DCAA Compliance, Audit and Government Contract Consulting

DCAA Compliance, Audit, FAR and Government Contract Consulting

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

October 6, 2011

Marketing Costs

I hear DCAA is going to re-focus on marketing costs for allowability. I understand they are going to start increasing its scrutiny on reviewing sales and marketing expense reports for allowability. This should make one emphasize the segregation of promotional marketing from Bid and Proposal efforts and direct selling efforts. The latter two are allowable in most cases. Contractors should review its expense reporting practices to make certain unallowable costs are properly segregated.

Thu, October 6, 2011 | link

September 7, 2011

Collecting On Incurred Costs Submissions

The whole idea under a cost reimbursable contract is to submit an Incurred Cost Submission at year end and firm up the billings to actual rates. However, DCAA has fallen far behind on its audits to finalize rates at year end. In some cases as much as three years. This situation is not addressed in the Allowable Cost and Payment clause. This is unfortunate for contractors. Unfortunately situation places contractors in a delay position on collecting any amounts due as a result of final indirect cost rates. It results in an under-recovery and the inability to collect until DCAA gets around to auditing the Incurred Cost Submission. Some suggestions to minimize this situation include:

1. Get submissions into DCAA as soon as you possibly can to get the ball rolling.
2. Go on offense pressure both DCAA and the Contracting Officer to make the audit a priority.
3. Get provisional rate proposals and agreements in place as soon as possible.
4. Remain conservative on forecasting the provisional rates knowing it may take years for DCAA to finalize the final rate. Do not understate these rates. Understating these rates is in essence an interest free loan that you are offering the government. This loan may take years to unravel.

To get caught up, I hear DCAA is hiring special audit travel teams to come in and get caught up in areas where DCAA is unreasonably behind. I have found this situation to be favorable to contractors. Get your submissions in so your rates can be audited and settled.

Most important is get the Incurred Cost Submissions into DCAA. Failing to do so puts the obligation on you. This further delays finalizing these rates and unltimately getting what your entitled to for indirect costs. Remember, you can only recover costs for indirect rates if there is funding available. The sooner you get the rates submitted, the more likely you can make certain there is adequate funding. If you have a funding issue, solicit additional funds sooner versus later. It is difficult to secure these funds late in a fiscal year or late in the contract's period of performance.

Wed, September 7, 2011 | link

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

October 1, 2010

Face Book

We are on Face Book, Check out dcaaConsulting for news and updates.

Fri, October 1, 2010 | link

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