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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December 29, 2010

DCAA Increases Threshold For Price Proposal Audits

DCAA by its Memorandum dated October 18, 2010 increased the threshold for conducting audits on price proposals to $10 Million for fixed price proposals and $100 Million for cost type proposals.  The only exception is under exceptional circumstances outlined in the contracting officer audit request letter. 

I agree with this development as it reduces potential audits on small insignificant proposals.  This may prove beneficial to small businesses.  However, small businesses must still develop its proposals in a manner that is compliant with cost or pricing data requirements.   The upside is there should be less audit activity on smaller proposals resulting a more streamlined approach to contract negotiations.

Wed, December 29, 2010 | link 

December 15, 2010

Deferred Compensation
I am often asked about deferring compensation especially in start up situations.  This cost can be allowable if it meets all the requirements of FAR 31.205-6 (k) which incorporates CAS 415, Deferred Compensation.  Keep in mind under cost reimbursable contracts and in situations where the Progress Payments clause is invoked billable direct costs must be paid in the normal course of business, usually within a business cycle.  For deferred compensation to be allowable the FAR and CAS criteria must be met.  There are special rules for unique circumstances and what if scenarios.  If your company uses deferred compensation suggest the program be reviewed in light of these requirements.  Also recommend that the awards be reduced to a written agreement.

A brief description of the main requirements is provided below.  It is not meant to be a complete discussion on the subject but to list the main requirements.  Please contact me for details if needed.

 

1) There is a requirement to make the future payment(s) which the contractor cannot unilaterally avoid.

(2) The deferred compensation award is to be satisfied by a future payment of money, other assets, or shares of stock of the contractor.

(3) The amount of the future payment can be measured with reasonable accuracy.

(4) The recipient of the award is known.

(5) If the terms of the award require that certain events must occur before an employee is entitled to receive the benefits, there is a reasonable probability that such events will occur.

(6) For stock options, there must be a reasonable probability that the options ultimately will be exercised.

Wed, December 15, 2010 | link 


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