Materials Management and Accounting System Compliance Statement
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1 Compliance Statement Materials Management and Accounting System Compliance Statement Infor LN Materials Management and Accounting System Compliance Statement The Defense Federal Acquisition Regulation Supplement (DFARS) requires certain contractors to comply with ten Contractor Material Management Accounting System (MMAS) Standards as described in DFARS subpart as follows: Policy DoD policy is for all contractors to have an MMAS that- Reasonably forecasts material requirements; Ensures the cost of purchased and fabricated material charged or allocated to a contract are based on valid time-phased requirements; Maintains a consistent, equitable, and unbiased logic for costing of material transactions; and Conforms to the standards at (f) when the contractor has cost reimbursement or fixed-price contracts with progress or other financial provisions, except when all of the contracts and subcontracts are- 1) Awarded under the set-aside or section 8(a) procedures of FAR part 19; or 2) Greater than the small purchase threshold in FAR part 57 FR (1) Not all defense contractors are required to comply with the MMAS standards. Essentially, those prime contractors and subcontractors who routinely do more than $50 million in defense work annually are required to fully comply with the MMAS standards. Those who do between $10 million and $50 million are required to prepare the disclosure document. Should the contractors Administrative Contracting Officer (ACO) or Program Control Officer (PCO) suspect deficiencies in the contractors MMAS, a full demonstration audit may be imposed. The following language from DFARS Subpart describes this requirement.
2 MMAS disclosure, demonstration, and maintenance requirements A large Business contractor is subject to MMAS disclosure, demonstration, and maintenance if in the preceding fiscal year the contractor received DoD prime contracts or subcontracts (including modifications) totaling- $50 million or more; or $10 million or more (but less than $50 million); and The contracting officer determines it to be in the best interest of the Government (e.g., significant MMAS problems are believed to exist). (1) The MMAS standards like other regulations, describe how a company must construct and implement a management control system in order to become compliant. Infor LN is an information system tool, which supports the overall Materials Management and Accounting System. The use of Infor LN does not in itself make a contractor compliant, but the proper definition and use of the system is a key element in helping a contractor become compliant. Many large, experienced defense contractors who use Infor LN have successfully satisfied the MMAS standards. The purpose of this document is to describe how a contractor can use Infor LN and its supporting documentation to implement a compliant Materials Management and Accounting System. Paragraph No. 1 Have an adequate system description including policies, procedures, and operating instructions compliant with the Federal Acquisition Regulation (FAR) & Defense FAR Supplement. (2) With each installation of Infor LN the contractor has three key deliverables, which can be used to prepare procedures and operating instructions: A&D Reference Models; System documentation Education and training materials. The A&D reference model is a series of process instructions, which give the contractor Infor s interpretation of a generic set of business processes aimed at the defense contracting industry. These processes are a starting point for the contractor and can be used as-is or modified at their discretion. System documentation is provided with Infor LN which describes the standard, off-the- shelf software solution, both from a functional and technical perspective. Should the contractor change or extend the off-the-shelf system it is incumbent upon them to modify or supplement the standard documentation to provide a full description of the software solution. 2 Infor MMAS Compliance Statement
3 Each contractor is given the opportunity to attend classes, which are intended to teach its employees how to use the system. The materials used to teach the classes are also a source of information, which can be used to prepare the procedures and operation instructions needed to support compliance with standard #1. Finally, each contractor has its own company specific policies, which govern all processes and operating instructions. These policies coupled with the processes and operating instructions gleaned from materials provided by Infor LN documentation and other materials will form the contractor s complete materials management and accounting system description. Paragraph No. 2 Ensure that costs of purchased and fabricated material charged or allocated to a contract are based on valid time-phased requirements as impacted by minimum/economic order quantity restrictions- A 98 percent bill of material accuracy and a 95 percent master production schedule accuracy are desirable as a goal in order to assure that requirements are both valid and appropriately time-phased. If systems have accuracy levels below those above, the contractor must demonstrate that- (A) (B) There is no material harm to the government due to lower accuracy levels; and The cost to meet the accuracy goals is excessive in relation to the impact on the government. (2) Infor LN provides several user configurable methods of material requirements planning, all of which ensures that the contractor is able to charge or allocate purchased or fabricated materials to a contract on a time phased basis. Order policies, defined uniquely for each part, determine the quantity of the part supplied on each replenishment order and can include minimum or economic order quantity restrictions. In the make- and engineer-to-order manufacturing environments, high volumes of engineering changes must be formally managed and incorporated into the material plan. These changes are initially incorporated into the as-designed bill of material then the asplanned bill and ultimately reflected in the as-built bill of material. Infor LN provides a series of reports where the contractor can compare the various versions of the bills of material to look for discrepancies to determine bill of material accuracy. With regard to master production schedule (MPS) accuracy each contractor creates a policy which describes how they convert contract deliverables into the delivery dates contained in the MPS. Compliance is measured by comparing the delivery dates in the MPS to those in the contracts and determining if they fall within the policy guidelines. Infor LN provides displays and reports to view master schedule delivery dates for this comparison. Infor MMAS Compliance Statement 3
4 Paragraph No. 3 Provide a mechanism to identify, report, and resolve system control weaknesses and manual overrides. Systems should identify operational exceptions such as excess/residual inventory as soon as known. (2) Infor LN is designed to be an exception driven system. These exceptions can occur inside or outside the bounds of contract specific information. Users of the system through normal business processes are trained on how to react to exception conditions and what transactions to process to correct said situations. In some cases, manual overrides to prescribed paths are permitted. Regardless, each transaction or update to data retained in Infor LN is recorded in the transaction audit trail. Within Infor LN, some materials are ordered to satisfy demands specific to a group of contracts or a single contract while other materials are ordered for common pool or noncontract demands. At any time during the life cycle of the contract, reports can be produced which will highlight inventory in excess of contract demands. Paragraph No. 4 Provide audit trails and maintain records (manual and those in machine-readable form) necessary to evaluate system logic and to verify through transaction testing that the system is operating as desired. (2) Infor LN provides a complete audit trail of every transaction that creates or updates data in or deletes data from the database. This transaction audit trail can be viewed either via on-line inquiries or hard copy reports. The audit trail is retained for a time period specified by each contractor. Once the data is purged from active data tables, it can be archived in any contractor specified machine readable media. Paragraph No. 5 Establish and maintain adequate levels of record accuracy, and include reconciliation of recorded inventory quantities to physical inventory by part number on a periodic basis. A 95 percent accuracy level is desirable. If systems have an accuracy level below 95 percent, the contractor must demonstrate that- There is no material harm to the government due to lower accuracy level; and The cost to meet the accuracy goal is excessive in relation to the impact on the government. (2) Infor LN is designed to rigorously control the movement of material into and out of perpetual inventory. As such, each planned inventory transaction requires a valid purchase, production, or warehouse order. Also, each unplanned transaction requires a reason code to support its receipt or disbursement. Periodically the contractor is required to test the account record accuracy of each and every part. This periodic test is referred to as cycle counting. Under cycle counting, each item is assigned a code (ABC code) which identifies its value category and how often its perpetual balance should be tested. For example, a category A item is the most valuable group of parts and each should be tested every six months. 4 Infor MMAS Compliance Statement
5 Also each cycle count category is assigned an accuracy tolerance. Category A items typically allow no tolerance. A cycle count test must reveal exact account record accuracy or the item fails the cycle count. Lower value items may allow some tolerance in account record accuracy. For example, category B may allow a 2% error and category C may allow a 5% error. MMAS standard number 5 recommends that the contractor should be within the account record accuracy tolerance on 95% of all cycle counts. It permits each contractor to set the value range, count frequency and allowable tolerances for account record accuracy for each ABC code. Infor LN supports cycle counting. ABC codes are assigned to each inventory part. Reports are printed to identify which parts should be counted during the next cycle count test. Special inventory transactions are entered which indicate the counted amount found and adjust inventory where appropriate. Paragraph No. 6 Provide detailed description(s) of circumstances which will result in manual or system generated transfers of parts. (2) Within Infor LN, material transfers can occur using one or all of the following three methods: System generated permanent transfers; Manually generated permanent transfers; or Borrow/loan Where the contractor has residual inventory or inventory received in advance of need and that inventory is linked to one cost account of a contract, Infor LN may generate a permanent transfer of said material. This transfer can occur: Between cost accounts of the same contract; or Between cost accounts of different contracts provided that both contracts are in the same contract group; or Between cost accounts of different contracts provided that both contracts belong to the same customer In any case, the contractor, through a contract or cost account level policy nomination will elect to allow or not allow Infor LN to generate these borrow/loan. Further, the contractor, when electing to permit the system to generate material transfers will allow the system to process transfers with or without user confirmation. Any authorized user of Infor LN may manually initiate a permanent material transfer. The same contract or cost account level policy, which governs system generated permanent transfers, applies to manual permanent transfers. If, at the cost account or contract level the contractor elects not to permit system-generated transfers, the user would be blocked from generating a manual transfer to or from that cost account. An authorized user of Infor LN can also initiate a borrow/loan. This borrow/loan is facilitated by issuing a part allocated to one cost account to a production order allocated to some other cost account. A borrow/loan implies that the receiving cost account is borrowing the material and intends to return it once its supply is received. Borrow/loan can become permanent. Each contractor who implements Infor LN will set a time parameter in their system. Infor MMAS Compliance Statement 5
6 After that time period specified number of days has passed, the borrow/loan become permanent transfers. With regard to borrow/loans and permanent transfers, the before mentioned circumstances must be incorporated in the contractors Cost Accounting Standard (CAS) disclosure statement. Paragraph No. 7 Maintain a consistent, equitable, and unbiased logic for costing of material transactions- The contractor shall maintain and disclose a written policy describing the transfer methodologies. The costing methodology may be standard or actual cost or any of the costing methods in FAR (b). Consistency shall be maintained across all contract and customer types, and from accounting period to accounting period for initial charging and transfer charging. The system should transfer parts and associated cost within the same billing period. In the few circumstances where it may not be appropriate, the Contractor may use a loan/pay back technique only if approved by the administrative contracting officer. When the technique is used, the Contractor shall have controls to ensure- (A) (B) (C) Parts are paid back expeditiously; Procedures and controls are in place to correct any overbilling that might occur; Monthly, at a minimum, identification of the borrowing contract and the date the part was borrowed; and (D) The cost of the replacement part is charged to the borrowing contract. (2) Infor LN employs the Moving Average Unit Costing (MAUC) methodology. Where the part is subject to contract (cost account) ownership, a unique MAUC can exist for each unique occurrence of contract ownership of that part. This method of moving average actual costing is fully compliant within FAR (b). All permanent material transfers and borrow/loans (see paragraph #6 for an explanation of permanent and temporary transfers) result in a transfer of cost between the cost accounts. Where the borrow/loan is permanent the transfer-from contract MAUC value of the part is credited from the transfer-from cost account and the same amount is debited to the transfer-to cost account. Where the borrow/loan is temporary the transfer-from contract MAUC value of the part is credited from the transfer-from cost account and the same amount is debited to the transfer-to cost account. When the temporary transfer is reversed, the original transferfrom value of the part is transferred from transfer-to cost account back to the transfer-from cost account. All permanent material transfers and borrow/loans are recorded in the Infor LN database. The contractor can print a report from the database that would identify all borrow/loans which have not been accompanied by a reversal (payback) transaction. As stated in standard #6, if the borrow transaction is not accompanied by a payback within a contractor specified time period, the borrow transaction becomes a permanent transfer. Finally, when materials from company inventory are issued to a contract owned production order, the MAUC value of the part is credited from the company inventory ledger and debited to the cost account ledger. 6 Infor MMAS Compliance Statement
7 Paragraph No. 8 Where allocations from common inventory are used, have controls (in addition to those paragraphs (b)(2) and (7) above to ensure that- Reallocations and any credit due are processed no less frequently than the routine billing cycle; Inventories retained for requirements which are not under contract are not allocated to contracts; and Algorithms are maintained based on valid and current data. (2) Infor LN provides the capability for the contractor to have soft allocated or company owned inventory. To facilitate material planning, soft allocated inventories are allocated to cost accounts on a time-phased basis of need. The time-phased material planning process ensures that an adequate supply of said inventory would exist to meet the demands of those contracts. In Infor LN, inventory purchased or manufactured to a specific contract group (hard allocated) is eligible for progress billings when it is acquired or as it is being produced. Soft allocated inventory is eligible for monthly progress billing either when it is consumed, or when it is purchased. Each contractor makes the decision of how to treat soft allocated inventory when creating progress-billing invoices. As with other MMAS paragraphs, it is incumbent upon the contractor to process those billings in a consistent manner. Paragraph No. 9 Not withstanding FAR (f)(1)(ii) have adequate controls to ensure that physically commingled inventories that may include materials charged or allocated to fixed-price, cost-reimbursement, and commercial contracts do not compromise requirements of any of the standards in paragraphs (f)(1) through (8) of this clause. Government furnished material shall not [be] Physically commingled with other materials; or Used on commercial work.(2) Infor LN provides for several forms of commingling. Those are categorized into inventory and supply order commingling. Inventory commingling occurs when inventory, hard allocated to two or more cost accounts is physically stored in the same location. Infor LN permits this, however it is the responsibility of the contractor to distinguish ownership. Physically marking the material is one way of distinguishing ownership. Where the contractor acquires government furnished materials, those must be received with a specified cost account or contract charge number (CCN). It is the responsibility of the contractor to physically separate those parts from parts belonging to other contracts. Allocating the part to a CCN means that only that specific CCN or another CCN in the same contract group can consume the material. Contractors must be sure that government and commercial contracts are not included in the same contract group. Following that practice will enable the contractor to be in compliance with this paragraph of the MMAS. Infor MMAS Compliance Statement 7
8 Infor LN also supports several different forms of supply order commingling. When initially defining the Contract Work Breakdown Structure (CWBS) the contractor combines contracts into common groups. Infor LN will commingle production and procurement supply orders within contract groups. When this is done, the labor, material and overhead costs incurred on a supply order are shared across all contracts covered by the supply order on a fair and equitable basis. Infor LN also commingles supply orders when they are not hard allocated to any cost account. When this is done the labor, material and overhead costs are charged to the cost account when the part is consumed. The amount of cost charged to the cost account is a proportional amount of the original supply order. Paragraph No. 10 Be subjected to periodic internal audits to ensure compliance with established policies and procedures. (2) Standard #10 suggests that each contractor implement a self-governance policy. The demonstration document described in standard #1 coupled with audit reports specified in standard #4 should lead the contractor to develop an internal audit procedure to ensure compliance. Standard #10 also states that the contractor s materials management and accounting system will be subject to period audits by the Department of Defense Contract Audit Agency. References (1) Defense Federal Acquisition Regulation Supplement Subpart Contractor Material Management and Accounting System (2) Defense Federal Acquisition Regulation Supplement Subpart Text of Provisions and Clauses. 641 Avenue of the Americas New York, NY infor.com About Infor Infor is fundamentally changing the way information is published and consumed in the enterprise, helping 70,000 customers in 200 plus countries improve operations, drive growth, and quickly adapt to changes in business demands. To learn more about Infor, please visit Disclaimer This document reflects the direction Infor may take with regard to the specific product(s) described in this document, all of which is subject to change by Infor in its sole discretion, with or without notice to you. This document is not a commitment to you in any way and you should not rely on this document or any of its content in making any decision. Infor is not committing to develop or deliver any specified enhancement, upgrade, product or functionality, even if such is described in this document. Copyright 2014 Infor. All rights reserved. The word and design marks set forth herein are trademarks and/or registered trademarks of Infor and/or related affiliates and subsidiaries. All other trademarks listed herein are the property of their respective owners. This document is provided for informational purposes only and does not constitute a commitment to you in any way. The information, products and services described herein are subject to change at any time without notice. INFDTP en-US
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