DCAA Compliance Blog
Your Source for DCAA & FAR Compliance News and Discussion
ReliAscent® LLC is the only government contract accounting firm that specializes in all aspects of government contracting compliance. From our DCAA compliant accounting services, to monthly government contract accounting for all government agency awards, contract management & administration, and financial services & planning, our goal is to ensure the success of our clients, and all small business government contractors and grantees.
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ReliAscent was involved in a recent negotiation with a Government Laboratory (the Lab is currently being run by a contractor), ReliAscent was told by the contractor that “travel time should NOT be charged or added to the cost of the contract”. ReliAscent informed the contractor that this was not proper but the contractor asked for references from the FAR to support the position ReliAscent was supporting. Through our experience with many contractors, ReliAscent believes that this point of view (not charging travel to the contract) is held by a number contractors. This point of view could originate from the commercial practice of company’s doing commercial work that expect their people to travel on their own personal time (rather than charge the company, or in this instance – the contract for travel).Read More
Topics: Allowable cost
The National Defense Authorization Act (NDAA) of 2012 set into motion a limit on the executive pay issue relative to government contractors. The NDAA resulted in an interim rule 78 FR 38535. Initially FAR Case 2012-017 extended applicability of the limit from not only the top 5 executives but further to all employees. FAR Case 2012-025 was then implemented that made this new caps retroactive to contracts issued prior to December 31, 2011 (It would affect billings on 1/1/2012 or after). These interim rules were recently finalized and will result in a change in the regulations. This rule change is applicable to all contracts with the Department of Defense, NASA and the GSA. The new rule will control not only the executive compensation limits on contractors but will control all pay levels (there may be some exceptions for certain scientist and engineers in highly specialized fields) of all employees. While I say "control compensation" it doesn't mean that the company cannot compensate individuals at levels above the limit but instead that any amount over the cap will be considered an "unallowable" expense and therefore not billable to the government.
Government contractors must pay close attention to costs and whether or not the government considers them allowable costs or unallowable costs. The government outlines specific costs that they do not want to see in their direct billings and they also do not want to see these included in any part of the calculation of the indirect rates. The accounting system should provide a mechanism to prevent the inclusion of these types of costs. An audit of an accounting system for compliance to government requirements will always look for such a systematic way of preventing these costs from billing to the government. The allowability of these costs is defined in the Federal Acquisition Regulations (the FAR) in part 31.205. There are certain costs in this part of the FAR that are unallowable under any circumstance. A summary of some of this type of unallowable costs are: