Payment of Interim Vouchers under Cost Reimbursement Contracts
In the mid-1990’s, the Department of Defense (“DoD”) instituted a new policy of permitting contractors who met certain criteria to submit interim vouchers under cost reimbursement contracts directly to the Defense Finance and Accounting Service (DFAS) payment office. Under this policy, known as direct billing, the Defense Contract Audit Agency (“DCAA”) did not review these vouchers before they were sent to DFAS. By eliminating the DCAA review, contractors were able to be reimbursed much quicker for costs they had incurred in performing these contracts. However, in 2012, DoD changed this policy and eliminated the direct billing procedure. As currently written,. Read More.
Topics: Cost Reimbursement Contracts, Defense Contract Audit Agency "DCAA", Defense Federal Acquisition Regulation Supplement "DFARS", Defense Finance and Accounting Service "DFAS", Department of Defense "DoD", Memoranda for Regional Directors "MRDs"
DCAA and Executive Compensation after Taylor/Metron
By: John Ford , Senior Consultant, Government Contractor Services Group Within a period of approximately six months at the beginning of 2012, the Armed Services Board of Contract Appeals (“ASBCA”; “the Board”) issued two significant decisions concerning the process for determining reasonable compensation under Federal Acquisition Regulation (FAR) 31.205-6(b)(2). These decisions were J.F. Taylor, Inc., ASBCA Nos. 56105 and 56322 (Jan. 18, 2012) and Metron, Inc., ASBCA Nos. 56624, 56751 and 56752 (June 4, 2012). In both cases, the Defense Contract Audit Agency (“DCAA”) had questioned substantial amounts of compensation as being unreasonable. This conclusion was reached by following the standard procedure. Read More.
Topics: Armed Services Board of Contract Appeals "ASBCA", Contract Audit Manual "CAM", Defense Contract Audit Agency "DCAA", Federal Acquisition Regulation "FAR", Upper Limit of Reasonable Compensation "ULRC"
DoD Inspector General Issues Two Reports on DCAA Quality Control
On August 27, 2014, the Defense Contract Audit Agency (“DCAA”) issued Memorandum for Regional Directors (MRD) 14-PAS-014(R) , captioned ”Audit Guidance on Removal of Modified GAGAS Statement in Audit Reports”. As background for this MRD, Generally Accepted Government Auditing Standards (GAGAS) require audit organizations to obtain an external peer review at least once every three years. For DCAA, the external reviews are performed by the Department of Defense’s (“DoD”) Inspector General. In August 2009, the Inspector General revoked its previous approval of DCAA’s quality control program. As a consequence, since August 2009, DCAA has been unable to state that it performed its audits in accordance with. Read More.
Unbilled Accounts Receivable: Real or Imagined Assets?
Unbilled accounts receivable (A/R) represents recorded revenue that has not yet been billed on a contract. There can be many different reasons for having unbilled A/R recorded on the balance sheet (B/S). Government contractors with cost reimbursable contracts tend to have greater unbilled accounts that stay on the B/S longer. The most common reasons for unbilled A/R are the following: Timing differences: These can exist due to the normal timeframe of processing employee timesheets and invoices through the accounting system. These amounts should be billed as soon as possible in accordance with contractual terms. Rate variances: These can exist when. Read More.
DCAA Issues Guidance on Dealing with Delinquent Final Indirect Cost Rate Proposals
On February 3, 2014, the Defense Contract Audit Agency (“DCAA”) issued Memorandum for Regional Directors (MRD) 14-PPD-002(R), entitled, Treatment of Delinquent Final Indirect Rate Proposals. As indicated by the title, the guidance addresses steps DCAA and the Defense Contract Management Agency (“DCMA”) will take when a contractor does not submit its final indirect cost rate proposal on time. Before discussing the MRD, some background information on submission of final indirect cost rate proposals is in order. Contrary to the belief of some DCAA auditors, contractors do not have an inherent duty to establish final indirect cost rates. Instead, contractors are. Read More.
Topics: Allowable Cost and Payment, Audit, Defense Contract Audit Agency "DCAA", Defense Contract Management Agency "DCMA", Defense Federal Acquisition Regulation Supplement, Federal Acquisition Regulation "FAR", Government Contracting, Indirect Cost Rates, Memorandum for Regional Directors "MRD"
DCAA Issues new Guidance on Establishment of Provisional Billing Rates
On June 27, 2014, the Defense Contract Audit Agency (“DCAA”) issued Memorandum for Regional Directors (“MRD”) 14-PPS-012(R) Guidance on Establishing Provisional Billing Rates . The new guidance is effective October 1, 2014, but early implementation is encouraged. This new guidance should help to ease issues that have arisen between DCAA and contractors regarding a contractor’s obligation to submit a proposal to establish billing rates. In the past, some of our clients have had DCAA auditors cite them for having deficient accounting systems because the contractor did not submit a “timely” proposal to establish billing rates. This was inappropriate because there is no specific requirement in the FAR for a contractor to submit. Read More.