The Auditor Strikes Back: Patent Costs Get an Update
As we reported in October, the Defense Contract Audit Agency (“DCAA”) Contract Audit Manual (“CAM”) was recently updated. One of the thirteen areas of cost updated related to patent costs. This topic is covered in Chapter 52 of the CAM, with the new version being separated into three key topics: 52-1, Allowability of Patent Costs 52-2, Patent Rights – Ownership by the Contractor and the Allowability of Associated Patent Costs 52-3, Special Requirements for Nonprofit Organizations Previously, the DCAA CAM addressed patent costs in Chapter 7-700, which was less than three pages in length on treatment of patent costs for allowability purposes. The. Read More.
Episode 1: Manufacturing and Production Engineering Costs vs. Independent Research & Development Costs
For companies that incur manufacturing, production line, engineering or product development costs, determining the true nature of the cost can be difficult. The Federal Acquisition Regulation (“FAR”) points us to FAR 31.205-25 — Manufacturing and Production Engineering Cost, to help companies determine if the cost incurred should be considered a manufacturing and production engineering cost. However, the issue companies have is where one draws the line if the costs should actually be considered independent research & development (“IR&D”). Determining if the costs falls under FAR 31.205-25 or meets the definition of FAR 31.205-18 and is considered IR&D doesn’t just impact. Read More.
Topics: DCAA Contract Audit Manual, Defense Acquisition Regulations System, Defense Contract Audit Agency "DCAA", Federal Acquisition Regulation "FAR", Independent Research and Development "IR&D", Manufacturing and Production Engineering Costs
The Auditor Strikes Back: Updated Cost Allowability Guidance Published by DCAA
During late summer, the Defense Contract Audit Agency (“DCAA”) published a “Selected Areas of Cost” guidebook to replace Chapter 7 of the DCAA Contract Audit Manual (“CAM”). The newly refreshed guidebook provides further direction for auditors and contractors on how to properly treat certain types of costs listed in Federal Acquisition Regulation (“FAR”) 31.2 regarding allowability. Specifically, an unlucky 13 areas of costs have been updated with additional guidance. Those costs include: Bonus and Incentive Compensation Joint Ventures and Teaming Arrangements Depreciation Insurance IR&D/B&P Idle Facilities and Idle Capacity Legal Patents Royalties Consultants Pensions Alcoholic Beverages Manufacturing and Production Engineering. Read More.