Your Source for DCAA News and Government Contracting Information 


Uncompensated Overtime - A DCAA Hot Button

Posted by Tyler Link on Wed, Feb 05, 2014 @ 12:53 PM

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?

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Topics: DCAA compliance, government cost accounting, DCAA audit, uncompensated overtime dcaa, uncompensated overtime

Continue to follow the Tech BizSolutions Blog

Posted by Mike Anderson on Thu, Jun 07, 2012 @ 01:57 PM

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. ReliAscent Group

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Topics: Government contract consultants, Tech BizSolutions

Outsourced Accounting and Cloud Computing Means Compliance

Posted by Mike Anderson on Tue, Feb 14, 2012 @ 09:02 AM

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!

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Topics: business consultants, Government contract consultants, DCAA compliance, Outsourced CFO

Provisional Rates - A potential DCAA focus area in 2012

Posted by Mike Anderson on Tue, Jan 24, 2012 @ 03:01 PM

Provisional Rates

Over the last year or so the DCAA has focused attention on larger government contractors.  Many smaller businesses may feel left out since they have not been visited by the DCAA.  More likely, they may feel that everything is "ok" since for most of us "no news is good news".  Our Account Managers here have been hearing bits of news from various sources that this might change in 2012.  First, the DCAA is apparently going to focus more on completing Incurred Cost Proposal audits in 2012, especially from smaller contractors.  The backlog of Incurred Cost audits was estimated to have quadrupled over the last 10 years but even DCAA Director Fitzgerald didn't know the exact number in a meeting with Senators Brown (R-MA) & McCaskill (D-MO) in  February last year.  Rest assured the number is huge.  We have recently seen clients that have received letters from the DCAA that demand the Provisional Billing Rates for Jan. 1, 2012 thru Dec. 31, 2012 be completed and turned in to the DCAA by February 1, 2012.  So we are seeing focus not only on the provisional rates (Ref Far 42.704(b)) but we expect to see a focus on cleaning up the backlog of Incurred Cost Proposals.  Both of these efforts will affect small business contractors.  The Provisional rates affect your ability to bill the government in the near future.  Once the DCAA audits the Incurred Cost Proposals the provisional rates become final rates.  The government is bound to payment based on the final indirect rates so these are very important numbers.  If your final indirect cost rates are lower than your provisional indirect cost rates, then the contractor could be liable for repayment to the government.  The important message for all government contractors is twofold: 1) it is important that your provisional rates are calculated correctly so that they come as close as possible to the final rates and 2) it is important that your Incurred Cost Reports are correctly done and accurate.  We envision spending a lot of time on those two areas this year.  It would be wise for all government contractors to do the same.

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Topics: Indirect billing rates, Year end indirect rates, Provisional rates, DCAA, DCAA audit

Top Ten Tips for year end allowable costs

Posted by HubSpot User Default on Wed, Dec 14, 2011 @ 09:55 AM

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.

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Monitor your subcontractor's Incurred Cost Submissions

Posted by Mike Anderson on Mon, Dec 12, 2011 @ 07:20 AM

Tech BizSolutions has noticed another policy change from the DCAA recently that could impact the bottom line of a small business.  One of our clients received a notice from the DCAA that indicated there will be more emphasis on subcontracts.  Specifically this emphasis will be on reviewing policies and procedures related to subcontracting.  Two areas of concern were outlined on monitoring subcontractors  and on requiring subcontractors over $700K to submit Incurred Cost Submissions either to the prime or to your ACO in accordance with FAR 52.216-7.  This has significant impact for many small businesses.   Tech BizSolutions can help any company with preparation of an Incurred Cost Submission as well as your subcontractors (just a reminder that an Incurred Cost Submission is due within 6 months from the end of a company’s fiscal year per FAR 52.216-15).  

So there are basically 2 action items required:

1.  You may need to review your Policies and Procedures to make sure you have the proper documents in place for your subcontracts and control of your subcontractors.  Tech BizSolutions can help you by performing a review and providing a “gap” analysis.  Then Tech BizSolutions can help fill in these “gaps” with standard procedures that Tech BizSolutions has developed to handle these situations. Of course, training can be supplied by Tech BizSolutions until you are comfortable that these policies and procedures are working properly to be compliant.

2.  You may need help with preparing your Incurred Cost Submission.  Now is not too early to start getting ready even though it may  not be due for 6 months.  Completing your ICE early can also help improve your positive cash flow.  To help you complete your ICE report, Tech BizSolutions has created two valuable resources to help you prepare for your ICE submission.  Use these resources to ensure you can accurately finish each Schedule from the ICE.  Click on the links below and you will be directed to our website where you can download each today!

Download your copy of “The Ice Date Requirements Checklist” here!

Download your copy of “The ICE Preparation Checklist” here!

Tech BizSolutions can help your company prepare a complete Incurred Cost Submission to ensure you remain in compliance.  Tech BizSolutions staff are experts in completing Incurred Cost Submissions.  We will complete this accurately, quickly, and in the most advantageous fashion for the needs of your company.

    Contact us today to see how we can help you with these important tasks.  In today’s government contracting environment you don’t want to have this done improperly.  Errors in Incurred Cost submissions can take money from your bottom line.  Don’t let that happen.  Call Tech BizSolutions today to see how we can help you protect your bottom line.

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    Topics: Incurred Cost Submission, DCAA compliance

    New potential DCAA threat - rejected cost vouchers in 2012

    Posted by HubSpot User Default on Wed, Dec 07, 2011 @ 08:22 AM

    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.

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