WHAT MAKES AN ACCOUNTING SYSTEM COMPLIANT

Similar documents
DCAA Current Trends and Practices. SCS GovCon Seminar October 24, 2013

Submitting a Quality Report. Presented by Laura Davis, Strategic Consulting Solutions, Inc.

DEFENSE CONTRACT AUDIT AGENCY

Preaward and Post Award Accounting System Audits. November 17, 2011 Pikes Peak NCMA Roland Wick

Presented by: Laura Davis, President Strategic Consulting Solutions, Inc. PDS Consulting Solutions, LLC November 12, 2015

Government Contract Accounting Are You DCAA Compliant? Procurement Technical Assistance Program (PTAP)

Post Award Accounting System Audit at Nonmajor Contractors

Accounting System Requirements

Labor Costs Interpretive Guidance Labor Costs: Timekeeping, Direct Labor Base, Labor Transfers & Direct to Indirect Labor Ratio

FAR UPDATE , Allowable Cost and Payment (Jun 2013)

Pre-Award Accounting Systems

Accounting System Requirements

What Exactly is an Acceptable Accounting System?

DEFENSE CONTRACT AUDIT AGENCY GUIDE FOR DETERMINING ADEQUACY OF CONTRACTOR INCURRED COST PROPOSAL

Cracking the ICE: Ensuring a Compliant Incurred Cost Submission. Carlos Alvarado, VP, FP&A

How to Survive a DCAA Audit

WELCOME. Accounting Systems for DOD Contracts

Preaward Survey of Prospective Contractor Accounting System

Master Document Audit Program. Version 1.5, dated September 2015 B-01 Planning Considerations

GOVERNMENT ACCOUNTING REQUIREMENTS

Presenting the Numbers: Accounting Systems for Government Contractors

DCAA Compliant Accounting Systems

Accounting Systems: Complying with FAR Requirements. John S. Sroka, CPA Acquisition Cost/Price Analyst

INTERNAL CONTROL MATRIX FOR AUDIT OF BILLING SYSTEM CONTROLS Version No. 4.2 August 2006

Implementing a FAR Part 31 Compliant Cost Accounting System

Basic Financial Requirements for Government Contracting

The Essential Role of Adequate Accounting Systems for Government Contractors

Post Award Accounting System Audit at Nonmajor Contractors

Government Contractor Business Systems and Overview of System Assessments

DEFENSE CONTRACT AUDIT AGENCY CHECKLIST FOR DETERMINING ADEQUACY OF CONTRACTOR INCURRED COST PROPOSAL

Slide 1. Slide 2. Slide 3 Standard Form 1408 ACCOUNTING SYSTEM ESSENTIALS

Chapter 6 Labor-Charging Systems and Other Considerations

THE DCAA AUDIT BECOMING DCAA COMPLIANT

How to Establish an SBIR Accounting System that Can Withstand a Government Audit

Time s Up: DCAA s Renewed Focus on Incurred Cost Submissions

Government Accounting, Estimating, and Billing Systems: Pitfalls and Answers

REAL-TIME LABOR EVALUATIONS. The views expressed in this presentation are DCAA's views and not necessarily the views of other DoD organizations

AGENDA FOR LUNCH SEMINAR WITH FMI AUGUST 28, :30 PM INTRODUCTION TO GOVERNMENT CONTRACTING

WORKING WITH THE U.S. GOVERNMENT YOUR GUIDE TO THE DCAA

Federal Regulatory Compliance Best Practices Washington Technology Webcast. September 27, 2012

Preaward Survey of Prospective Contractor Accounting System Checklist

What Documents are required at Pre-award Audit of an agreement or sub-agreement. How to Avoid Common Proposal Mistakes

Is Your Accounting System Making the Grade? Attributes of an Acceptable Accounting System April 26, 2012

How to Establish an SBIR Accounting System that Can Withstand a Government Audit

CHAPTER Preaward Surveys of Prospective Contractor Accounting Systems

ACCOUNTING & AUDIT GUIDELINES FOR CONTRACTS WITH CALTRANS

Certificate of Accounting, Billing and Property System Adequacy

DEPARTMENT OF TRANSPORTATION AUDITS & INVESTIGATIONS. Overview of A&E Related Audit Issues

Managing Cost Type Contracts

How To Audit A Government Contractor

Presented by Albert D. Goldwasser, CPA Government Contractor Consultant

Thank You for Joining Us, The Webinar Will Begin Shortly. While you are waiting please check out the Upcoming Webinars on

Defense Contract Audit Agency NAVAIR Small Business Aviation Technology Conference

Financial Management Guide for Government Contractors

You've successfully subscribed to this feed! Updated content can be viewed in Internet Explorer and other programs that use the Common Feed List.

Surviving a DCAA. Audit. Nicole Mitchell, CPA Director Aronson LLC. March 29, 2011

Uncompensated Overtime

4 Essentials to Becoming a Successful Government Contractor

INSPECTOR GENERAL UNITED STATES POSTAL SERVICE

Guidance for Small Firms (And/or New to WSDOT)

A&E CONSULTANT CONTRACT REVIEWS AND INDIRECT COST RATE AUDITS AND REVIEWS

Objectives of the Incurred Cost Audit

Incurred Cost Submissions. John S. Sroka, CPA Acquisition Cost/Price Analyst

Staff Timesheets: Requirements and Issues

Direct and Indirect Labor. The Scenario

January (1) CHAPTER 6. Table of Contents

SIGAR. USAID s Health Care Improvement Project: Audit of Costs Incurred by the University Research Company, LLC APRIL

Enprise Job Costing and DCAA Compliance

Incurred Cost Submissions

back

DCAA and the Small Business Innovative Research (SBIR) Program

How to Develop an Indirect Rate for Your SBIR Proposal

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

ACCOUNTING AND AUDITING GUIDELINES. Table of Contents 11.1 MDT POLICIES AND PROCEDURES

INTERNAL CONTROL MATRIX FOR AUDIT OF LABOR AND ACCOUNTING CONTROLS Version No. 4.2 June 2006

Frequently Asked Questions (FAQ s)

Incurred Cost Submissions - It's Not Too Early!

How to Survive a DCAA Pre-Award Audit

Are you in Compliance with the Financial Rules for 8(a) Companies?

4 Essentials to Becoming a Successful Government Contractor

How-To-Tutorial for MoDOT s Consultant Prequalification Process. How-To-Tutorial for MoDOT s Consultant Annual Financial Prequalification Process

COST PLUS AWARD FEE CONTRACT ADMINISTRATION DESKGUIDE

Indirect Rates for Government Contractors

Timekeeping Case Study #1 [OIG Audit Report No ]

DCAA Perspective: Key Subcontracting Practices for Maintaining Approved Business Systems Accounting System and Estimating System

The need for reliable, accessible and traceable data that reconciles internal billing information with

Cost Allocation Cost Pooling & Time Distribution

Microsoft Dynamics NAV for Government Contractors

Strategic Implications of the New DFARS Business System Rule Co-presented by Venable LLP and Argy, Wiltse & Robinson June 12, 2012

[INTERMEDIATE QUICKBOOKS FOR NONPROFITS] Presented by Ian Shuman, CPA Gelman, Rosenberg & Freedman CPAs October 4, 2011

GOVERNMENT CONTRACTING MICROSOFT DYNAMICS AX AND

SCOPE OF WORK FOR PERFORMING INTERNAL CONTROL AND STATUTORY/REGULATORY COMPLIANCE AUDITS FOR RECIPIENTS OF SPECIAL MUNICIPAL AID

Indirect Cost Rate Agreement Guide for Non-Profit Organizations

Review of Consultant/Professional Services Cost Accounts

Complying With DCAA (Defense Contract Audit Agency)

DEFENSE CONTRACT AUDIT AGENCY 8725 JOHN J. KINGMAN ROAD, SUITE 2135 FORT BELVOIR, VA PPS June 26, 2012 INFORMATION FOR CONTRACTORS

Ensure Compliance For Government Contractors

DCAA Our Role. Laura Cloyd-Hall, CPA, MBA John D. Mollohan II, CPA, CFE. Page 1. DCAA : Celebrating 50 Years of Excellence

Are You Looking to Sell Your Products & Services to the US Government? Overview

Section 3.16 Comprehensive Community Services (CCS) 2012

Transcription:

WHAT MAKES AN ACCOUNTING SYSTEM COMPLIANT Presented by: Laura Davis

OVERVIEW Why Do I Need a Compliant Accounting System Auditor s Judgment Definitions Key Components Audits How to be prepared for an audit Common Deficiencies

Why Be Compliant? Required by Cost-Type Contracts FAR Clause 52.216-7 Prime Contractor May Require Competitive on Future Bids Management Tool Claims/Requests for Equitable Adjustments

Auditor s Judgment Anything can cause an accounting system to fail Judgment will vary between auditors Perception is critical Using key phrases and words with auditor to show understanding of compliance Be prepared to use the auditor s lingo

Definitions FAR 2.101 Direct Costs Costs that can be identified specifically with a particular final cost objective Indirect Cost Any cost not directly identified with a single, final cost objective, but identified with two or more final cost objectives or with a least one intermediate cost objective Unallowable Costs any cost that, under the provisions of any pertinent law, regulation, or contract, cannot be included in prices, cost-reimbursements, or settlements under a Government contract to which it is allocable

Key Components Segregation of Direct and Indirect Costs Segregation of Direct Costs by Contract and/or task (depending on contract requirements) Collection of Indirect Costs by Cost Pool Segregation of Unallowable Costs Labor Tracking System Monitoring Against Contract Value

Key Components (Cont d) Recording Costs as Proposed / Billed Traceability of Transactions through the Accounting System Reconciliation of General Ledger to Job Cost Ledger Ability to Calculate Indirect Rates Policies / Procedures

Segregation of Costs Segregation of Costs handled through the Chart of Accounts Account Number Range for: Direct Each Cost Pool (Fringe, Overhead, G&A, etc) Unallowable Costs Segregation of Projects and Tasks usually handled with a Job Cost Ledger Can be built into Chart of Accounts, but is not recommended

Labor Tracking o Solid Timekeeping Procedures Controlled timesheets Audit trail of corrections/changes Signatures and approvals o Accounting System Visibility Reports of labor by person and/or by charge code Flows through the system to General Ledger and Job Cost Flows through to Billing, if billable Traceable back to payroll

Monitoring Contract Value Ability to track Billed against Funded and/or Contract Value FAR 52.232-20 Limitation of Costs Notify the CO when the Contractor has a reason to believe that: Inception to date costs are expected to be greater than a certain threshold (between 75% and 85%) of estimated costs within the next 30 90 days; or Total costs at completion will be greater than or substantially less than previously estimated costs.

Monitoring Contract Value (Cont d) FAR 52.232-21 Limitation of Funds written notice to the CO is required when the contractor has reason to believe that inception to date costs are expected to be greater than a certain threshold (between 75% and 85%) of funds allotted to contract within the next 30 90 days. In addition, sixty days prior to the end of the contract schedule, the contractor is required to provide written estimate of any additional funds required and when the funds would be required. If, after written notice, additional funds are not allotted to contract by CO, the contractor is not obligated to perform or incur additional costs and CO will terminate contract.

Collecting Costs As Proposed Cost Pools proposed vs. actual Cost Pools Treatment of Direct vs. Indirect Consistent Treatment of Costs

Tracing Costs Through the System Source document such as timesheet or vendor invoice Reviewing Edit Reports and Journals Verifying costs recorded on General Ledger Verifying costs recorded on Job Cost Ledger Flowing the costs through the billing Reviewing proof of payment

Job Cost to General Ledger Separate General Ledger and Job Cost Ledgers must be reconciled For QuickBooks, Company P&L compared to P&L by Job All direct costs must be associated with a contract/task Ability to print Job Cost Reports (P&L by Job)

Calculate Indirect Rates Ability to Calculate Indirect Rates Application of Indirect Rates to Projects Compare Provisional Rates to Actual Rates Impact on Billing Submitted Invoices for Rate Adjustment

Policies / Procedures Accounting Policy documenting accounting system, indirect rates, cost collection, etc. Policy on Unallowable Costs Labor / Timekeeping Policy Travel Policy Purchasing Policy Bonus

Accounting System Audits Triggered by Proposal Submission Contracting Officer Requests Pre Award - Must demonstrate design is acceptable Post Award - Must show system is working as designed Standard Form 1408

How to Prepare for Audit Review Standard Form 1408 Review/Complete DCAA Internal Control Questionnaire (ICQ) Review DCAA s Audit Program for Accounting System Review Company Policies/Procedures Perform Internal Audit Sample Transactions Sample Billings Review Contract Files Verify Timesheets Signed/Approved

Other Inadequate Areas Not Paying Vendors in Reasonable Time Inadequate Documentation No time cards for officers and owners All time is not reported (Total Time) Total of job cost reports does not reconcile to income statement Funding and cost limitations are not correct No billing to cost reconciliation is performed Direct Indirect Rate Variance No contract briefing cards

QUESTIONS?

Laura Davis 109A Jefferson Avenue Oak Ridge, TN 37830 (865) 220-0051 ldavis@scsconsults.com www.scsconsults.com Contact Information