Department of Energy (DoE) Accounting Requirements

While most of the “granting” agencies follow the compliance requirements in Uniform Guidance (UG) (Title 2 Code of Federal Regulations Part 200), the DOE issued its own additional regulations under 2 CFR Part 910.

The Department of Energy can issue contracts, grants or cooperative agreements, and generally, the requirements for an accounting system are relatively uniform (especially when dealing with "for profit" entities).  Many DOE grants & contracts require awardees to comply with GAAP and the cost principles found in Title 48 CFR Part 31. It’s important to read through these award documents to understand the differences between the requirements, and which part of either the Uniform Guidance or the FAR apply to your grant, as they vary from grant to grant based on the program, funding, and other factors. 

Noncompliance with your award’s requirements can result in disciplinary action, which can range from debarment from future federal funding to audits by a federal agency.

If you have a contract or grant from the DoE, ReliAscent can install a DCAA or FAR Part 31 compliant accounting system, and provide you with outsourced accounting and DCAA audit support.

 

Calculating an Indirect Cost Rate for DoE

When putting together your grant’s budget, the Indirect costs are going to be an important part of the approved grant budget. For companies that have never had a federal grant or a government contract, calculating this indirect cost rate can be difficult, but it can be easily done with the help of experts.

Companies have the option to choose the 10% de minimis rate or they can propose a higher indirect cost rate (as long as they use a methodology that is acceptable by the cognizant agency and can justify the rate with the proper data and calculations). ReliAscent always suggests grantees calculate their own indirect cost rate before taking the 10% de minimis rate, because in many cases, it will be considerably higher, and the government doesn’t reward you for leaving money on the table. Note however, that some grants do have caps on indirect costs.

 

DoE Audits

The DoE requires that any "for profit" entity that receives awards from DoE have either the DCAA or an independent public accountant (IPA), audit their system periodically if the entity expends more than $750,000 (total federal expenditures) in the year.  The contracting officer will determine the required frequency of the audits.  The audit report must be available to the DoE contracting officer(s) that have awards with the company. 

Many companies do not realize that the burden of audit falls directly on the awardee.  While this is an allowable expense, it is a necessary expense to companies meeting this Federal expenditure level. ReliAscent can help to set-up a compliant system and can work with the audit agency to make sure the company is found compliant.  It is important to note that the awardee may not request an audit from the DCAA (only a contracting officer may request a DCAA audit).  The awardee may schedule an independent audit, at their own expense.  Audits can be stressful for the unprepared but ReliAscent can take the stress out of the audit.

There are two basic requirements in a DoE audit for the auditor to determine & report:

  • If the awardee has an internal control structure that provides reasonable assurance that it is managing Federal awards in compliance with Federal laws and regulations and the terms and conditions of the awards.
  • Based on a sampling of Federal award expenditures, the recipient has complied with laws, regulations, and award terms that may have a direct and material effect on Federal awards.

 

Department of Energy SBIR/STTR Grant Accounting Services

First, it is important to note that you do not need to hire a govcon accounting firm like ReliAscent during your DoE Ph I grant. As long as you track your direct grant expenses and time, there is no need to pay for gimmicky "Ph I packages" or services to SBIR accounting firms. However, once your Ph II proposal is selected for funding, the compliance requirements become far more stringent, as DoE treats their grants like cost type contracts.

Once your business has a DoE SBIR Ph II (or DoE contract or cost share that requires much stricter accounting compliance), ReliAscent provides your business with a DCAA & FAR compliant accounting system, and then provides the outsourced accounting services needed to maintain compliance and pass any audits. All grantees are provided with the same DCAA compliant,  QuickBooks Online or (cloud-hosted) Enterprise system, and all bookkeeping, accounting, financial reporting, audit support, and grant drawdowns are handled by our accounting teams.

Compliant system setup starts at $2,000, and monthly accounting services for DoE Ph II winners and Cost Share awardees start at $1,500/month. To learn more about our accounting services for DoE grantees, contact us today for a no-obligation quote.