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On-going - Consult with clients on an as-needed, telecommuting basis - from designing an allowable-bonus policy to enhancing internal controls.
June & July, 2017 – Guide client through Pre-award Survey, SF 1408. Provide feedback, especially DCAA "hot button" words that might lead to misunderstandings. Draft some re-writes, especially for the Cost Allocation Methodology. Discuss Bid and Proposal (B&P) and how it folds into the General and Administrative (G&A) pool; Paid Time Off (PTO) accruals, and the indirect rate structure. Set up a template workbook tailored to convert client QuickBooks (QB) Profit & Loss by Job report into indirect rates calculations and absorptions. Guide client on Policies and Procedures (P&P's) and internal controls. Review P&P's for gaps. Train client in support and General Ledger (G/L) recording transactions of all kinds, including employee reimbursements; "hard" close; and ICE Model. Sample transactions for a mock audit and provide feedback. Draft wording for a memo to DCAA. Review and provide feedback on the Organization Chart with Job Descriptions.
February through April, 2017 – Format proposed travel. Provide definitions and examples of contract "types." Review and recommend an indirect rates template; recommend revised formulas, added "check totals" for verification. Review (whole) cost proposal. Guide future-labor proposed rate development and advise what supporting documentation is needed. Train client on unallowable G&A labor charges, absorption of indirect costs on direct unallowables and overruns. Explain and give examples of allowable, objective employee bonuses.
December, 2016 through March 2017 – Guide client in supporting Price Justifications for sole source purchases. Recommend specific requirements in related supplier solicitations. Perform an evaluation of sample transactions. Recommend specific supporting documents for some types of transactions – especially the record (in the G/L) of travel expenses. Address client concerns about "like circumstances" commercial Independent Research and Development in a company-wide indirect pool.
August through November, 2016 – Conduct a G/L review and recommend specific improvements. Review and recommend supporting documents for G/L transactions. Draft P&P's from templates. Review client cost proposal and provide feedback. Create an indirect rate template based on the client's Chart of Accounts; train client on use. Discuss owner-salary options. Create an empty "shell" G/L, Chart of Accounts, etc. for a new subsidiary of the client. For a sample period, calculate labor and recommend Journal Entries to record Labor. Discuss unallowable costs. Train client on proration of Direct Labor among separately-billed Contract Line Item Numbers. Set up and calculate transactions for paycheck amounts and accounts for three new-hire wage earners plus one new exempt, salaried employee. Train client on QuickBooks functions.
March through June plus October, 2016 – Guide client on developing labor rates and related overhead; forward-pricing (projected for proposals) on-site and off-site indirect rates; and "wrap" (all-inclusive burdened labor) rates. Recommend specific Journal Entries to eliminate double-counting Partner salaries, to accurately apply G&A, and to re-do an August proposal schedules.February, 2016 - Provide detailed feedback on the package of documents client intends to send DCAA Auditor, in response to request for desk-review background.
February, 2016 - In preparation for a client's first CPSR, explain in more detail and with examples, what DCMA expects in the population list; request an adequate list, from which a small sample of Orders can be pre-reviewed. At client's request, draft responses to item in all six DCMA Questionnaires. Build and send a revised plan of steps, showing the last date for receipt from/to client that allows four months of (post-implementation of new policies and procedures) audit trails. The four-month window considers the newly pushed-back period under review, established by DCMA.
January, 2016 - Act as liaison during conference call with DCAA Supervisor, DCMA ACO, DCMA Contract Administrator, the client's Accountant and two client executives. Note several priorities stated by DCAA Supervisor, and later discuss "translation" with client. Discuss client's intended steps and create a list of populations from which DCAA likely pulls sample source documents (timecards, vendor bills, etc.) to review, based on original Accounting System Review findings.
January, 2016 - Review and provide feedback on current policies and procedures covering the period of performance for an up-coming Contractor Purchasing System Review (CPSR). Based DCMA letter requesting "desk-review" background documents, at client's request, prioritize top three priorities. Analyze current purchasing documentation and subcontract Terms and Conditions. Participate in an online conference with the two client representatives managing the CPSR-preparation project; discuss potential Government postponement (due to new policies and procedures in process), population for preparatory mini-review, and approval signatures showing segregation of duties. Tailor most missing policies, procedures, and related forms from boilerplates. Provide a list of topics for which a policy and procedures is strongly recommended, and request direction to draft these.
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