DCAA Compliance Summary 06.13.11
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DCAA Compliance Summary 06.13.11

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DCAA Compliance Summary 06.13.11 DCAA Compliance Summary 06.13.11 Presentation Transcript

  • Government Contractor Compliance Requirements
    DCAA – Defense Contract Audit Agency
    FAR – Federal Acquisition Regulation
    CAS – Cost Accounting Standards
    Summarized by Teri Wilt
    06/13/11
  • 1) Timekeeping Requirements
    2) Labor Accounting Practices
    3) Indirect Cost Pools/Burden Rates
    4) FAR Expressly Unallowable Costs
    5) ICE - Incurred Cost Submissions
    6) DCAA Audit-Preaward/Postaward
    7) Contract Closeout/Final Billing
    8) Quick-Closeout Procedures
    Table of Contents
    Teri.Wilt@att.net
    2
    06/13/11
  • Timesheets are required for all employees
    Employee must record hours worked daily
    Must report all hours worked if paid or not
    Only employee can complete his timesheet
    Employee must know projects to charge to
    Only paid leave can be recorded in advance
    Employee must sign & supervisor approves
    Changes require explanation & both initials
    Mandatory employee timekeeping training
    Written timekeeping policies & procedures
    Timekeeping is an important job function
    Timekeeping Requirements
    Teri.Wilt@att.net
    3
    06/13/11
  • Total time accounting is required for labor
    Employees record all hours, employee pay per company policy, billing by contract type
    Non-exempt hourly employees are paid OT
    by state law, but contract may not allow OT
    Exempt salaried employees are not eligible
    for OT and if they work more than standard
    hours, the hourly rate is prorated on hours
    Hourly exempt – Paid all hours straight rate
    Labor Accounting Practices
    Teri.Wilt@att.net
    4
    06/13/11
  • Clearly segregate direct vs. indirect costs
    Collect direct costs by project = contract
    Exclude unallowable cost per FAR Part 31
    Accumulate indirect costs into cost pools
    Cost pools are logical groupings of costs
    Allocate indirect on causal beneficial basis
    Most common indirect cost pools include:
    Fringe is allocated over total labor dollars
    Overhead allocated over total direct labor
    G&A allocated over total direct & indirect
    Indirect Cost Pool/Burden Rates
    Teri.Wilt@att.net
    5
    06/13/11
  • 31.205-1 Advertising
    31.205-3 Bad Debts
    31.205-7 Costs for contingencies
    31.205-8 Contribution/donations
    31.205-14 Entertainment expenses
    31.205-15 Fines and penalties
    31.205-20 Interest expense
    31.205-23 Losses on other contracts
    31.205-27 Costs of reorganization
    31.205-41 Federal income taxes
    Teri.Wilt@att.net
    FAR-Expressly Unallowable Costs
    6
    06/13/11
  • Due six months after company year end
    ICE form and instructions available online
    All required ICE schedules are completed
    DCAA can and will reject for inadequacy
    Includes actual direct and indirect costs
    Exclude unallowable from pools not base
    Reconciliations to all accounting records
    Shows incurred cost adjusted to claimed
    Must match Forward Pricing rate structure
    Must match to CASB Disclosure Statement
    ICE-Incurred Cost Submissions
    Teri.Wilt@att.net
    7
    06/13/11
  • Pre-award Financial Capability Assessment
    Pre-award System Adequacy– Timekeeping,
    Accounting, Billing, Estimating, Purchasing
    Pre-award Flexibly-priced Proposal Audits
    Forward Pricing Rate Proposal Annual Audit
    often same rates as Provisional Billing Rates
    MAAR–Mandatory Annual Audit 19 Reviews
    Timekeeping Floor Check Audit is 1 MAAR
    ICE Audit of Incurred Cost Claim submitted
    CAS (Cost Accounting Standards)-19 Audits
    DCAA Audits – Pre/Post Award
    Teri.Wilt@att.net
    8
    06/13/11
  • Required for Prime contracts & Subcontracts
    Due 120 days after final indirect rate audits
    May be at Contract level or Task/D.O. levels
    Must have final billings from Subcontractors
    Forms DD882 Patents & DD 1662 Govt Prop
    Must submit final billing with audited rates
    Contractor’s Release and Assignment forms will be signed & notarized by notary public
    See FAR 4.804 – Close-out of Contract Files
    Contract Closeout/Final Billing
    Teri.Wilt@att.net
    9
    06/13/11
  • To avoid wait for final rate audit approval
    Negotiated between ACO and Contractor
    Contract work & paperwork must be done
    Unsettled indirect cost must be < $1M &
    < 15% FY cum unsettled indirect cost-type
    Parties must agree on total amounts to pay
    Rates are final regardless of incurred finals
    These rates do not apply to other contracts
    ACO decision may be subjective on history
    Risk considers accounting system adequacy
    Refer to FAR 42.708 for more information
    Contract Quick-Closeouts
    Teri.Wilt@att.net
    10
    06/13/11
  • Questions?Teri.Wilt@att.net