PRESENTATION FOR SMALL BUSINESS JUNE 10, 2004 PRESENTER ANN INTRAVIA, DCAA FLA
2 AGENDA Opening/Introductions DCAA Organizational Overview FAR Cost Principles Accounting System –Elements of an Adequate System –DCAA Review Labor Charging –Elements of an Adequate System –DCAA Review –Penalties for Labor Mischarging Wrap up/Questions??
3 Established in 1965 Separate Agency of the Department of Defense Reports to DoD Controller Provides Services to All DoD Components Provides All Necessary Contract Audits for DoD DEFENSE CONTRACT AUDIT AGENCY
4 Advisory Services To Non-DoD customers Agency Staffing Of Approximately 4,000 Professional Auditors Comprise 83% of Staff CPAs Comprise 37% of The Auditors DEFENSE CONTRACT AUDIT AGENCY
5 Where can you find out more about us?? Who will audit at your location? DEFENSE CONTRACT AUDIT AGENCY
10 http://deskbook.dau.mil/jsp/default.jsp FARSite FAR Chapter 30 Cost Accounting Standards Administration FARSite FAR Chapter 31 Contract Cost Principles and Procedures FARSite FAR Chapter 32 Contract Financing
11 FAR Part 31 Contract Cost Principles and Procedures FAR Part 31.2 Contracts with Commercial Organizations Main Basis for Todays Presentation FAR 31.001 Definitions Provides Background for Key Terms Examples: Cost Objective, Indirect Cost Pools, G&A
31.201 -- General. 31.201-1 -- Composition of Total Cost. 31.201-2 -- Determining Allowability. 31.201-3 -- Determining Reasonableness. 31.201-4 -- Determining Allocability. 31.201-6 -- Accounting for Unallowable Costs. FAR Subpart 31.2 Contracts-Commercial Organizations
13 Composition of Total Cost FAR _______ deals with composition of total cost. 31.201-1 The total cost of a contract is the sum of the direct and indirect costs allocable to the contract, incurred or to be incurred, less any allocable credits, plus any allocable cost of money pursuant to 31.205-10.
14 Determining Allowability Allowability Criteria: G__________________ R__________________ L__________________ A__________________ C__________________ FAR _______ deals with allowability. 31.201-2 AAP easonable imits/ terms in contract llocable AS (if applicable)
15 Determining Allowability Continued Contractors Are Responsible For: Appropriate Accounting Maintaining Adequate Records/Documentation Demonstrating Allowability/Allocability of Costs
16 Determining Reasonableness Reasonableness Criteria: 1. Not Excessive_ 2. Prudent Businessperson 3. Competitive Business 4. Burden of Proof On Contractor if challenged 5. Contractor Policy FAR _______ deals with reasonableness. 31.201-3
17 Determining Allocability FAR 31.201-4 deals with Allocability If a cost is incurred specifically for the benefit of a contract – allocable to that contract (Direct Cost) Benefits more than one contract (Indirect Cost) Benefits the business as a whole (G&A)
18 Determining Allocability Continued Allocate a cost means? How should a cost be charged if it is incurred specifically for a contract? To Distribute, Assign, Charge, Pro-rate, etc. Direct to Contract
19 Determining Allocability How should a cost be charged if it is incurred for more than one contract, but not for all contracts? Indirect or Overhead How should a cost be charged if the cost is necessary to the business as a whole, but does not benefit any specific contract? G&A
20 Unallowable Costs FAR 31.201-6 deals with accounting for unallowable costs. 1.The practices for accounting for and presentation of unallowable costs will be those described in: CAS 405 2.Unallowable costs include: Mutually agreed to costs Directly associated costs Contracting officer unilateral decision
21 Expressly Unallowable Costs … a particular item or type of cost which, under the express provisions of an applicable law, regulation or contract, is specifically named and stated to be unallowable. FAR 31.001
22 DIRECT COST FAR 31.202 A Direct Cost Is Any Cost That Can Be Identified Specifically With A Particular Final Cost Objective.
23 INDIRECT COST FAR 31.203 An Indirect Cost Is Any Cost Not Directly Identified with A Single Final Cost Objective, But Identified with Two or More Final Cost Objectives...
24 FINAL COST OBJECTIVE FAR 31.001 A Cost Objective That Has Allocated to it Both Direct & Indirect costs... Is One of The Final Accumulation Points
25 Cost Objective FAR 31.001 A function, organizational subdivision, or other work unit that cost data are accumulated for Can be Final Contract Or Intermediate Indirect Cost Pool
26 FAR Sections Key FAR sections associated with cost -- – Negotiation - FAR Part 15 – Contract Types – FAR Part 16 – Cost Principles - FAR Part 31 – Contract Financing - FAR Part 32 – Contract Management - FAR Part 42 – Contract Clauses - FAR Part 52 – Forms - FAR Part 53
27 FAR Part 31.205 Selected Costs Defines the cost Defines what is allowable Defines what is not allowable DO Read each definition very carefully Look out for changes (Use current FAR) http://farsite.hill.af.mil/
28 ADEQUATE ACCOUNTING SYSTEM Conforms With Generally Accepted Accounting Principles, (GAAP) Produces Equitable Results--Verified, Applicable to The Contemplated Contract (s), and Is Capable of Being Consistently Followed. GENERAL
29 Accounting System Review Adequacy of Documentation Suitability to Business Reasonable Data- Projection Practices Accumulating Costs GENERAL
30 Accounting System Review Proper Segregation: Direct Cost Indirect Cost Identification & Accumulation Direct costs by contract Consistent Allocation of Indirects Under G/L Control
31 Accounting System Review Timekeeping System-Identifies Labor by Intermediate or Final Cost Objectives Labor Distribution System- Charges Direct & Indirect Labor to Appropriate Objectives
32 Accounting System Review Interim Determination of Costs – at Least Monthly Exclusion of Unallowable Costs from Contracts Identification of Costs by Contract Line item If Required
33 LABOR CHARGING SYSTEM External Documentation Physical Evidence Indoctrinate Employees Wrong Correct Recording Time Charges Guard Against Fraud & Waste
34 Segregation of Responsibilities Procedures Maintenance of Controls Individual Employees INTERNAL CONTROLS
35 TIMECARD PREPARATION Recording Time on A Daily Basis Recording Time on The Timecard (Ink) Project Numbers, Contract Number, etc… Changes To The Timecard Recording All Hours-Whether Paid or Not Signing The Timecard (?)
36 RECOMMENDED TIMEKEEPING POLICY Supervisor Should Approve & Cosign Supervisor Is Prohibited to complete unless: Prolonged Period Travel Status Employee Returns Work Determines Proper Distribution Company Policy-Employees Responsibility
37 FLOOR CHECKS Employees Are Actually at Work Assigned Job Classification Time Is Charged to The Appropriate Job/Code Unannounced Checks
38 PENALTIES LABOR MISCHARGING The Manipulation of Charges to a Contract May Be Subject To Criminal Charges Under 18 United States Code (U.S.C.) 1001. The Following Can Be Liable for The Violation: Employees Who Fill & Sign T/C With False Information. Supervisors Who Approve…Knowingly Managers and Officers Who Know Those Facts… The Company- sufficiently high enough level There does not have to be a direct contractual relationship between the Government and the employee who submitted the false timecard for the employee to be liable
39 ADEQUATE ACCOUNTING SYSTEM Accounting System Is Unacceptable Auditor-Contractor Auditor-Procurement Official Identify Recommendations for Correcting The Deficiencies.
40 ANN INTRAVIA 303-676-3480 firstname.lastname@example.org Presenters Information