ReliAscent's DCAA Blog

Uncompensated Overtime - A DCAA Hot Button

tlink@reliascent.com (Tyler Link) — Wed, 05 Feb 2014 19:53:00 GMT

One question we always get is how to account for uncompensated overtime. Almost every small business has at least one employee working gazillion hours over a standard 40-hour work week. The DCAA considers these hours "at work labor." They want these hours captured in the name of treating all contractors accounting and pricing systems equitably and consistently.

Not addressing this issue successfully now poses a huge risk since DCAA auditors have no wiggle room in overlooking it as a minor problem. Any deficiency in your accounting system will likely lead to a failing grade, according to the latest DCAA guidance to its auditors (see previous article). This could prevent you from obtaining lucrative flexibly-priced contracts or fixed price contracts financed through progress payments.

The DCAA way
The basic DCAA audit guidance for addressing uncompensated overtime is very simple and straight-forward. They will divide your yearly salary by all the hours you worked and used for personal time off. This results in your "effective" billing rate. The DCAA expects you to adjust your rate in your accounting system each pay period to reflect this effective rate. The drawback to this system is contractors have to make these adjustments in their accounting system every pay period. It also artificially reduces your hourly rate. The DCAA will use this lower rate when evaluating any proposal you have submitted to the government or a prime.

A better way
The DCAA guidance does recognize other methods as being suitably fair and consistent. One approach lets you use your existing timekeeping system to segregate your "extra effort" hours, dollarize those hours, and direct those dollars to the appropriate place on your balance sheet as a liability, similar to how you might already treat regular accrued wages. Periodically, you can bring those dollars back to the income statement as a credit expense in an indirect pool. This reduces your pool costs, which gives the government credit for your extra work. You also won't have to adjust your billing rates in your accounting system or for proposals.

Everyone's happy, even the DCAA. That's what life's all about for government contractors, right?

References:
1) DCAA Information for Contractors DCAAP 2641.90, section 2-302.1
2) DCAA Contract Audit Manual, section 6-410

Continue to follow the Tech BizSolutions Blog

manderson@ReliAscent.com (Mike Anderson) — Thu, 07 Jun 2012 19:57:00 GMT

As of June 1st, Tech BizSolutions, Inc. has merged with PBC, Inc of Denver to form a new company called ReliAscent, LLC. ReliAscent will still offer all of the same services that Tech BizSolutions and PBC offered individually. In addition, ReliAscent will offer services based on the synergy of bringing these two successful organizations under one roof. For instance, PBC has very detailed technical accounting knowledge to add to the Tech Biz accounting knowledge base. Tech BizSolutions has a wealth of contract management knowledge to add to the base of PBC's knowledge of government contracts. PBC has focused on the SBIR/STTR market in the past and brings intimate knowledge of this contract vehicle to the offering. Tech BizSolutions has offered services to all types of government contractors including Broad Agency Announcements, IDIQ contracts, GSA schedules, Seaport-e contracts, EFAST contracts and other contracting vehicles. PBC brings a strong working knowledge of the 8(a) program and other specialized contracting vehicles.

The bottom line is that we believe the synergy of working together will be much greater than the sum of the two individual companies. We envision that someday we can provide complete, compliant, efficient back office services to our clients in a virtual manner. We anticipate being able to provide more timely services to our clients, have more backup talent in the office, provide a wider scope of services and therefore a better bottom line to our clients. We will perform all of the mundane, back office tasks, that businesses get bogged down with. We can perform these duties more efficiently, based on our knowledge base, experience and we enjoy doing these tasks. This will allow our clients to focus on their expertise (the technical aspects that will bring money in the door). This will bring better profits to the table for our clients and reduce their operating risk. Please continue to follow our blog but now it will be found at the url: www.reliascent.com/government-contracting-blog/.

Outsourced Accounting and Cloud Computing Means Compliance

manderson@ReliAscent.com (Mike Anderson) — Tue, 14 Feb 2012 16:02:00 GMT

How do small businesses survive in the world today, especially when they are primarily government contractors? The government has such a twisted path of regulations concerning contractors and then they control the amount of fee or profit that the small business can earn. There is definately a cost in doing business with the government that many businesses don't realize when starting. One of the constants we have noticed over the years is that experience in government contracting makes a difference. Small businesses usually can't afford to hire someone with experience on their staff but they can hire a consultant and outsource this experience level on an "as needed" basis. We have found that fully outsourcing back office services such as bookkeeping, accounting, payroll, contract management and even HR or purchasing can be valuable to the small business. This allows those services to be performed by "experts" in the area and allows the members of the small business to focus on the tasks that they are experts at - thereby increasing their value to the bottom line. A web hosted accounting system is a great tool for this scenario because both the outsourced consultant as well as company management can access the financial records at any time. The following video outlines some of the benefits of such a web hosted solution, just imagine the cloud shared application is your accounting system!

In government contracting there are many risks of not being compliant with either your accounting system or your contract. Sometimes companies are not aware of the risk they are running until an audit or a contract close out occurs and then the problem can be too large for the small business to survive. Prevent that from happening by hiring a knowledgeable consultant to:

Maintain and verify your compliance on a daily basis
Free up your valuable time to contribute to the bottom line
Perform routine and mundane tasks but in fully compliant terms
Provide real time management reports and documents on a cloud based solution
Help direct your business to the most profitable path

At Tech BizSolutions, we have the experience and we are the experts in these back office services.

Top Ten Tips for year end allowable costs

HubSpot User Default — Wed, 14 Dec 2011 16:55:00 GMT

You read many articles this time of year about easily overlooked IRS deductions for your personal taxes. A similar dynamic applies to government contractors when evaluating actual indirect rates for the year.

Measuring indirect rates is critical for contractors having cost reimbursable contracts or cost-funded grants. Under-running billing rates (pre-approved, negotiated, or capped annual indirect rates) means you may owe the government money on contracts with cost-based billings or grant drawdowns.

While undesirable in this first case, low indirect rates can mean extra profits on Time & Material or Fixed-Price contracts. However, under-running rates on T&M and fixed –price contracts might not be in your best interest from a long-term financial or competitive pricing point of view.

So here is our Top 10 List of easily overlooked allowable expenses for government contractors that you can take advantage of before the end of the year.

Accrued vacation (FAR 31.205-6)
Bonuses (FAR 31.205-6)
Equipment, hardware, software below capitalization limit (FAR 31.205-25/26)
Raise the capitalization limit to $5,000 per item
Training/seminars (FAR 31.205-44)
Dues and subscriptions (FAR 31.205-44)
Visiting prospects (FAR 31.205-46)
Bid and Proposal (FAR 31.205-18)
Independent Research & Development (FAR 31.205-18)
Some patent and other legal costs (FAR 31.205-28/30)

New potential DCAA threat - rejected cost vouchers in 2012

HubSpot User Default — Wed, 07 Dec 2011 15:22:00 GMT

The DCAA appears to be pushing for Provisional Billing Rate (PBR) proposals earlier than past years. PBR proposals have suffered a tortured history the past few years. They have alternately been ignored and considered mandatory by the DCAA. Now, we’re getting the sense that the DCAA may be insisting on proposals even if indirect rates don’t change. One clients said their auditor advised they should get their billing rate proposal in the first of the year to assure that there is no gap in billing.

As a reminder, under cost-plus type contract having FAR clause 52.216-7 and 42.704, contractors must establish provisional billing rates for those contracts. This allows contractors to use fixed indirect rates for billing purposes for a specific annual period. The risk contractors now face is the DCAA or contracting officer rejecting invoices sent to the government in the new year without a new negotiated PBR.

Tech Biz has the tools to perform this analysis and advise clients on indirect rate strategies that ensure profitability and growth in the government contracting environment. With cashflow being more critical now in this austere budget environment, it's best to be prepared rather than surprised by government actions.

Top 5 Reasons Small Government Contractors should outsorce their CFO

manderson@ReliAscent.com (Mike Anderson) — Fri, 28 Oct 2011 14:21:00 GMT

In small businesses executives must wear many hats. There simply isn't enough revenue to fund specialists in various "non-direct" areas like accounting. For this reason alone, the Chief Financial Officer (CFO) duties are often carried out either by a founder with limited financial experience or carried out by someone who does not have enough time to devote to the duties to do the job in a complete and efficient manner. As a result, the business usually suffers. To hire, as a consultant, an outsourced CFO for your business you can focus on the tasks that will bring the most benefit to your firm again and rest assured that the financial health and strategic growth of the company are being watched. Here is a quick list of the top 5 reasons for hiring a consultant to serve as your CFO:

Cash flow: Cash flow is the lifeblood of a small government contractor or subcontractor. Managing cash for a small government contractor requires knowledge of government contract types and specific clauses related to contract payment. Negotiating the most favorable terms may mean the difference between long term success or failure of the contract and possibly even the firm.
Pricing: Pricing in the proposal stage of a contract is crucial. Knowing how to leverage government cost rules when budgeting and pricing new proposals will directly affect cash flow after the award of the contract. With all the FAR regulations and other flow-downs on most government contracts it is critical that the small business has an expert CFO that can anticipate and construct pricing models that will be in the best interests of the firm going forward.
Compliance: Depending on your mix and dollar amounts of the contracts, your financial and business systems may be heavily scrutinized by the government. Most small businesses simply don't have the expertise to survive the scrutiny if it focuses on your firm. An experienced outsourced CFO can provide that expertise and stability.
Profitability: Success as a government contractor means monitoring profits and threats to performance on a job-by-job basis. Understanding the special contractual obligations imposed by government work is key to assuring this success. Understanding all of the government's complex matrix of requirements and applying them strategically can also lead to the maximization of a limited "fee" under government contracting guidelines.
Company Vision: An outsourced CFO provides a "second set of independent eyes" on your business that assures the best possible long term strategy. This helps control costs because you pay for only the CFO duties that you need and don't need to pay 6 figures to receive the benefit of this position. A part-time CFO makes you look "bigger" and helps assure the government of your ability to survive and grow in the market. Also, by hiring a consultant you may have the benefit of more than one CFO at the outsourced agency that can "poll" their ideas and strategies resulting in a better final strategy for the small business. To top it all off, this is an allowable expense for government contractors.

Tech BizSolutions offers experienced CFO personnel on an outsourced basis. All of our CFO's have over 20 years experience with government contracting and financial responsibilities. Call me today if you want to discuss how this could positively impact your business.

Budget Cuts, Fraud & Inefficiency Means Stricter Compliance

manderson@ReliAscent.com (Mike Anderson) — Wed, 12 Oct 2011 14:30:00 GMT

There may be a perfect storm brewing in the government contracting world that will make it harder to do business with the federal government. It started in July of 2008 when the Government Accountability Office (GAO) issued a report that 3 of 3 DCAA audits showed inadequacies in the DCAA's performance of the audits. This was followed up with another GAO investigation in September of 2009 that indicated a widespread problem within the DCAA organization. As a result the DCAA went through 3 directors in a little over a year. Major reform was announced and the DCAA is performing audits strictly to the book now, with only a "pass/fail" grade issued. But even with this increasing dose of compliance issues for contractors, there continues to be problems . Does it seem to you that we are hearing more about federal contractor fraud cases lately? And then how about the case where government contractor executives are paid excessive salaries? Many contracts suffer from cost overruns and late deliveries. Combine all of this with the current economic crisis and the emphasis on cutting the federal budget and we have a perfect storm focused on government contractors. What does this mean? I think it will mean more scrutiny on government contractors, more emphasis for compliance and certainly more emphasis on performance. There will be more difficulty for firms to survive in the government marketplace that do not meet all he compliance issues and/or that don't perform on-time and either on budget or under budget. The contractors that can do this will be rewarded. The contractors that cannot perform to this new standard will be rapidly pared from the market. Companies that have an experienced staff to respond to all the government's compliance issues will prosper. Companies that do not have significant experience in this area need to shore up that weakness. Outsourcing this function can strengthen a company and assure survival. Tech BizSolutions staff has the experience to offer to these companies in need of this service. Call us today if you need to address a weakness or potential weakness. We can help.

Happy New Year Government Contractors

manderson@ReliAscent.com (Mike Anderson) — Wed, 05 Oct 2011 14:56:00 GMT

The new year starts this week for the government. Just like last year at this time, the budget is not yet approved for this fiscal year. Instead, the House just approved yesterday a measure to operate through mid-November. This happened several times last fiscal year too if you remember. Finally the government threatened to shut down in late spring before congress approved the budget. In other words, the government operated half way through the fiscal year without an approved spending budget! (Try that in your business!!) We are headed for more of the same this year. Federal spending is cautious at best under such guidelines. Spending is postponed for fear of possible cuts and/or cancellations. This makes it difficult not only for the Contracting Officers but also for the businesses bidding on projects that the government needs to buy. Combine this with the proposed trimming of the budget and business is very uncertain and tough for small business contractors. Large business contractors also feel the pain. It has always been a challenge to do business with the Federal Government but now, especially with the certain drop in defense spending for the first time in over 10 years, makes it even more challenging. There are some areas of opportunity in this market however. It seems that certain areas of spending will demand a growing emphasis, including areas such as Energy (especially conservation related areas), Healthcare, Budget Streamlining and Cybersecurity. There will continue to be Defense related opportunities (spending will be cut, not eliminated) but they will result in more competition and it will be harder to secure them. This will mean businesses need to focus on making sure their systems are compliant, that they can deliver a quality product, at a competitive price and on time. Sounds like typical "lip service" except in today's environment this is no longer "lip service". Only the "best" will survive the competition. If you would like help making sure your offering is in this class, Tech BizSolutions can help you.

Federal Contracts: Quick-closeout procedure

manderson@ReliAscent.com (Mike Anderson) — Mon, 03 Oct 2011 20:52:00 GMT

In helping a client recently with some contract closures, it became quickly apparent that the DCAA was way behind in getting to the audit of the system to close out this contract. It became quickly apparent that there are several risk factors for this happening. First the contract work will be in the distant rear-view mirror by the time the audit takes place. The chance of misplaced records and forgotten tasks becomes much greater as more time passes. Such omissions could result in the government disallowing costs that would change the indirect rates. This could end up costing the company money. To mitigate this risk, it can be in a contractor's best interest to try to have the government perform what is called the quick closeout procedure. This is described in FAR 42.708. This clause allows the Contracting Officer (CO) to negotiate the settlement of indirect costs for a specific contract. There are a couple of requirements to be able to use this clause. First the contract must be complete. Then the contract's unsettled cost must be relatively insignificant. For the government, insignificant usually means unsettled indirect costs of less than a million dollars for one contract. There are provisions for restrictions to not exceed 15% of the estimated total unsettled indirect costs allocable to cost-type contracts for that year too. It is worthwhile to talk with your CO to see if an agreement could be reached to close out the contract so you don't have to wait for the DCAA to "wade" through their backlog and get to your specific contract. By the time they get to it, you could end up with a penalty that you didn't anticipate.

Government Contracting: 5 Strategies to Beat the Budget Crunch

manderson@ReliAscent.com (Mike Anderson) — Tue, 06 Sep 2011 21:54:00 GMT

The government plans to cut $2.4 Trillion from the budget over the next 10 years, beginning in the 2012 budget. It is expected that up to $900 Billion in cuts could be included in the 2012 budget. The Defense department could see over $28 Billion in cuts in 2012 with an expected $350 Billion over the next 10 years. Federal agencies and departments are "running scared". Contractors should be too as many current programs either will not exist or may exist in a reduced form in the next budget. The Federal Budget is a large pendulum that swings from one extreme to the other. We have enjoyed almost 10 years now of increased spending that can only be viewed as a boom. Now there is a correction. Sometime in the future the pendulum will swing back, we need to survive in the meantime. Here are 5 strategies that small businesses can use to help mitigate their risk in this uncertain time;

1) Communicate with your customer - You need to stay close with your customer to find out as much as you can about their changing needs. You should be having regular conversations with your CO, your TPOC and other customer contacts to not only tell them about progress on current jobs but to find out more about what is happening in their organization. What priorities are changing, how can you help solve these changing needs with your value proposition.

2) Subcontract with Primes - If you currently are contracting direct with the government and think the contract may change, you should look to team with a large Prime that may need your expertise and help. The Small Business Liaison at these companies is a good place to start to form a relationship.

3) Diversify your government customer base - You may want to look at other agencies that could use your products and services. For instance if you have been supplying IT services to a military base (DoD) you may want to look at how the other agencies like NIH, DOE, etc. might use your services. Don't be afraid to visit these "target" agency websites to find initial contacts and drill down to find the right people to talk to.

4) Diversify your product offering - Currently some of the large DoD primes are adding health care services to their product portfolios. They are doing this to help bolster top line revenue in anticipation of loosing DoD weapons and other related sales.

5) Diversify to commercial markets - If you have been successful in selling to the government, are there commercial markets that you have overlooked in the recent boom? Time to analyze the market and target some more commercial sales.