ACCOUNTING FOR GOVERNMENT CONTRACTS in .NET framework

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ACCOUNTING FOR GOVERNMENT CONTRACTS
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Margaret M Worthington, CPA
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371 UNIQUE ACCOUNTING REQUIREMENTS FOR FEDERAL CONTRACTORS 372 MANAGEMENT INFORMATION SYSTEM REQUIREMENTS (a) Cost Accounting Systems (b) Cost Estimating Systems (c) Material Management and Accounting Systems (d) Project Management Systems (e) Billing Systems (i) Cost-Reimbursement Contracts (ii) Fixed-Price Contracts (f) Record-Retention Requirements 373 SPECIFIC ACCOUNTING REQUIREMENTS
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(a) Effects on Contractors (b) Cost Principles (i) Advance Agreements on Particular Cost Items (Federal Acquisition Regulation 31109) (ii) Composition of Total Allowable Costs (iii) Factors Affecting Allowability (Federal Acquisition Regulation 31201) (c) Cost Accounting Standards (i) Contract Coverage (ii) Price Adjustments (iii) Disclosure Statements (iv) The Standards (d) Contract Changes and Terminations (i) Contract Changes (ii) Contract Terminations
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371 UNIQUE ACCOUNTING REQUIREMENTS FOR FEDERAL CONTRACTORS
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The federal government operates within a formalized statutory and regulatory framework when it acquires products and services That process was signi cantly streamlined and simpli ed in the 1990s for acquisitions of commercial products and services or awards that are competed among quali ed suppliers For contracts awarded in these circumstances, negotiations are based on prices submitted by offerors in response to government solicitation notices However, when products or services are custom made and/or awards are not competed, the estimated or actual cost of performance becomes a dominant factor in setting prices Consequently, systems used by federal contractors in this latter environment must not only maintain information that is necessary to effectively price contracts and control contract incurred costs but also must comply with special cost estimating, cost accounting, billing, and project management requirements This chapter is
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ACCOUNTING FOR GOVERNMENT CONTRACTS
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designed to provide a practical discussion of those unique federal contracting requirements, which include:
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Cost Principles Federal cost principles contained in Part 31 of the Federal Acquisition Regu-
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lation (FAR) provide speci c criteria as to the costs that may be included in contract proposals, claims and billings submitted to the government Cost Accounting Standards (CAS) Nineteen CAS and disclosure statement ling requirements address disclosure of cost accounting practices and measurement and assignment and allocation of costs Defective Pricing The Truth in Negotiations Act is designed to ensure that the government has the opportunity to review all signi cant and relevant cost or pricing data available to the contractor when contract prices are being negotiated on the basis of estimated costs of performance If, after the negotiation, it is determined that current, complete, and accurate data were not submitted, the contract price is subject to downward adjustment for any price increase resulting from the failure to disclose the relevant data
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372 MANAGEMENT INFORMATION SYSTEM REQUIREMENTS
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To compete effectively in any market, management must have the information necessary to plan and control its business In the complex federal acquisition environment, companies must have systems and controls that provide adequate accounting, estimating, and project management information The planning phase begins when a contract proposal is prepared During that process, contract performance is broken down into meaningful work packages with cost estimates, performance schedules, and performance responsibility assigned to appropriate cost centers When the contract is awarded, such data should be used to establish the performance and cost baseline for monitoring actual performance During performance, comparisons of actual and budgeted costs and schedule permit a contractor to take prompt corrective action as unfavorable variances occur (a) COST ACCOUNTING SYSTEMS Most negotiated federal contracts contain the FAR 522152 clause, Audit and Records Negotiation, which provides that the Contractor shall maintain records and other evidence suf cient to re ect properly all costs claimed to have been incurred or anticipated to be incurred directly or indirectly in performance of this contract Contractors performing contracts for which cost or pricing data were submitted before contract award must have cost accounting systems that comply with FAR (and perhaps CAS) requirements Allowable costs form the basis for requests for reimbursement of costs incurred under cost-reimbursement contract billings and xed-price contract progress payments For rm- xed-price contracts requiring submission of cost or pricing data prior to contract award, an adequate cost accounting system is required even though costs incurred on the contract do not affect the remuneration ultimately paid to the contractor upon contract completion Rather, the cost accounting system is critical for providing data for follow-on contract cost pricing, providing a basis for tracking contract performance and supporting cost-based progress payment requests To price follow-on contracts, information on the rate of improvement in performing repetitive tasks on subsequent production (ie, learning curves) is important Well-designed cost accounting systems can enable estimators to identify the costs or hours incurred on prior contracts or production lots The ability to segregate nonrecurring costs from recurring costs is also critical for follow-on pricing Clearly, the design of the accounting system is all-important in providing valuable input for the estimating or planning process for contract costs The regulations do not specify that the contractor maintain any speci c type of accounting system Rather, FAR 31201-1 states that any generally accepted method of determining or estimating costs that is equitable and is consistently applied may be used Cost ledgers can be designed in a variety of ways to permit ef cient accumulation of costs for billing purposes In practice, these records vary considerably, based on the individual company s need for information
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