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What is DCAA Compliance?

The DCAA is the government agency responsible for performing all audits for the Department of Defense (DoD) to ensure government contractors comply with federal regulations regarding proper financial management. The DCAA also provides contract audit services for many other non-DoD government agencies.

DCAA compliance, short for Defense Contract Audit Agency compliance, is a crucial necessity for businesses seeking or currently engaged in government contracting work. To ensure compliance with DCAA requirements, it is essential for organizations to understand the Federal Acquisition Regulations (FAR) and adhere to its mandates. The FAR serves as the principal set of rules in the Federal Acquisition Regulation System, governing the acquisition process through which the government procures goods and services.

The DCAA conducts various audits, including Accounting System Review, Provisional Billing Rate Audit, Progress Payment Audit, Timesheet Floor Check, and Annual Incurred Cost Audit. These audits are designed to assess a contractor’s adherence to the FAR and evaluate their compliance with federal regulations. Non-compliance with the FAR can result in detrimental consequences for contractors, such as being excluded from future government contracts or teaming arrangements with other contractors.

Moreover, the DCAA has the authority to recommend actions to the Contracting Officer, such as the suspension of payments on ongoing projects or the disallowance of costs on completed contracts. Therefore, it is crucial for both large and small contractors to prioritize DCAA compliance and ensure that their business processes and systems align with the stringent requirements set forth by the agency.

In summary, DCAA compliance is a comprehensive framework that encompasses adherence to the FAR and adherence to DCAA requirements. By establishing and maintaining DCAA compliance, businesses can not only secure government contracts but also maintain a positive reputation within the industry.

What does DCAA Compliance Entail?

DCAA compliance entails adhering to the recommendations and guidance set forth by the DCAA, ensuring full compliance with federal law and adequate preparations for audits down the line. The DCAA conducts various audits, including an Accounting System Review, Provisional Billing Rate Audit, Progress Payment Audit, Timesheet Floor Check, and Annual Incurred Cost Audit. These audits assess the contractor’s compliance with the Federal Acquisition Regulations (FAR), which is the principal set of rules in the Federal Acquisition Regulation System.

The FAR is a collection of regulations issued by federal agencies to administer the acquisition process, which involves the government’s purchase of goods and services. Compliance with the FAR ensures that contractors meet the requirements established by the government for the acquisition process. It serves as a framework for contractors to follow, ensuring transparency, accountability, and fairness in government contracts.

When the DCAA performs these audits, they thoroughly evaluate the contractor’s adherence to the FAR. They assess the contractor’s accounting system, provisional billing rates, progress payments, timesheet accuracy, and annual incurred costs. The purpose of these audits is to verify that the contractor’s systems and processes are in line with the requirements set forth by the FAR.

Maintaining DCAA compliance involves having comprehensive documented procedures and policies in place, ensuring that these procedures are fully adhered to. It also requires the implementation of systems that meet the specific requirements of the DCAA. For example, the accounting system must be capable of accurately tracking various costs separately, including direct costs and indirect costs, with related indirect costs grouped by cost pools.

Additionally, integrating DCAA compliance with the company’s timekeeping system is crucial. This ensures accurate and reliable timekeeping records, which play a significant role in cost allocation and tracking. In the event of an audit, easy accessibility to all the necessary reports that the DCAA may require is essential to demonstrate compliance with the FAR and facilitate the auditing process.

Overall, DCAA compliance encompasses adherence to the recommendations and guidance of the DCAA, while also meeting the specific requirements outlined by the FAR. It involves thorough evaluations of the contractor’s systems, procedures, and records to ensure transparency, accuracy, and compliance with federal regulations governing government contracts.

What is the Role of CAS and FAR in DCAA Compliance?

DCAA compliance is essential for government contractors, ensuring adherence to federal regulations and proper preparation for audits. Central to this compliance are two key sets of rules: CAS and FAR. CAS, which stands for Cost Accounting Standards, was developed in 1968 to maintain consistency in cost accounting practices among government contractors. It provides detailed guidelines on contract charges, cost allocation, accounting system maintenance, and the flow of costs within an organization. By adhering to CAS, contractors can establish accurate and reliable accounting practices necessary for DCAA compliance.

In parallel, the Federal Acquisition Regulation (FAR) plays a vital role in the government acquisition process. FAR is the primary set of rules within the Federal Acquisition Regulation System, governing the purchase of goods and services by federal agencies. It encompasses various aspects of contractor requirements, including specifications, payments, conduct, solicitation of bids, and invoice payment. Contractors, regardless of their size, must comply with the FAR to ensure adherence to the regulations set forth by the government.

Failure to comply with the FAR can have serious consequences for contractors, such as being precluded from future government contracts or teaming arrangements with other contractors. Therefore, it is of utmost importance for all contractors to understand and adhere to the FAR. By following the guidelines set by CAS and FAR, contractors can maintain DCAA compliance, ensuring they meet the necessary standards and regulations imposed by the federal government.

The Federal Acquisition Regulations (FAR) outlines the requirements of contractors during the acquisition process:

  • for selling to the government,
  • the terms under which the government obtains ownership, title and control of the goods or services purchased,
  • rules on specifications, payments, and conduct,
  • actions regarding solicitation of bids, and
    payment of invoices.

DCAA Compliance for Government Contractors

If a contractor is not in compliance with the FAR, they may be precluded from future government contracts or teaming arrangements with other contractors. It is also possible for DCAA to suggest to the Contracting Officer to stop payments on work that is in progress or disallow costs on completed contracts. Therefore, it is critical for all contractors both large and small to comply with the FAR. 

Review the DCAA Publication “Information for Contractors” on DCAA’s website for a look at requirements when working with DCAA auditors.

Understanding the Types of DCAA Audits our Clients Often Face

Common with small business contractors, preaward audits examine the contractor’s accounting system, determining whether it is adequate for awarding a contract, and involves completion of the SF 1408 form (Pre-Award Survey of Prospective Contractor Accounting System).

    • The audit looks at the contractor’s accounting system to confirm they are GAAP (Generally Accepted Accounting Principles) compliant and have accurate timekeeping, labor distribution, cost allocation, and billings.

Conducted after the contract award, to determine the accuracy of a contractor’s cost representations.

Conducted before the contract award, these evaluate a contractor’s estimate of how much it will cost the contractor to provide the products or services.

Confirms the existence of employee, the adequacy of timekeeping practices and tests the validity of employee time entry. 

DCAA Project Accounting System Compliance from PROCAS

PROCAS software and consulting services guide government contractors to meet the FAR compliance requirements and pass DCAA audits. 

Although DCAA does not support, endorse, or approve accounting software from any vendor, PROCAS Software is specifically designed to comply with the FAR. PROCAS has worked exclusively with government contractors since 1997, and clients consistently report passing DCAA audits. The Standard Form 1408 (SF 1408) that the DCAA uses for Preaward Accounting System Surveys is available to view here.

DCAA

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