Preparing for a DCAA AuditPosted: January 24, 2018
The Defense Contract Audit Agency (DCAA) provides audit and financial advisory services to Department of Defense (DoD) and other federal entities responsible for acquisition and contract administration. They serve as dedicated stewards of taxpayer dollars to ensure that agencies get what they need at fair and reasonable prices.
In an audit, the DCAA aims to establish that your indirect rates are properly allocated. These include fringe benefits (costs related to employing your labor force), overhead (indirect costs of carrying out your contracts) and general and administrative costs (G&A) (the residual costs necessary to run a business, regardless of whether you have government contracts). (See this post for more details.)
Why does this matter? If these costs are not allowable, allocatable to one of the areas in the indirect cost matrix, they won’t count towards your reimbursement. You can’t claim them and use them to build up your rates. If you’ve spent $100,000 but only $50,000 is allowable, that other $50,00 is unrecovered in your rate schedule.
What I’m going to give you in this blog post is the most common things the DCAA looks for. I’m not necessarily going into all the details, rules or regulations. You always have to consult with a knowledgeable contracts person, accountant, or legal expert.
The first issue is consultants and consulting costs, where you need to get outside advice. There are many things that a consultant can do for you, but some of these are not allowable costs under the DCAA rules.
Let’s say I want to bill the government for an analyst at $100 an hour. From the government’s perspective the DCAA comes out and says a certain amount is salary, some are fringe benefits, some is overhead, some is general administrative, and finally the rest is profit. What goes into those buckets can only be allowable costs.
If you have unallowable costs, you may be forced to reduce your rates and that’s what we’re trying to avoid. Of course their goal is to find as many unallowed costs as they can in order to save the government money.
Next there is compensation. We’ve got two areas there – executive compensation and incentive compensation. Executive compensation was capped in the Obama administration, so you need to look into those details. Incentive compensation is very stringently regulated. You can give business development and executive incentive compensation but you have to understand the basis on which you’re calculating and paying those incentives.
Again, I’m not a DCAA accountant; I’m just trying to guide you towards what questions to ask so you don’t get in trouble.
Then we have base labor costs (salaries), and while it seems logical that salaries are covered, you have to be careful because there are lots of things that go into salaries, such as bonuses and gift cards – are they allowable?
For example, at our company TAPE, when you get a “kudo letter” from a customer you get a gift card. That would be a labor charge under employee morale, but you have to work that out with your professional advisor. All of the aspects of how you pay your employees, including health insurance benefits, sick leave, etc., must be addressed.
As for legal costs, the ones that are associated with your projects in government work are allowable, but legal costs for organizational issues, e.g., issuing stock to members of your LLC or owners of your corporation, may not be allowed.
Employee morale is distinct from traditional benefits like life insurance – e.g., you buy soft drinks and put them in the fridge and anyone can take them. That may or may not be an allowable cost. It is an employee morale cost, but you must check that this cost is allowable.
These are some of the many things the DCAA will evaluate when they come out, so make sure you are ready for them!