DCAA Guidelines. How the SBIR firm can work effectively with the Defense Contract Audit Agency

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1 DCAA Guidelines How the SBIR firm can work effectively with the Defense Contract Audit Agency

2 Today s Presenters

3 OUTLINE Presenter Introduction DCAA & DCMA DCAA Overview Types of DCAA Audits What it takes to meet DCAA Requirements How to behave in a DCAA Audit

4 PRESENTING COMPANY ReliAscent LLC was formed by the merger of two of the nation s leading consulting firms for helping small federal contractors with DCAA and other Federal regulatory compliance issues, mainly related to accounting and contract administration. ReliAscent expands on that base by not only providing consulting in those areas but by offering complete outsourced back office services to allow small businesses to completely focus on their core competencies and allow them to maximize their growth. Services include, but are not limited to: Outsourced full function accounting (including CFO services) Outsourced contract administration Outsourced payroll functions Other back office services Business consulting services

5 DCAA vs. DCMA DCMA Contract Mgmt. Before Award Help construct solicitations Help select most capable suppliers Write contracts After Award Monitor cost Monitor delivery Monitor quality Contract Closeouts DCAA All necessary DoD contract audits Accounting Advisory Services for DoD contracts Financial Advisory Services for DoD contracts Provide contract audit services for other agencies as required

6 DCAA / DCMA Relationship

7 REGULATIONS FAR Federal Acquisition Regulations 53 Major Parts covering all aspects of Federal Procurement 2,017 pages of small font print 48 CFR 1 DFARS CFR Defense Federal Acquisition Regulation Supplement 53 Parts & 9 Appendices Code of Federal Regulations

8 DCAA OVERVIEW Types of Audits Pre-Award Price Proposals Pre-Award Surveys Forward Pricing Labor & Overhead Rates Post-Award Incurred Cost Truth in Negotiation Act Compliance CAS Claims Labor Floor Checks Contractor Business Systems Accounting Estimating EDP Billing Material Management

9 Types of Contracts Fixed Price Contracts Cost Reimbursable Contracts Time and Material Contracts 10 8 Cost Reimbursable type contract Buyer s Risk 6 4 T & M type contract 2 0 Seller s Risk Fixed Price type contract

10 SBIR / STTR Phase I Price Proposal Audit Phase II Price Proposal Audit Pre-Award Survey Accounting System Audit Incurred Cost Audit Phase 2.5 Same

11 Price Proposal Audit Allowability, Reasonableness, Allocability Indirect Rates Basis Basis of Proposed Rates Direct Labor Hours Basis Cost Estimates Basis Direct Material Basis ODC Basis Indirect Rates Cost of Money (if applicable)

12 Pre-Award Survey SF 1408 Allowability, Reasonableness, Allocability G/L Control Pooled Costs Labor Distribution Direct Costs assigned to final cost objective Labor Collection Method of Indirect Rate Calculation Job Cost Reports Management of Indirect Rates

13 Incurred Cost Audit Determining Risk Less than $500K Auditable Dollar Volume Considered Non-Major Generally Low Risk Audit Dollar Volume $500K to $15M Considered Non-Major Generally Low Risk unless >$10K questioned costs Audit Dollar Volume $15M to $90M Considered Non-Major but High Risk Audit Dollar Volume >$90M Considered Major & High Risk

14 Incurred Cost Audit Nonmajor Desk Review Allowability, Reasonableness, Allocability Establish final Indirect Cost Rates Scan for Unusual Items Verify Mathematical Accuracy Scan for Significant Costs

15 Incurred Cost Audit Allowability, Reasonableness, Allocability Indirect Rate Computations accuracy Review Executive Compensation Basis of Proposal Review Permanent Files Review Pension & Retirement Plans (if appl) Excessive Pass Through Costs (Subcontracts > 70%) Tax Returns & Financial Statements Changes in Direct/Indirect Cost Charging

16 Accounting System Audit - Nonmajor Contractors Adequacy & Suitability of Accounting System GAAP & Internal Controls Segregation of Costs & Direct Cost to Contract Accumulation of Cost under General Ledger sufficient detail for use in follow-on pricing Interim Determination of Costs Direct Labor Direct Material, ODC, Subcontracts Indirect Costs Exclusion of Unallowable Cost Adequate Billing System

17 Labor Floor Check Usually unannounced must be done during first field visit to contractor in the year Controls (timeclock, timecards, etc.) Procedure to notify employee job number and recording procedures How are hours on timecard reconciled with payroll records Division of responsibility (time / payroll) Observe & Verify time recorded properly Interview Supervisors & Employees Verify follow procedures (daily)

18 Audit Preparation Review Records for Compliance Review Records for Mathematical Accuracy Review Contract and FAR part 31 for Unallowables Verify they are removed Provide Auditors Access to Personnel & Records Make Contracts Available for Auditor

19 Audit Etiquette Be Courteous - Listen Don t be Defensive Make sure you understand what is being asked before responding get clarification. Only provide an answer to the question. Do not supply additional information unless asked. Resist the temptation to fill an awkward silence by offering additional information. The Auditor will note the contractor s reaction at the exit conference and include in the report

20 QUESTIONS? Questions today Questions later, Please feel free to contact us: Mike Anderson (cell) Dave Donley (cell)

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