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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July 13, 2010

FAR 52.203-13, Implements Significant Compliance Requirements
New rule affecting a contractors compliance and internal control systems is codified by FAR 52.203-13.  Actually the clause has been around for a while.  It was established in 2008.  The rule has been heavily debated with back and forth but is now implemented.  In addition DCAA has started an initiative to audit against it.  The new rule is applicable to contracts exceeding $5 Million and 120 days of contract performance. Certain parts of the rule apply to small business.  The rule requires:

1. Contractors maintain written standards of conduct, be diligent in the prevention and detection of criminal conduct and maintain a culture of ethical conduct/compliance.  It also requires contractors to disclose in writing to the Office of the Inspector General incidents where there is credible evidence that a violation has occured of criminal law or the civil False Claims Act. 

2. Contractors must implement an ongoing employee awareness program regarding standards of conduct and reporting incidents, an internal controls system that is designed to detect incidents of noncompliance and corrective measures are implemented and carried out.  The rule goes on to describe minimum requirements including periodic audits, testing and monitoring.  This item only applies to large businesses, small businesses are exempt from the internal control system requirement.

This is an alert and is intended to notify contractors of the new rule and is a summary.  It is not an analysis of the new rule as it is a substantial rule with detailed requirements.  I encourage contractors to get a copy of FAR 52.203-13 and review the clause in its entirety.

This new rule imposes substantial compliance responsibility upon large and small businesses.  Small businesses are only subject to the standards of conduct policies, training and the reporting provisions of this new rule.  I encourage all contractors to review its compliance policies, procedures and monitoring in light of this rule. I encourage contractors to enhance its policies, procedures and internal control programs to comply with this complex but important rule.  In regards to the reporting to the Office of Inspector General I strongly encourage contractors to seek legal counsel regarding its rights in light of disclosure. Contractors should engage qualified professionals and possibly legal counsel as needed.
Tue, July 13, 2010 | link 


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