Small Business Outreach. April 28, 2009

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1 Sma Business Outreach Apri 28, 2009

2 Presentation Overview Where to Get More Information DCAA Background and History Accounting System Requirements Forward Pricing Proposas Incurred Cost 2

3 Where to Get More Information 3

4 Audit Guidance Open Audit Memorandums and Audit Guidance Standard Audit Programs DCAA Pubications Information for Contractors (Pamphet No ) Incurred Cost Eectronic Mode DCAA Contract Audit Manua (CAM) Links to Other Web Sites - DCMA, DFAS etc. 4

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8 DCAA Background 8

9 DCAA Background & History Estabished in 1965 Separate Agency of the Department of Defense Reports to the DoD Controer Genera Provides services to a DoD Components Provides a necessary contract audits for DoD Provides accounting and advisory services for DoD and other non-dod Agencies 9

10 COMMON AUDITS EXPERIENCED BY CONTRACTORS Accounting/Biing System Financia Capabiity Labor Charging System Forward Pricing Proposas Caims or Terminations Incurred Costs 10

11 Pricing Poicy FAR Pricing Poicy states: Contracting Officers must -- (a) Purchase suppies and services from responsibe sources at fair and reasonabe prices... Responsibe Sources FAR 9.1 Fair and Reasonabe Prices FAR

12 Responsibe Contractors FAR Responsibe Contractors states: Purchases sha be made from, and contracts sha be awarded to, responsibe prospective contractors ony. 12

13 Genera Standards FAR Prospective Contractor must have: a) Adequate financia resources e) Necessary organization, experience, accounting and operationa contros, and technica skis 13

14 Obtaining Information FAR Obtaining Information the contracting officer sha obtain from the auditor any information required concerning prospective contractors' financia competence and credit needs, the adequacy of their accounting systems, and these systems' suitabiity for use in administering the proposed type of contract. 14

15 The Accounting System 15

16 ACCOUNTING SYSTEM The auditor must determine if the accounting system provides costs that: è è è è Conform with GAAP Produces equitabe resuts that can be verified Are appicabe to the contempated contract(s) Are consistenty appied 16

17 ACCOUNTING SYSTEM AUDITS SB contractors must have deveoped a system that is operabe, though not necessariy in use.... be abe to demonstrate this new system to the auditor and be ready to impement the system prior to incurring any costs on the Government contract... 17

18 ACCOUNTING SYSTEM Guidance USE STANDARD FORM (SF) 1408: 18

19 Types Of Contract Costs DIRECT COSTS those costs that can be identified specificay to a contract INDIRECT COSTS those costs that cannot be directy identified to a singe contract but identified with two or more contracts aocated 19

20 SF 1408 Segregation of direct from indirect costs Identification & accumuation of direct costs by contract Indirect Costs-ogica/consistent aocation method Accumuation of costs under GL contro Timekeeping system identifying empoyee s abor by cost objective 20

21 SF 1408 A abor distribution system charging direct & indirect abor to the appropriate cost objectives Interim (at east monthy) determination of contract costs Excusion of unaowabe costs (FAR Part 31 or other contract provisions) Identification of costs by contract ine item and units (if required) Segregation of preproduction costs from production costs 21

22 Indirect Cost Aocation Exampe Account Description Account # Amount O/H Saaries 101 $ 22,000 FICA 201 $ 8,109 FUTA 202 $ 241 SUTA 203 $ 903 Workers Comp 301 $ 1,500 Gen Liabiity Insurance 302 $ 3,000 Indirect Trave 400 $ 500 Office Suppies 500 $ 250 Furniture (Depreciation) 600 $ 450 Tota (Poo) $ 36,953 Direct Labor (Base) 100 $ 84,000 Overhead Rate 44% 22

23 Labor Charging Recording Time Daiy Recording Time on the Timecard (In Ink) Project Numbers, Contract Numbers, etc Changes to the Timecard 23

24 Timekeeping Poicies... Supervisors shoud approve and cosign a timecards. The supervisor is prohibited from competing an empoyee s timecard. Nature of work determines the time charge; time charging is not based on avaiabe funding, contract type, etc. 24

25 Accounting System Audits Contracting Officer may request audit... Contractor submits a proposa for a cost-type contract Contractor is awarded a cost-type contract Contractor submits proposa under firm fixed price contract with progress payments 25

26 Accounting System Audits If accounting system is unacceptabe, DCAA wi notify contractor and procurement officia of system deficiencies. DCAA wi not deveop an acceptabe accounting system for contractor. 26

27 Proposas 27

28 Proposas - Guidance FAR , Tabe 15-2, provides instructions Chapter 3 of DCAA s Information for Contractors (DCAAP ) Provide Data in Eectronic Format Adequate Proposa = Expedited Audit 28

29 Proposa Basic Requirements Cost Eement Breakdown Proposa - Indexed and Referenced Identification of Incurred Costs Narrative for Basis of Estimate Direct Materias - Consoidated BOM & Basis of Estimate (BOE) 29

30 Proposa Basic Requirements Direct Labor Basis of Estimate of Labor Hrs Basis for Labor Rates Escaation Factors (If Proposed) Indirect Costs Cear Expanation of Rate Deveopment List of Expenses Comprising the Poo Is the Seection of Base Equitabe? 30

31 What To Expect from the Auditor Proposa Reviewed for Adequacy Entrance Conference Auditor Wi Review Proposa Using Appicabe Auditing Standards Exit Conference Audit Report Issued to the Contracting Officer Contractor May Request Copy of Audit Report from the Contracting Officer 31

32 Incurred Cost 32

33 Fexiby Priced (Sub)Contracts CPFF FPI CPIF CPAF Cost Reimbursabe Cost Sharing Fixed Price Re- Determinabe T&M (Bied Amounts) Labor-Hour (Bied Amounts) 33

34 Incurred Cost Audits Express an opinion whether costs are: è è è è è Reasonabe Aocabe Aowabe In accordance with GAAP & CAS, if appicabe Not prohibited by the contract, statute, reguation, or previous agreement with the contracting officer 34

35 Aowabe Cost & Payment Cause (FAR ) Requires the contractor to submit an incurred cost proposa with 6 months of its fisca year-end Requires a signed Certificate of Indirect Costs 35

36 Incurred Cost Submissions Adequacy Review DCAAP No Incudes proposed rates and supporting incurred cost data Separate schedue for EACH poo/rate Contractor may use its interna reports Encouraged to submit eectronicay 36

37 Questions? 37

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