DCAA-Assist

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AUDIT COMPLIANCE

DCAA AUDIT OBJECTIVES

Defense Contract Audit Agency (DCAA) compliance is crucial for any company engaged in government contracting. There are some common misconceptions about what exactly DCAA software is and/or how to make yours compliant.

Software systems aren’t actually approved by DCAA because such a process does not exist. The actual manner by which a government contractor earns DCAA’s trust and reliance is through intelligent implementation of several key accounting policies, procedures, and systems. These include, but are not limited to, a reliable internal control environment, comprehensive time and labor reporting, a clearly defined chart of accounts, and effective cost capturing and allocation methods.

It is certain that your accounting system will be reviewed by DCAA, sometimes before they award you the contract, and periodically throughout the entire contract engagement. During these reviews they will determine the adequacy and suitability of your accounting process for accumulating costs. What DCAA wants to see is a) do you have these processes in place and b) are they reliable?

Having a compliant solution that sufficiently records cost, tracking, allocation, billing mechanisms and internal controls will provide DCAA auditors with a sense of confidence in the record keeping and capabilities of the contractor. As a result of their level of confidence in your records and system, it is likely that their findings will be satisfactory.

DCAA-Compliance testing is a multi faceted process which generally includes several thorough questionnaires, key management interviews, one of more site-visits, and requests for documentation (for internal controls, policies and procedures, accounting reports, etc.). Below you will find:

  • A sample DCAA Pre-Award letter requesting data and records
  • A sample Internal Controls Questionnaire (ICQ)
  • DCAA Form 1408 (prepared by the DCAA Auditor) [click here for pdf]

DCAA-Assist will help you prepare a thorough and professionally documented response to all DCAA requests for information so your accounting system and internal control environment (including all pertinent Policies & Procedures) will earn DCAA approval.

ACCOUNTING SYSTEM EVALUATION LETTER

Dear Contractor,

This letter is to advise you we are initiating an audit relating to Contractor’s accounting system as a result of proposal F2-77.5104.88. Specifically, DCAA has been requested to perform a pre-award accounting system evaluation to determine whether your accounting system is adequate according to Federal Acquisition Regulations (FAR) for award of future government contracts. In conjunction with our audit, it is requested that the following data and records be assembled and made available for our audit field visit.

  1. Most recently completed fiscal year prepared financial statements and associated notes.
  2. Most recently completed monthly financial statements (to include Statement of Stockholders’ Equity, Balance Sheet, Income Statement, and Statement of Cash Flows).
  3. Year to date Trial Balance.
  4. Year to date Chart of Accounts.
  5. Identify the general ledger account codes for each indirect expense that make up your indirect cost pools and each expense account that makes up your allocation bases.
  6. Detailed computations for each year to date indirect rate.
  7. Most current month’s Job Cost Subsidiary Ledger.
  8. Identification of general ledger accounts used to collect unallowable costs.
  9. Policies and procedures pertaining to the following:
    1. Identification of direct and indirect costs.
    2. Describing how costs are accumulated by contract.
    3. Describing the indirect costs, indirect cost pools, and the allocation bases.
    4. Application of overhead to the job cost ledger, if applicable.
    5. Describing the establishment of provisional billing rates based on annual forecasts at the beginning of the year.
    6. Describing how often you monitor interim provisional billing rates to preclude significant over/under contract billings of costs.
    7. Describing in regards to actual indirect rate determination and incurred cost submission at year end.
    8. Billings adjustments after the final indirect rates have been established.
    9. Describing whether a job cost ledger is used as a basis for billings on contracts.
    10. Describing system of recording labor hours, ensuring they are recorded in the labor distribution report and reflected in the job cost ledger and general ledger trial balance.
    11. Written policies and procedures for posting costs to the job cost general ledger, if available.
    12. Identification and removal of FAR 31 unallowable and directly associated costs from the contract and from the indirect costs pools which are allocated to contracts.
    13. Training to accounting personnel in regards to unallowable costs.
    14. Budgetary and cost monitoring controls to ensure contract performance can be accomplished within the contractual cost ceiling.
    15. Notification to the contracting officer in the event that total costs will be significantly different from the estimated costs.
    16. Description of timekeeping system.
  10. Accounting system description with an overview of the system and a description of the major subsidiary books of account; including a description of what ledgers are fully integrated into the accounting system and what systems are manual in part.
  11. Current employee listing.

INTERNAL CONTROL QUESTIONNAIRE -

SURVEY OF CONTRACTOR'S ORGANIZATION, ACCOUNTING SYSTEM AND SYSTEM OF INTERNAL CONTROLS (ICQ)

Purpose. This questionnaire provides the basis for documenting the auditor’s understanding of the entity’s internal control components and is used to plan the audit. Five components of internal control are applicable to the audit of every entity: Control Environment; Contractor’s Risk Assessment; Information and Communications; Monitoring; and Accounting System Control Objectives and Activities.

Procedures For Obtaining Understanding. In obtaining an understanding of controls that are relevant to audit planning, the auditor should perform procedures to obtain sufficient knowledge about the design of the relevant controls pertaining to each of the five internal control components and determine whether they have been placed in operation. This knowledge is ordinarily obtained through previous experience with the contractor and through procedures such as inquiries of appropriate management, supervisory, and staff personnel; inspection of the contractor’s documents and records; and observation of contractor activities and operations. The form and extent of this documentation is influenced by the size and complexity of the contractor, the auditor’s previous experience with the contractor, the nature of the particular controls, and the nature of the contractor’s documentation of specific controls (AU 319.58).

[PART B - CONTROL ENVIRONMENT AND OVERALL ACCOUNTING SYSTEM]

  1. Does management promptly correct deficiencies noted in external CPA's management letter on internal controls and in DCAA internal control audits?
  2. Does the contractor maintain written policies and procedures to describe:
    1. The assignment of authority and areas of responsibility so that there is adequate segregation of duties.
    2. The general accounting system.
    3. Identification and exclusion of unallowable costs.
    4. Direct/Indirect charge practices.
    5. Preparation of incurred cost submissions and forward pricing proposals.
    6. Allocation of indirect costs to final cost objectives.
    7. Approval and documentation of journal entries.
    8. Establishment of account numbers.
    9. Approvals for establishing contract charge numbers.
    10. Allocation of income, rebates, refunds, allowances or other miscellaneous credits.
  3. Are the contractor’s cost accounting records reconciled to and controlled by the general accounting system on a current basis, i.e., postings are made at least monthly?
  4. Does the contractor’s system identify costs by contract (e.g., job cost ledger)?

[PART C - CONTRACTOR’S RISK ASSESSMENT, INFORMATION AND COMMUNICATIONS, AND MONITORING]

Contractor’s Risk Assessment:

  1. Does the contractor have a risk assessment process for identification, analysis, and management of risks relevant to the preparation of submissions to the Government in accordance with Federal Government regulations?
  2. Has any current or previous assignment identified the contractor’s failure to properly assess the risk of having noncompliant submissions?
  3. Has any significant change in accounting for costs within the contractor’s current and preceding two years?
    1. Allocation of indirect costs --Structure of the indirect overhead rates (pool or base costs)?
    2. Accounting for direct costs?

Information And Communications:

  1. Does the contractor have written policies and procedures for the IT system that include appropriate manual and computerized control procedures to:
    • initiate, record, process, and report the contractor’s transactions and journal entries (as well as events and conditions) from their occurrence to their inclusion in the accounting records;
    • enter transaction totals into the general ledger;
    • record recurring and nonrecurring adjustments or reclassifications if they are not recorded through formal journal entries?
    • convert hard-copy documents to electronic medium (if applicable)?
  2. Do the contractor s policies and procedures address the individual roles and responsibilities pertaining to internal controls over accounting information?
  3. Does the contractor disseminate its policies and procedures to its employees?
  4. Has any current or previous assignments identified the contractor’s failure to properly implement any of these internal control procedures?

Monitoring:

  1. Does the contractor have ongoing monitoring procedures and/or separate internal control reviews/audits to ensure that internal controls are operating as intended and that they are modified as appropriate for changes in conditions?
  2. Has any current or previous assignment identified the contractor’s failure to monitor the effectiveness of internal control procedures?

[PART D. - ACCOUNTING SYSTEM CONTROL OBJECTIVES AND ACTIVITIES]

Labor System:

  1. Does the contractor have a training program to reasonably assure that all employees are aware of the importance of proper time charging?
  2. Do the contactor’s written policies and procedures provide labor documentation/work descriptions that identify the work to be performed, and are labor charges tracked to a final cost objective, whether allowable or unallowable/direct or indirect?
  3. Does the contractor maintain written timekeeping policies and procedures to reasonably assure that labor hours are accurately recorded and corrections are documented, including authorizations and approvals?

Materials/Purchasing Systems:

Does the contractor maintain written policies and procedures to describe the major manual and automated systems that comprise the material management and accounting system?

Estimating:

Does the contractor have written estimating policies and procedures to address employee training, assignment of authority and responsibilities, cost estimate development, and the estimating system process, activities, and functions?

Billing System:

Does the contractor have and disseminate written billing policies and procedures which address employee training, contract briefing to identify special billing provisions and limitations, and management review of billings?

Planning / Budgeting:

Does the contractor have written policies and procedures for the planning and budgeting system, which include the formal assignment of duties and responsibilities and a description of the system?

Compensation:

Do written policies and procedures for compensation exist to include:

  • a salary structure and administration;
  • a description of fringe benefits provided to employees; and
  • a system for determining pay increases, bonuses, and promotions?

Overall Accounting System Control Objectives And Activities:

Has any current or previous assignment identified the contractor’s failure to properly implement any of its internal written control procedures in Part D above?

ADDITIONAL INFORMATION