PROCAS has Achieved a SOC 2 Type 2 Report author avatar

PROCAS invests in establishing and maintaining currently recommended security practices to make sure your data stays safe. Today, we’re excited to share a milestone achievement in our continuous improvement process! PROCAS has achieved the AICPA Service Organization Controls (SOC) 2 Type 2 report with an unqualified audit opinion.

In addition to our SOC 2 Type 2 report, we also have a SOC 3 Type 2 report available for download from our website. The SOC 3 report provides a summary of the SOC 2 Type 2 report.

Current clients can access a copy of the PROCAS SOC 2 Type 2 report after signing a nondisclosure agreement. For more information related to this report, please reach out to your PROCAS consultant.

What is SOC Compliance?

Businesses are increasing the outsourcing of basic functions such as data storage and access to applications to Software as a Service (SaaS) providers and other service organizations. The importance of having a standard assessment and reporting process for internal controls has become increasingly important.

For many, SOC 2 is considered the benchmark for security compliance for Software as a Service (SaaS) companies in the US. SOC 2 requires companies to establish and follow strict information security policies and procedures, encompassing the secure protection of customer data.

Our Focus on Your Security

Our 2019 SOC reports provide assurance that PROCAS is complying with the standards of the AICPA guidelines. To achieve the unqualified opinions of our SOC reports, PROCAS has implemented and maintains policies, procedures and processes to comply with these security controls to protect the important data that our clients have entrusted to us. The audit demonstrates that the controls are defined adequately, and they are operating effectively.

These controls cover the topics and operational practices like logical and physical access management, data storage and recovery, encryption, change management, vendor management, incident management, detection and response, security and privacy awareness training, organizational management, and personnel security.

We’re proud of this milestone, but we recognize that security is an ongoing effort. Our information security program is constantly focused on providing the highest level of delivery for PROCAS Accounting Solutions Software.

Utilizing PROCAS to Help Streamline your 1099 Process author avatar

PROCAS has built in procedures to help clients automate their 1099 & 1096 process.

Every January, accounting staff & business owners walk into the same old confusing process as they wake up from their holiday slumbers…

*Grabs coffee and begins annual research*

“What is a 1099 again?”

“How do I determine who should receive a 1099?”

“What are the different types of 1099s that need to be reported?”

Ok, I think I remember this process,

“Now where do I print these forms out?”

“THAT’s right, I can’t print them online. Need to swing by Staples to pick some up.”

“Wait, I only bought a box of 50 forms, why are there a billion papers in here?”

“Oh yeah, I have to complete FIVE forms for each contractor/vendor…”

“Ok… (takes deep breath), now who do I send all these forms to and when are they due?”

And most importantly…

“Can I get in trouble if I mess this up?”

Frustrated accountant attempting 1099 reporting

Fear not! We will break down this process in detail below and explain how PROCAS can help you simplify the reporting requirements. So, keep the Tylenol up in the cupboard, we aren’t going to need it!

Editor’s Note – This post takes into account the changes the IRS has made to reporting 1099MISC Nonemployee Compensation for 2019 fiscal year, which is covered under the Penalties section.

 

What is a 1099 and why is it important?

1099-MISC forms are used to track income of organizations who are not established as corporations (or LLCs taxed as C or S corps). For most companies, 1099-MISC forms will be used to provide an accurate representation of how much non-employees, vendors, sub-contractors, and consultants have been paid throughout the prior year. Because these people and businesses do not receive W-2’s for work performed, 1099s are what the IRS depends on to know how much they owe in taxes for the calendar year.

 

Who receives a 1099?

Determining who receives a 1099 can be a tricky process. To help, we’ve broken the decision-making tree into the following points:

1) Is the person in question an employee of your organization?

  1. YES – No need, they should have received a W-2.
  2. NO – Independent contractors and consultants will most likely need a 1099, proceed to Question 3.
  3. NOT SURE Consider the following questions:
    1. Do you provide benefits to this individual?
    2. Do you provide equipment, office space, or materials for the individual to complete their job?
    3. Do you reimburse business expenses incurred by the individual?
    4. Are you the sole client or primary client of the individual? And do you completely control their weekly workflow?
  4. NOT SURE – If you answered NO to all the above sub-questions, proceed to Question 3.
  5. NOT SURE – If you answered YES to any of the above sub-questions, you may be considered that individual’s employer in a court of law and may need to start providing W-2 information. Consider seeking a labor lawyer’s advice.

2) Is the vendor you purchased services from a corporation?

  1. YES – No need to send a 1099.
  2. NO – Sole Proprietorships and Partnerships will most likely need a 1099, proceed to Question 3.
  3. NOT SURE – LLC’s are the most confusing of the bunch. To determine how the company is taxed, please send a W-9 to that vendor’s accounting staff. Once returned,
    1. If taxed as S Corp or C Corp, no need to send 1099.
    2. If taxed as sole proprietorship or partnership, proceed to Question 3.

3) How much money was paid to individual or vendor?

  1. Anything less than $600 total for the calendar year does not require a 1099.
  2. Any payments totaling $600 or more will require a 1099.
  3. Common Exceptions:
    1. $10 or more in royalties will require a 1099
    2. In general, payments made to law firms will require a 1099
    3. If paid via credit card, a 1099 is not required (even in excess of $600). The credit card company will take care of the reporting for you.
    4. Business expense reimbursements for employees will not require a 1099.

 

Forms & Deadlines

1099-MISC forms contain 5 parts to be filled out and sent to their appropriate recipient(s):

  1. Copy A - For Internal Revenue Service Center
  2. Copy B - For Recipient
  3. Copy C - For Payer or State Copy
  4. Copy 2 - To be Filed with Recipient's State Income Tax Return, When Required
  5. 1096 - Completed with 1099

While these forms can be generated around the same time, they typically are sent separately at different deadlines:

  1. January 31st
    1. If reporting Box 7 - Non-employee compensation, mail Copy A forms and 1096 to the IRS
      1. DO NOT mix in other 1099-MISC forms for Copy A if other boxes are selected
      2. Can also e-file if preferred
    2. Send Copy B to recipients if payments are NOT reported in Boxes 8 or 14
  2. February 18
    1. Send Copy B to recipients if payments reported in Boxes 8 or 14
  3. February 28
    1. Mail remaining Copy A forms and 1096 to the IRS
      1. Make sure no payments we in fact recorded in Box 7
  4. April 1
    1. Deadline to e-file to the IRS for Copy A forms and 1096
      1. Again, make sure no payments we in fact recorded in Box 7

 

PENALTIES

You may have noticed in the above deadlines that I reiterated multiple times to not include Box 7 payments with other payments. This is a new change the IRS has made for 2019 and subsequent years as there is a newfound focus on capturing all non-employee compensation. There are two large penalties you want to avoid in regards to this change:

 

1) Be sure to file BOX 7 - Non-Employee Compensation payments by the Jan 31 deadline!

If you do not mail these 1099 MISC forms by Jan 31, you can almost be guaranteed to be hit with late penalties. Depending on the severity (in both # of forms and tardiness), you can expect the penalties to be of substantial monetary value.

 

2) DO NOT file all Copy A forms together by the Jan 31 deadline.

You may think it would be a good practice to play it safe and file all your 1099 MISC forms by the Jan 31 deadline. However, the IRS specifically wants only Box 7 - Non-employee compensation payments to be filed together and before the rest of your submissions. IF you file them together, you can be hit with monetary penalties for having the two batches mixed.

 

For more information related to 1099s and all the associated forms, deadlines, and penalties, please click here.

 

Utilizing PROCAS to complete your 1099s & 1096s

PROCAS currently supports three types of 1099s: 1099-MISC (all payments), 1099-INT, and 1099-DIV, as well as 1096s. Each form can be generated out of the system by following these 3 steps:

  1. Determining which vendors/subcontractors require 1099s
  2. Establishing 1099 form type and box by vendor/subcontractor
  3. Generating 1099/1096 forms from PROCAS

 

1) Determining which vendors/subcontractors require 1099s

In order to find out who you paid money to in the prior year, please go to the following:

Accounting --> General Ledger --> General Ledger

Here, use the parameters next to the orange arrows below to generate a report for cash payments made in the following year.

Once you’ve printed your report, please follow the above section “Who receives a 1099” to whittle down you’re list of possible vendors to those who should receive a form.

 

2) Establishing 1099 Form Type & Box by Vendor or Subcontractor

Now that you have your list of vendors and subcontractors, time to label their records as to which type of form they should receive. Please navigate to:

Setup --> Purchasing --> Vendors

And select the “Find” button or “F8” function key to begin searching for those vendors/subs. Once on the record of an applicable vendor/sub, select the “Payment Info” tab of the record to locate a box called “1099 Type & Box.”

If you click in this box, you can then select the “Lookup” button or “F9” function key to see the list of possible 1099 types.

From the above list, make the appropriate selection for each vendor/sub in your list.

 

3) Generating 1099 & 1096 forms from PROCAS

Once all 1099 types and boxes have been determined, navigate to the final menu:

Accounting --> Accounts Payable --> Forms 1099/1096

This screen will be broken into two separate parts to get the appropriate items needed to print your forms:

The header section of Forms 1099/1096 has specific parameters to determine which items will generate in the detail grid:

  • Reporting Year Date - Use the prior calendar year for as is required for reporting 1099/1096 amounts.
  • Cash Account - Use the cash account recorded in the GL for payments made to each vendor/sub (if left blank, all accounts will generate).
  • Batch Liability Account - If you make payments in batch from your bank account, enter the liability account used here.
  • 1099 Type - Choose applicable 1099-MISC, 1099-DIV, or 1099-INT.
  • Minimum Amount - This will limit the minimum amount recorded in each transaction. Use applicable minimums if needed.
  • Search - Will populate below detail

In this detailed grid, select the payments made to each vendor if you are looking to include them on your forms. When all appropriate rows have been selected, print the proper 1099 or 1096 report from the below report bar.

  • Each column has the ability to sort items if you click the name of each column
  • Each column also has the ability to filter items if you select the filter icon to the right of each column header
    • Editor's Tip - Filtering on "1099 Type" is very useful if you want to separate out your Box 7 Non-employee compensation forms from the rest for the IRS 01/31 submission!!

 

Extra Help & Form Alignment

For additional help completing your 1099/1096 forms using PROCAS:

  • In the upper right hand corner there is a "?" symbol, which will provide in-system help for detailed instructions on any of the menus!
  • Feel free to reach out to our Support Team at support@procas.com
    • We can help align your report forms to your printer specs as well as help explain the process.

 

 

PROCAS Sponsored Event - National 8(a) Association Small Business Conference 2020 author avatar

We will be a sponsor of National 8(a) Association’s Small Business Conference from Feb. 11th – 13th in New Orleans, LA.

For any clients that are 8a certified or are looking to obtain an 8a certification, this is a great opportunity to network with industry leaders, including hundreds of federal agencies, large business primes, and corporate companies. The primary focus of the event includes updates to government contracting, specifically to small business (SBA) and 8a type work, as well as match making opportunities with these industry leading organizations.

Types of small businesses invited to attend: Minority, Aspiring, Current 8(a), Graduate 8(a), HUBZone, SDVOB, VOSB, SDB, WOSB, DBE, and Teaming Partnerships.

Statistics: Below is a full graphic of who is anticipated to attend!

For those interested, click here to check out the full agenda of the event.

Setup

We will have a vendor table setup in the Preservation Hall of the 2nd Floor of the New Orleans Marriott (Canal St.). For those walking the exhibit hall, look out for our name as you try to join the WiFi network!

As you attend presentations, educational sessions, matchmaking, and networking events, please use the below hashtag when posting to social networks.

#N8ASmallBiz20

PROCAS Software Update & Happy Holidays! author avatar

We are excited to bring you some long-awaited news of the PROCAS Accounting upgrade! Our entire team has been very busy this year working on the development of the upgraded accounting software. We are grateful for the many clients that agreed to jump on board early and help us improve the usability and functionality of the software before a general release.

The upgraded version, while closely based on the existing version that you are used to, is accessed directly from a web browser. Since it is web-based, the user interface is quite different than what you are currently familiar with. We also have the flexibility to improve how things work and to continuously add new features and functions.

 

Upgrade Logistics

We are slowly transitioning our clients to make sure everyone gets one-on-one time with a consultant to help get acclimated to the new user interface and many of the new features. Part of the transition includes an import of all your existing data into the new system. This means that you will maintain all the general ledger transaction, invoice history, and setup details that you have now. This also means that you can transition during any time of the year, regardless of where you are in the accounting cycle.

By the way, there is no added cost to upgrade—not even the time spent with your consultant! We want all our clients to enjoy the new software without an unplanned hit to their bottom line.

Our transition schedule is full through the end of this year, and we are looking to start adding clients to the list for 2020. If you are interested in a demo to learn about new features, or how to get on the transition wait list for 2020, send us an email at feedback@procas.com.

 

From all of us at PROCAS, we would like to wish you a wonderful holiday season!

We look forward to hearing from you and working with you soon!

- The PROCAS Team

 

PROCAS Sponsored Event – DHG’s 24th Annual Government Contracting Conference author avatar

We will be a sponsor of Dixon Hughes Goodman’s 24th Annual Government Contracting Conference on October 24th in Hampton Roads, VA.

For any clients interested in growing their GovCon knowledge, this 1-day event is perfect for you! The conference will cover a variety of topics, ranging from cybersecurity to DCAA updates, incurred cost submissions, and much more.

For those interested, click here to check out the full agenda of the event.

We will have a vendor table set up close to the sign in table of the Chesapeake Conference Center. Feel free to stop by when you have some spare time!

Change in Government Fiscal Year author avatar

Government Fiscal Year

For clients that operate on a government fiscal year basis, please remember to address the following items in accordance with the year change on October 1st!

Required

  • Establish new task numbers to increment the option year on cost type contracts that continue beyond the end of the current fiscal year
  • Complete the billing setup for the new task numbers
  • Establish new work authorizations
  • Establish new expense authorizations

May Be Required*

  • Enter the new accounting year
  • Enter the accounting periods for the new accounting year
  • Establish timesheet periods for October 2019 – September 2020
  • Establish new task numbers for tracking PTO by fiscal year

*If you operate on a calendar basis but have contracts that operate on a government fiscal year basis, not all of the above items will apply to your company. If that is the case, we recommend focusing on the first 4 items.

 

Additional Help

If you need help with any of the listed items, please contact your consultant. Depending on which version of the software you are on, some of the items may not be relevant to your company.

Our consulting team can be reached at consulting@procas.com.

PROCAS Sponsored Event – 2019 MACPA Government Contractors Conference author avatar

We will be a sponsor of the 2019 MACPA Government Contractors Conference on September 24th in Hyattsville, MD.

For any clients or third parties interested in growing their GovCon knowledge, this 1-day event is perfect for you!

According to the Maryland Association of Certified Public Accountants, “The Government Contractors Conference is designed to help CPAs understand issues related to their government contractor clients and manage their engagements. This unique event addresses current issues affecting government contracts, enabling CPAs in industry to add strategic value to their organizations.”

For those interested, click here to check out the full agenda of the event.

We will have a vendor table set up close to the sign in table of the College Park Marriott Hotel & Conference Center. Feel free to stop by when you have some spare time!

Five Potential Changes for HUBZone Certified Contractors – SBA Recap author avatar

HUBZone Map

As announced two weeks ago, we had the opportunity to sponsor the National HUBZone 2019 Conference in Chantilly, VA. There were many great presentations and industry updates, all of which could have a direct impact on HUBZone business in the near future.

Of these presentations, the U.S. Small Business Administration’s agency and regulatory update had potentially the greatest impact on HUBZone contractors. Led by Associate General Counsel, John Klein, the SBA’s team commented on many major changes to legislation that they feel will be made into law by 12/31/21.

Below are our 5 main takeaways from this update, which all focus on proposed changes to HUBZone requirements. It’s important to note that this information is all speculative at this point in time, but these were heavily emphasized throughout the 90-minute presentation:

 

1) HUBZone status is no longer required at all phases of attaining contract.

Prior requirement – Contractor must be HUBZone certified from the time of offer through time of award.

Proposed change – Contractor only has to be HUBZone certified at either the time of offer or time of award. No longer required for both steps.

Interpretation – Contractors in danger of losing HUBZone certification can still bid on work before losing status, which helps continue cash flow while management readdresses company status. New companies can also bid on work while attempting to become HUBZone certified rather than having to wait for the process to complete. This change should smooth out the work opportunities of companies on both ends of the spectrum. 

 

2) HUBZone status to drop the minimum requirement from 35% to 20% HUBZone designated employees.

Prior requirement – Contractor must have at least 35% of its employees live in a HUBZone designated area.

Proposed change – Contractor only has to have at least 20% of its employees live in a HUBZone designated area.

Interpretation – The 35% rule is being loosened for HUBZone certification. This could allow for more companies to attempt to become HUBZone certified, as well as HUBZone work to become more competitive. The drop in percentage allows for current certified contractors to have some leeway in employee status.

 

3) Employees must live in HUBZone designated area for at least 180 days to be considered towards the new 20% requirement. Registering for a voter ID can no longer expedite process.

Prior requirement – Employees could either live in HUBZone designated area for 180 days or register for voter identification to be considered towards the 35% requirement.  

Proposed change – Employees must live in HUBZone designated area for 180 days to meet the new 20% requirement.

Interpretation – While the 35% rule is being loosened, employee status is being tightened. This is mostly done to cut down on any loopholes being exploited in filing for voter registration. Contractors that depend on employee hirings to impact their percentage immediately will have to build in a 180-day buffer. 

 

4) Employees do not lose HUBZone certification after 180 days, even if they move. However, status is lost once they leave the company.

Prior requirement – In order to count towards the 35% requirement, employees must live in a HUBZone area.

Proposed change – Employees can now move out of HUBZone area as long as they achieved HUBZone status after 180 days. This status is continuous only for that specific employer, and once employment ends, the status is lost.   

Interpretation – SBA mentioned that one of the goals of HUBZone work is economic advancement for employees. They do not want to penalize companies for having employees advance in their careers and afford to move out of economically challenged areas. As long as the company still resides in the economically challenged area, and the employee stays with that company, they feel it is a beneficial to all parties to allow advancement and career growth.

 

5) The areas determined to be HUBZone designated will be unfrozen after the 2020 Census.

Current Status – The HUBZone map that defines the lines for which areas are economically challenged is currently frozen. SBA is waiting for 2020 Census information before unfreezing the maps.

Once Unfrozen – The estimated timeframe to be unfrozen is 12/31/21. HUBZone certification will continue as it was before the HUBZone map was frozen on 12/07/17. For example, if your company was in an area set for redesignation 3 months after being frozen on 12/07/17, you can expect the redesignation to occur 3 months after 12/31/21 on 03/31/21.

 

Follow Up Information

If any of the above points interest you or your company, we highly recommend attending this event next year. These are just 5 of the many important updates covered by the Council that effect HUBZone businesses in the near future. For more information, be sure to check in with the HUBZone Council here.

For frequently asked questions about current HUBZone rules and regulations, SBA’s HUBZone information can be found here.

For more information related to these potential changes, SBA has a blog they update regularly with more interpretations and concepts related to updates.

 

PROCAS Sponsored Event – 2019 National HUBZone Conference author avatar

We will be a sponsor of the 2019 National HUBZone Conference on September 4-5th in Chantilly, VA.

For any clients that are HUBZone certified, this is a great opportunity to network with industry leaders including large prime contractors and federal agencies related to HUBZone designated contracts and subcontracts. The primary focus of the event includes updates to government contracting, specifically related to small business and HUBZone work, as well as matchmaking opportunities with these industry leading organizations.

For those interested, click here to check out the full agenda of the event.

We will have a vendor table set up in the Washingtonian section of the Westfield Marriott towards the center of the room. Feel free to stop by when you have some spare time!

Types of DCAA Audits for Government Contractors author avatar

Audit Procedures

Being the largest purchaser of goods and services in the world, it is no wonder that businesses large and small want to work with the United States Federal Government. With an average of $500 billion spent annually, many view federal contract procurement as a potential revenue stream to grow their business. However, many of these companies do not consider all of the rules, requirements, and oversight that come with that potential revenue. Before jumping headfirst into government contracting, let’s take a look at the types of oversight a company can expect when doing business with the government.

 

What is a DCAA audit?

The Defense Contract Audit Agency is the auditing branch of the federal government. Under control of the Secretary of Defense, the branch’s main purpose is to make sure federally procured funds are being spent accurately and appropriately.

According to DCAA’s Information for Contractors publication, “DCAA performs all necessary contract audits for the Department of Defense and provides accounting and financial advisory services regarding contracts and subcontracts to all DoD Components responsible for procurement and contract administration.”

Essentially, what this means is that their primary goal is to ensure taxpayer dollars are spent on fair and reasonable contract prices. It is DCAA’s responsibility to serve public interest first and foremost.

In order to accomplish this, DCAA has a multitude of audit procedures to ensure that government contractors are kept in line. DCAA is especially concerned with contractors working on cost reimbursable contracts as opposed to those who provide fixed price work. This is because there is more room for error (and even fraud) when billing at cost.

Common DCAA Audit Types

Some of the most common DCAA audit types for companies providing cost-type work are as follows:

  1. Accounting System Requirements (Pre & Post Award) Audit
  2. Real-time Labor Evaluation Audit
  3. Provisional Billing Rates Audit
  4. Public Vouchers (Progress Payments) Audit
  5. Incurred Cost Submissions Audit

We will break down the first 4 of these common audit procedures below.

Notes:

  • Incurred Cost Submissions are too involved to cover in an overview post. This audit type will be covered in a detailed post to follow.
  • There are many more types of audits that do take place, such as financial capacity, proposal adequacy, contract briefs, monitoring subcontracts, contract close outs, etc. The above 5 were selected for the accounting heavy folks in your organization!

 

1. Accounting System Review

Government agencies want to make sure your company is operating using proper accounting policies and procedures before providing funding for any cost type work. To do this, a contracting officer from said agency for said contract will request DCAA perform an accounting system audit on your company, which is broken down into two phases – the pre-award & post-award audits.

         Pre-Award DCAA Audit

The pre-award audit takes place before any cost type contracts are awarded to your company. This is the preliminary check that DCAA reviews to see if you have a proper accounting system in place to be able to handle the proposed contracts.

To start the process, a contacting officer or DCMA (Defense Contract Management Agency) will have you complete standard form 1408, which lists what’s required for your accounting system. Some requirements include segregation of direct costs from indirect costs, identification and accumulation of direct costs by contract, ability to allocate indirect costs consistently across cost objectives, etc. For a full list of what is required, please see our prior blog post How PROCAS Addresses the SF1408.

Once the SF1408 is completed and returned to the contracting officer/DCMA, DCAA will meet with your company to see if you have the capacity to perform on what was completed in the form. This is an upper level review that does not get into the nitty gritty of the system, but ensures you have the proper policies and procedures included with your accounting system. For more on what DCAA audit requirements will be necessary of your system, please see their related documents here.

         Post-Award DCAA Audit

The post-award audit takes place after your company has been performing on the awarded contract for some time. Typically, this is not too long after being awarded and is around 3-6 months (but can be earlier or later). The purpose of this phase of the audit is to make sure you are complying with the accounting policies and procedures specified in the pre-award.

During the post-award audit, you can expect the auditors to dig around your system more than the pre-award. This is a total accounting system review, which will include testing of your policies and procedures as well as data entry. Some examples of areas they could test include: segregation of duties, proper levels of access to data, correct revenue and expense recognition, trailing transactions from general ledger to invoicing, accurate labor distribution from timesheets to general ledger, etc. 

At the end of the day, DCAA wants a vote of confidence that you are operating as you said you would in the pre-award. Therefore, the auditor will take their time and conscientiously look through your system to make sure it does not have any holes.

 

2. Real-time Labor Evaluations

Also known as the “Help! DCAA auditors showed up at my door unannounced, and I don’t know what to do!” audit, real-time labor evaluations are checks to see if your people are working when they say they are working. For service-based contractors, labor is the largest piece of what is billed to the government, so it is of major concern to be monitored by the DCAA.

In these time check or “floor check” audits, the auditors are going to randomly select employees of your company and ask them simple questions to see how timesheet procedures are performed. Some of these procedures include completing time entries, determining how charge codes are created/selected, submitting timesheets, correcting/adjusting time entries, the approval process, access to employees’ timesheets, etc. Once these are confirmed, the auditors will meet with the accounting staff to see how timesheets are collected and labor is distributed with cost. They will want to see that specific cost journals in the general ledger match historic timesheets!

Some common deficiencies in timekeeping compliance that can lead to the failure of a real-time labor evaluation include:

  • The ability of more than 1 person to access an employee’s timesheet to record time
  • Improper selection of charge codes for work being performed (inaccurate use of labor categories, projects, etc.)
  • Inconsistent charging of time across contracts
  • Failure to track changes to employees’ time by audit trail (without reason)
  • Approvers overriding subordinate time without employee consent
  • Inconsistent method of applying labor cost to employee timesheets

In this DCAA audit, there is no warning for when the auditors are going to stop by. Therefore, it is important that your employees know your company’s policies and procedures at all times. We recommend having supervisors and management review these policies with your staff as frequently as possible. For more information to prepare for this surprise DCAA audit, please see click here.

 

3. Provisional Billing Rates

If specified in the provisions of a cost-type contract, contractors are allowed to be reimbursed for indirect costs via interim payments as opposed to waiting until the end of the contract. FAR 42.704 governs the procedures and guidance for establishing provisional billing rates, which is the effective way to approximate a contractor’s final year-end rates (adjusted for any unallowables). Provisional billing rates pose as an estimation of these final year end rates, which are trued up to actual indirect rates at the end of the contract’s fiscal year. More information on FAR 42.704(b) can be found here.

One major criterion for an adequate accounting system is that it provides for billings that can be reconciled to cost accounts for current and cumulative amounts claimed. The auditor is going to check to make sure your system can handle this process within the Accounting System Review audit. However, once approved, the contractor is still going to have to submit provisional billing rates to its DCAA Office or administrating contracting officer every fiscal year included in the contract.

According to DCAA audit requirements, provisional billing rates should be:

  • Submitted at the beginning of each fiscal year or when established billing rates are no longer accurate in representing final year rates (unforeseen circumstances)
  • Representing a 12-month period (contractor’s fiscal year)
  • Submitted at least annually and electronically (if possible)
  • Provided in an Excel format

According to DCAA audit requirements, provisional billing rates should contain:

  • Proposed billing rate calculations (including rationale)
  • Prior fiscal year pool and base
  • Current fiscal year to date pool and base
  • Current fiscal year budget pool and base (if available)
  • Comparative analysis with explanation of significant differences (if applicable)

Penalty: If the above measures are not taken, vouchers and progress payments can be held/returned until appropriate measures are taken to adjust billing rates. This not only hurts your cash flow but can affect all future invoices!

 

4. Public Vouchers (Progress Payments)

Following the same thought process described above, contractors can claim interim payments on work performed throughout their fiscal year. According to DCAA, cost type contracts allow for payments for costs on a Standard Form 1034 public voucher or equivalent. Typically, contracting officers have slight variations on how they would like their invoice to look, however the audit process will look similar for checking how the records of each invoice are maintained. For a look into all of the contractor’s and DCAA’s responsibilities in establishing progress payments, please click here.

Voucher audits are conducted by DCAA to determine the accuracy of costs billed to the government. DCAA auditors will use sample testing to track individual invoices from submitted government invoice in WAWF to the general ledger and job cost report and eventually to the source documents supporting the billed voucher.

Looking at your accounting records, an auditor will check for:

  • Compliance between the invoice and contract terms
  • Accuracy of billed costs to recorded costs (current and cumulative)
  • Consistent application of labor distribution
  • Consistent allocation of indirect rates using established provisional billing rates
  • Segregation of unallowable costs from allowable costs (unallowables cannot be invoiced)
  • Timely payments to vendors and subcontractors
  • Appropriate source documentation for billed costs

Penalty: If the above measures are not taken, vouchers and progress payments can be held/returned until appropriate measures are taken to adjust your invoices. This not only hurts your cash flow but can affect all future invoices!

 

At the end of the day, DCAA wants to make sure the public’s money is being spent appropriately. The above measures can seem very intimidating, so it is important that your company is aware of all the rules and regulations that need to be followed. Remember, you always have the right as a contractor to ask why an auditor needs what they are requesting from you. If anything appears to be unrelated to the measures described in each audit above, you have the right to know why it is required. If any PROCAS clients need help through any of the above audits, feel free to reach out to our consulting team at consulting@procas.com.