Understanding the DCAA Audit Process and How to Prepare for Success

Similar documents
Adequate Accounting Systems for Cost-Type Work

Accounting and Auditing for Government Contractors

DCAA Audit and Compliance Strategies

Contractor Purchasing System Review, an Alternative Perspective

What Exactly is an Acceptable Accounting System?

DFARS Accounting System Reviews

STUDENT GUIDE. CON 170 Fundamentals of Cost & Price Analysis. Unit 5, Lesson 1 Cost Analysis Process, Players, and Business Systems

Best Practices in Dealing with the DCAA

Leading KPIs of Positive Financial Performance. Presented by: Hugh Shaw, Ventera Corporation Bill Riviere, Unanet

Standards, Best Practices, and Typical Problems for Companies New to the Federal Market

DLA Enterprise Supplier Conference and Exhibition

Contractor Estimating Systems: System Adequacy Standards and Key Compliance Issues

AUDIT PROCESS FOR PROFESSIONAL SERVICES CONSULTANTS AND CONTRACTS

Defective Pricing- Material Pricing Deficiencies. Next Slide

How to Prepare a DCAA Compliant Cost or Price Proposal. Bag Lunch Webinar November 17, 2016

Forward Pricing Proposal- Labor Categories. Next Slide

DEFENSE CONTRACT AUDIT AGENCY DEPARTMENT OF DEFENSE 8725 JOHN J. KINGMAN ROAD, SUITE 2135 FORT BELVOIR, VA

Contractor Business Systems Earned Value Management, Material Management and Accounting, and Property Management

Government Contract Controls: Going Beyond Business Systems

Make or Buy Decisions in a Proposal Audit. Next Slide

Eralis Job and DCAA Compliance. January 2017

2018 National Contract Management Association Boston Workshop

DFARS Business Systems Compliance. March 11, 2015

PSP A/ March 28, PSP-003(R)

Real-Time Labor Evaluations

Contractor Business System MMAS

Master Document Audit Program. Version 1.7, dated April 2016 B-01 Planning Considerations

Uncompensated Overtime. Next Slide

CPSR Expectations Before, During and After Review

Government contracting hot topics

2018 Research Financial Management Conference

Subcontractor and Vendor Kickbacks. Next Slide

Report to Congress on FY 2013 Activities at the Defense Contract Audit Agency

GC-153. Preparing for the CPSR A Practical Guide. Presented By: Susan Longo, Supervisor, Watkins Meegan Rich Wilkinson, Director, Watkins Meegan

Enhancing Audit Efficiency and Effectiveness. Dan Purvine A/E Clarity Consulting and Training, LLC

Another option that is becoming more and more prevalent is the use of independent CPAs to perform audits of a contractor s accounting system.

The Contracts Crunch. Jennifer Eastman Senior Product Marketing Specialist, Deltek. Melissa Amdahl Product Manager, Compusearch.

Contractor Purchasing Systems Reviews (CPSR) The Current CPSR Environment. Bryan Felber, Director of Purchasing & Compliance

SIGAR. USAID s Support for the American University of Afghanistan: Audit of Costs Incurred by the American University of Afghanistan M A R C H

POLICY AND PROCEDURES FOR THE DOD PILOT MENTOR-PROTEGE PROGRAM (Revised August 12, 2008)

Yes No. Yes. Yes. Firm Name. What form of business entity is your firm? When is your firm s fiscal year end (FYE)? (mm/dd/yyyy)

back

DFARS Appendix I. Appendix I Policy and Procedures for the DoD Pilot Mentor- Protégé Program TABLE OF CONTENTS. I-100 Purpose. I-101 Definitions.

Master Document Audit Program

Subcontract Management Regulatory Compliance - The Most Current Trends and Issues

Roger D. Duke Vice President -Contracts & Procurement. September 21, 2016

12/6/2016. Who Is Booth Management Consulting? Key Team Members. What is an Agreed-Upon Procedures Engagement?

Management and control systems

The New Purchasing System Review

Master Document Audit Program. Activity Code Compliance Audit CAS 420 Version 5.21, dated March 2018 B-1 Planning Considerations

DCAA Pre-Award Survey

A cost analysis is required for any negotiated (non competitive) contract procurement on behalf of any University program, if:

Managing Government Contracts in Deltek Vision By June R. Jewell, CPA & Melissa Garner Acuity Business Solutions

The New Era of Transparent Internal Audit: What You Should Know

Repetitive Bidding of Duplicative Material Costs. Next Slide

Improper Billing of Costs on Progress Payments 1

Materials Management and Accounting System Compliance Statement

Master Document Audit Program. Version 9.6, dated November 2017 B-1 Planning Considerations. Purpose and Scope

STUDENT GUIDE. CON 170 Fundamentals of Cost & Price Analysis. Unit 5, Lesson 4 Understanding Rate Applications

Times Are Changing: Contractor Purchasing System Review Expectations and Realities for 2017

SAM Supplement Representations, Certifications and Other Statements of Offerors for Government Related Orders

Understanding Contractor Purchasing System Reviews

July 30, (1) CHAPTER 5. Table of Contents

Master Document Audit Program. Version 4.28, dated March 2018 B-1 Planning Considerations

Recommended mitigating controls

Cost and Pricing Overview

DCMA INSTRUCTION 2501 CONTRACT MAINTENANCE

The Integrated Baseline Review (IBR)

Master Document Audit Program. Activity Code Compliance Audit CAS 407 Version 5.19, dated December 2017 B-1 Planning Considerations

OCEAN COUNTY COLLEGE PURCHASING MANUAL

Chapter 4. General Audit Requirements

(800) jamis.com

Government Contract Reporting Requirements:

Master Document Audit Program. Statement. Version 4.9, dated December 2017 B-1 Planning Considerations

PHASE 2 - Pre-Final Proposal Revision

Acquisition Planning for Limited Sources

DFAS Commercial Pay Overview Getting Paid by DFAS

Timekeeping for Government Contractors Mike Mardesich & Brad Tress March 28, 2017

Lfl CY) The. DoD Contractor. Risk Assessment Guide ~DTICO ,-CTE. 89 OC OBTt

Emissions Reductions Alberta

DCMA Manual Forward Pricing Rates

Master Document Master Document. Version 4.28, dated December 2017 B-1 Planning Considerations

Contract and Procurement Fraud

Preparing for a CPSR Audit

NONPROFIT CONTRACTOR FISCAL & COMPLIANCE REVIEW STANDARD MONITORING FORM

Contract Closeout. Rebecca Beck Director of Finance - DFAS Columbus

THOUGHT LEADERSHIP SERIES CPSR 360: 2-PART SERIES.

A Contractor s Guide: Is the Alliant 2 RFP for You?

DCAA Finds New Ways to Reduce its Audit Backlog. Written by Nick Sanders

GROUND RULES AND PRICING INSTRUCTIONS:

B-1 Preliminary Steps WP Reference

Keeping Up With the FAR

Section M: Evaluation Factors for Award HQ R LRDR Section M: Evaluation Factors for Award For HQ R-0002

Audit Preparation Best Practices

Price to Perform: Winning the Battle of Business in an Austere Environment

PSP A/ November 27, PSP-006(R)

Audit and Timekeeping Requirements

Background. Page 1 of 16

What to Consider When Facing a Construction Cost Audit

TxDOT Internal Audit Travel Division Operations Audit (1405-1) Department-wide Report

Transcription:

Understanding the DCAA Audit Process and How to Prepare for Success Breakout Session #: C11 Presented by: Beverly Arviso, CPA, Fellow, CPCM, CFCM Date: July 22, 2013 Time: 4:00-5:15

DCAA s Mission Compliance Updates Types of Audits Agenda Preparing for the Audit and Best Practices Resources Available Questions 2

DCAA s Role Mission To perform all necessary contract audit services for the Department of Defense (DoD) Accounting and financial advisory services regarding contracts and subcontracts to all DoD components responsible for procurement and contract administration Ensure taxpayer dollars are spent on fair and reasonable contract prices Provide contract audit services for other federal agencies, e.g., NASA, FAA, DOT, DOE, etc. 3

Compliance Updates DCAA is not an advisory service Pass/Fail environment Proof of accounting system in operation Calculation of indirect rates on-the-spot Statement of Conditions and Recommendations (SOCAR) Expect delays 4

Types of Audits Pre-award Contract Audit Services Pre-Award Accounting System Survey, SF 1408 Financial Capability, SF 1407 Cost/Price Proposals Forward Pricing Labor and Indirect Rates 5

Types of Audits Post-award Contract Audit Services Post-Award Audit Incurred Cost Proposals TINA Compliance Cost Accounting Standards Claims 6

Types of Audits Contractor Business Systems Audits Accounting Estimating Electronic Data Processing (EDP) Billing Materials Management 7

Types of Audits Pre-Award Accounting System Survey FAR Part 16.301-3 a cost reimbursement contract may only be used when the contractor s accounting system is adequate for determining costs applicable to the contract; and Appropriate government surveillance during performance will provide reasonable assurance that efficient methods and effective cost controls are used Results are adequate or inadequate Contract type NOT size or revenue triggers an audit T&M Contract Trends for Prime and Subcontractors 8

Types of Audits Pre-Award Accounting System Survey Accumulation of Costs under General Ledger control Interim (at least monthly) determination of costs charged to a contract through routine postings to books of account Proper segregation of direct costs from indirect costs Exclusion from costs charged to government contracts of amounts which are not allowable in terms of FAR Part 31, Contract Cost Principles and Procedures, or other contract provisions A timekeeping system that identifies employees labor by intermediate or final cost objectives 9

Types of Audits Pre-Award Accounting System Survey A labor distribution system that charges direct and indirect labor to the appropriate cost objectives Identification and accumulation of direct costs by contract A logical and consistent method for the allocation of indirect costs to intermediate and final cost objectives Identification of costs by contract line item and by units (as if each unit or line item were a separate contract) if required by the proposed contract Payment of vendor within terms 10

Post-Award Types of Audits Directed at determining the adequacy of the accounting system for segregation and billing of costs as required by the contract Proper segregation of costs Direct costs by contract (subsidiary job cost ledger) Direct labor Timekeeping system, Labor distribution 11

Pre- vs. Post-Award Types of Audits Pre-award tests the accounting system is operable, though not necessarily in use, i.e., CAN the system do it, Post-award tests DOES the accounting system segregate and accumulate costs by direct and indirect costs on a job cost basis 12

Proposal Audit Types of Audits DCAA no longer perform field pricing audits on cost-type proposals less than $100M and fixed price proposal less than $10M effective 10/18/10 DCMA will be responsible for field pricing assistance below these dollar thresholds 13

Proposal Audit Types of Audits Chapter 3 of DCAA s Information for Contractor s Guide provides guidance on proposal requirements, DCAA audit evaluations, and examples Must show how indirect rates are computed AND applied Must show trends and budgetary data with explanations to support reasonableness 14

Proposal Audit Types of Audits Provisional Billing Rates Are approved solely for billing purposes per FAR 42.704, and are not the same as forward pricing rates Provide a method for interim reimbursement of indirect costs during contract performance May be the basis for forecasted rates in the present year, but it is not a substitute for future price analysis 15

Proposal Audit Types of Audits Provisional Billing Rates DCAA examines the estimating rationale for the development of the indirect rates with supporting documentation for the future periods of contract performance Failure to provide such documentation will result in the proposal being deemed inadequate and the proposal will be returned to the requestor 16

Proposal Audit Types of Audits Provisional Billing Rates If asked by the requestor to proceed with the audit, DCAA will consider the indirect costs unsupported, which could lead to an adverse opinion on the proposal Contract Pricing Proposal Adequacy Checklist www.dcaa.mil 17

Types of Audits Incurred Cost Proposal Allowable Cost and Payment Clause at FAR 52.216-7 Incurred cost proposals are due within 6 months after the contractor s fiscal year end A model incurred cost electronically (ICE) model can be found at www.dcaa.mil 18

Types of Audits Incurred Cost Proposal Instructions on how to complete the ICE can be found in the Information for Contractor s Guide Require a Certificate of Indirect Costs at FAR 52.703-2 (Schedule N of ICE) Incurred Cost Submission Adequacy Checklist www.dcaa.mil 19

Types of Audits Incurred Cost Proposal Incurred cost audits include an evaluation of direct and indirect costs to determine whether costs are Reasonable Allocable Allowable Penalties can be assessed at FAR 42.709 Part of the contract close-out process 20

Preparing for the Audit: Best Practices DON T PANIC Inquire as to the purpose of the visit, i.e., what type(s) of audit are they performing 21

Preparing for the Audit: Best Practices Request an entrance conference and a list of items you can prepare in advance of the visit 12/15/10 DCAA is required to provide a notification letter to the contractor during the planning phase of the audit on the nature and scope of the audit, either during or shortly after the entrance conference The notification letter is not supposed to replace the entrance conference 22

Preparing for the Audit: Best Practices Request or download and review the audit program at www.dcaa.mil Understand what the auditor is asking for and control responses Ask why the auditor is requesting the data if you are uncertain as to the purpose Maintain good records and documentation 23

Preparing for the Audit: Best Practices Request interim audit results to mitigate potential negative comments/results Get your house in order before the audit Accounting System Estimating System Budgeting and Forecasting Timekeeping Travel & Expense Purchasing Education and training of employees Analyze key accounts 24

Preparing for the Audit: Best Practices Request an exit conference Respond to draft reports quickly and obtain outside assistance if needed Respond accurately and quickly, but not so quickly as to jeopardize your preparation and audit success Request a copy of the final audit report for your records 25

Resources Federal Acquisition Regulations (FAR) Part 31, Cost Principles www.dcaa.mil Information for Contractor s Guide DCAA Office Locator Incurred Cost Electronically (ICE) Contract Audit Manual Adequacy Checklists Open Audit Guidance Standard Audit Programs 26

Questions??? Beverly Arviso, CPA, Fellow, CPCM, CFCM Arviso, Inc. 757-373-9536 beverly@arvisoinc.com 27