLC
Certified Public Accountant
Mobile: 336-880-9040
E: emoore@dcaaconsulting.com Alternate Email: dcaaconsulting@gmail.com
W: www.dcaaconsulting.com

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June 24, 2009

Allowable Rental Costs
Recently, DCAA was taking exception to rental costs of a small business contractor, claiming the cost was a related party transaction as an owner was the lessor or leasing the facility to the contractor.  Truth was the lessor was a minority (less than 50% owner).  DCAA claimed that since the owner of the building was also an owner of the the company it qualified as a related party transaction and that the FAR limited allowable costs to ownership costs, depreciation, insurance, taxes and insurance.  This was a large disallowance to the contractor.

Well, the truth is, that is not what the FAR says.  The FAR (FAR 31-205-36) states allowable costs are limited to ownership costs provided the there is "common control" between the contractor owner and the building owner.  The DCAA's own audit guidance states the same concept.  Well there was not any common ownership.  the primary or majority owner of the contractor did not have any ownership in the building and the owner of the building was a minority (less than 50% ownership) in the contractor.  So in this case the allowable costs were not limited to ownership costs.  The full value of rental costs, provided they were reasonable, was allowable.

We prevailed on the issue and the contract in question was re-negotiated to the contractor's satisfaction.

This situation is common in small businesses.  I advise against it for this very reason, DCAA questioning costs without getting all the facts and not applying the regulations or their own audit guidance properly.  Best not to open the door to the possibility of questioned costs.  But if you are in this situation, just keep in mind the limitation on allowable costs (the ownership cost rule) only applies where there is common control between organizations.
Wed, June 24, 2009 | link 


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