We will be a sponsor of the 2019 National HUBZone Conference on September 4-5^th 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!

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.

Time collection is one of the most important processes for service-based government contractors. In order to effectively collect employees’ time, apply labor distribution, and bill the government accurately, you first need to make sure employees know how to access their timesheets. This is the simplest, yet most important step of implementing a DCAA compliant timekeeping system.

In PROCAS, employees can access their timesheets from any web browser on any device with internet access. This includes laptops, mobile devices, tablets, home computers, and even TV’s.

Let’s take a look at how you can access your timesheet in PROCAS. The following post will be broken down into 4 sections:

• Upgraded Version, Returning User
• Upgraded Version, New User
• Legacy Version, Returning User
• Legacy Version, New User

To determine which category you belong to, please look at the integrated screenshots below to see which login screens look familiar.

As of 04/14/2020 - If you are using a mobile device, instructions for login and usage can be found here. The following post assumes you are using a desktop or laptop computer.

PROCAS Timesheet – Upgraded Version, Returning User

If your company has upgraded to the most recent version of PROCAS, you have the easiest journey to accessing your timesheet. Everyone logs into the same web address, so all you have to do is click here and enter your username and password.

If you forget your username and/or password, please select the “Reset Password” link and enter the email assigned by your administrator to begin the reset process.

Note: If you cannot remember this email either, the accounting admin of your company can look it up under Accounting --> Setup --> Time and Expense Users.

PROCAS Timesheet – Upgraded Version, New User

If your company has upgraded to the most recent version of PROCAS, and this is your first time logging in to record your time, you will need to establish a username and password via an email invitation. Your company’s administrator will determine your level of access in PROCAS and send an email from invites@procas.com to get the login process started.

Click on the first link at the bottom of the email as displayed in the screenshot above. From here, you will be able to establish your login credentials as displayed in the screenshot below.

Follow the instructions defined in the email sent from invites@procas.com to complete the fields required for login.

Note: Your email address will be your official username, which is set by your administrator and cannot be changed by you once this process is completed.

PROCAS Timesheet – Legacy Version, Returning User

If your company is on a Legacy version of PROCAS time, the path you will take to access your timesheet follows the sequence --> www.procastime.com/ + Company Code. In this sequence, the first portion of the web URL stays consistent, however the “Company Code” portion is a code assigned specifically to your company. The following example illustrates this:

Ex. LJ’s Maintenance Shop has been a PROCAS client for 5 years. When implemented, LJ’s Maintenance Shop was assigned the company code of LJMAIN. Therefore, all employees (new and existing) will login to www.procastime.com/ljmain until upgraded to the newest version of PROCAS.

If you forget your username and/or password, please click the “I Forgot My Password” button and enter the email assigned by your administrator to begin the reset process.

Notes:

• If you cannot remember this email either, the accounting admin of your company can look it up under System --> Time and Expense --> Web Users.
• If you are using the correct email, and the system replies with User could not be found, please try logging into this link, or contact your administrator.

PROCAS Timesheet – Legacy Version, New User

If your company is on a Legacy version of PROCAS time, you will first need to set your password before you can log in to the timekeeping system. Following the example in the above section, please navigate to your company’s timekeeping link using the sequence --> www.procastime.com/ + Company Code.

Once you’ve made it to timekeeping, select the “I Forgot My Password” link and enter the email assigned by your administrator upon onboarding. This will generate a system email, which will provide a link to set and confirm the password required to log in. 

Note: If you are using the correct email, and the system replies with “User could not be found”, please try logging into this link, or contact your administrator.

If you bump into any issues attempting any of the above login processes, feel free to contact our Support team at support@procas.com.

As always, running DCAA compliant timekeeping software not only incorporates the software itself, but how it is used. Please be sure to check with your administrative staff for an explanation of how your policies and procedures align with our government contract timekeeping system.

One of the biggest challenges government contractors face is putting together a compliant system that passes DCAA requirements. As most know, developing a DCAA compliant accounting system is a little more complicated than just purchasing accounting software. It is the total incorporation of a company’s best practices, policies, and procedures into a system that allows contractors to be consistent and appropriate in their tracking of costs.

This can be very daunting for the new contractor, who not only is worried about landing their first government contract, but also has to establish those company policies and procedures. The below post will identify the preaward audit process and how PROCAS meets the requirements of the SF1408 form.

Preaward Audit Process

Before being awarded a cost type contract, the DCAA is going to want to verify that the appropriate measures were taken in order to prove the contractor’s ability to adequately track the costs for that proposed contract. This process is known as the preaward audit or preaward survey.

Typically, an auditor will meet with the contractor first to review the established system and procedures, and then again in the future to make sure that system is being followed consistently (post award audit). However, before that takes place, the contracting officer on the proposed contract will require that Standard Form 1408 be completed. This form will be submitted to the DCAA when they request the initial audit of your system. This piece is very important because it gets the entire process started.

Standard Form 1408 is the Preaward Survey of Prospector Accounting System used by the DCAA as an evaluation checklist to determine if your system is sufficient in supporting the proposed contract(s). According to the DCAA, the audit scope will consist of understanding the design of the contractor’s prospective accounting system as well as the procedures essential to reach an informed opinion if that system is acceptable in accumulating and generating required cost information. Having an accurately completed SF1408 is the first step in conquering this audit scope.

For DCAA’s official explanation of the preaward process, please click here.

PROCAS Addresses Standard Form 1408

Below are our answers for how PROCAS addresses the standards that the auditor will be concerned about when evaluating your prospective accounting system. All SF1408 requirements are broken down in detail.

A downloadable version of the below sample SF1408 can be found here.

1. Except as stated in Section I Narrative, is the accounting system in accord with Generally Accepted Accounting Principles applicable in the circumstances?

The PROCAS project accounting software (PROCAS Accounting) is designed to be operated in accordance with Generally Accepted Accounting Principles (GAAP), including maintaining the books of record on the accrual basis of accounting.

2. Accounting system provides for:

a. Proper segregation of direct costs from indirect costs.

In PROCAS Accounting, expense accounts in the chart of accounts are identified as either direct or indirect, which provides for the proper segregation of direct costs from indirect costs. Additionally, PROCAS assigns specific account types to further segregate these costs.

b. Identification and accumulation of direct costs by contract.

In PROCAS Accounting, the identification and accumulation of direct costs requires the assignment of direct costs to a corresponding project code. The project code corresponds to a contract.

c. A logical and consistent method for the allocation of indirect costs to intermediate and final cost objectives. (A contract is a final cost objective.)

PROCAS Accounting provides logical and consistent methods for the allocation of indirect costs to intermediate and final cost objectives. Indirect rates can be calculated automatically for Fringe Benefits, Facilities, Material Handling, Subcontract Administration, Overhead and G&A. Bid and proposal and internal research and development costs are also treated appropriately. The indirect rates can be further segregated by division, location and work-site. Indirect rates are automatically applied to contracts in direct correlation/proportion to the respective allocation base.

d. Accumulation of costs under general ledger control.

PROCAS Accounting accumulates costs directly to the general ledger, which is the basis for financial and job cost reports.

e. A timekeeping system that identifies employees’ labor by intermediate or final cost objectives.

PROCAS provides online timesheet software (PROCAS Time) in which employees record their time to intermediate or final cost objectives. Employees are assigned appropriate intermediate and/or final cost objectives for recording their time and can only record their time to their authorized work assignments.

f. A labor distribution system that charges direct and indirect labor to the appropriate cost objectives.

In PROCAS Accounting, the distribution of direct and indirect labor costs are recorded automatically from the employee timesheets created in PROCAS Time to the appropriate cost objectives. PROCAS Accounting supports the calculation of effective hourly rates associated with total time accounting.

g. Interim (at least monthly) determination of costs charged to a contract through routine posting of books of account.

In PROCAS Accounting, direct costs are posted in the general ledger and job cost ledger in real time and do not require the use of batch processing or summary entries. Indirect rates can be automatically calculated and applied at any time.

h. Exclusion from costs charged to government contracts of amounts which are not allowable in terms of FAR 31, Contract Cost Principles and Procedures, or other contract provisions.

In PROCAS Accounting, expense accounts are identified as being either allowable or unallowable. Unallowable expenses are excluded from indirect cost pools when automatically calculating and applying indirect rates.

i. 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.

PROCAS Accounting has the capability to incorporate logical project assignments that will track costs by unit and/or line item.

j. Segregation of preproduction costs from production costs.

In PROCAS Accounting, pre-production costs are segregated from production costs through the use of project assignments and/or separate expense accounts.

3.Accounting system provides financial information:

a. Required by contract clauses concerning limitation of cost (FAR 52.232-20 and 21) or limitation on payments (FAR 52.216-16).

In PROCAS Accounting, reports are available to assist with managing the limitation of costs and/or limitation of payments.

b. Required to support requests for progress payments.

PROCAS Accounting supports cost type, time and materials and fixed price invoices which are generated automatically from the accounting records. Requests for progress payments can be generated for interim time periods, by percentage of completion or by deliverables as specified by the contract.

 4. Is the accounting system designed, and are the records maintained in such a manner that adequate, reliable data are developed for use in pricing follow-on acquisitions?

Yes. In PROCAS Accounting, records are designed to be maintained so that adequate, reliable data can be developed for use in pricing follow-on acquisitions.