DCAA Relations, Department of Defense News, Running Your Business

DOD Prohibits Funding of Contractors with Certain Restrictive Confidentiality Agreements

DOD issues a class deviation from the FAR that addresses employee confidentiality agreements. If DOD determines that such an agreement can restrict an employee’s ability to report waste or fraud, DOD can yank the contractor’s funding.

As usual, the joy will be in the interpretation of the word ‘restricting’. Good financial ethics, as modeled in my book, require a concerned employee to report up the chain of command. Could telling someone else in the company before calling the government be considered ‘restrictive’?

http://www.acq.osd.mil/dpap/policy/policyvault/USA004514-16-DPAP.pdf

 

4th-ed-cover

Available on Amazon on www.dcaacompliance.com

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Running Your Business

The Most Important Business Rule You Will Ever Learn: The House is White on this Side

In Robert Heinlein’s future world found in Stranger in a Strange Land (1961) it appears the CPA profession evolved a new profession called Fair Witnesses.

In a world envisioned back in 1961, the future world would allow anyone to fake anything: documents, audio recordings, video, anything. Sound a bit prophetic, does it not?  In such a world, people with perfect recall were trained to attest to exactly how the original document, conversation, event occurred. These individuals formed a profession called Fair Witnesses.

In the book, a character named Jubal is explaining to another character Jill, the importance of a Fair Witness. Jill states that she has never met one, not realizing that one of the ladies she is socializing at Jubal’s house is a Fair Witness. The conversation goes as follows:

 

Anne was on the springboard; she turned her head. Jubal called out, “That house on the hilltop—can you see what color they’ve painted it?”

Anne looked, then answered, “It’s white on this side.”

Jubal went on to Jill, “You see? It doesn’t occur to Anne to infer that the other side is white, too. All the King’s horses couldn’t force her to commit herself . . . unless she went there and looked—and even then she wouldn’t assume that it stayed white after she left.”

“Anne is a Fair Witness?”

“Graduate, unlimited license, admitted to testify before the High Court. Sometime ask her why she gave up public practice. But don’t plan anything else that day—the wench will recite the whole truth and nothing but the truth, which takes time.

“It’s white on this side”. “The house is white on this side.”

My children, friends, staff, and clients hear me express these words time and time again. Never assume the house is white on the other side.

  • Never assume that they credited cash on the other side of the entry
  • Never assume what the regulation says
  • Never assume the lady wishes to talk to you
  • Never assume that the professional is professional
  • Never assume that Paul or Jane know what they are talking about.

 

And so on and so on.

Most skeptics assume something is wrong until it is proven right. I am talking about something a little more intelligent, a little subtler.  I am talking about the eternal and constant search for the truth, for the facts, and a healthy understanding of what we think or assume.

  • Find the other side of the entry
  • Look at the regulation
  • Ask the lady if you are bothering her
  • Get a second opinion or more information about the individual giving you the first opinion
  • Keep an open mind about what Paul or Jane said and form your own opinion before you act.

The House is White on This Side.

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Accounting System, Cost And Accounting, DCAA Relations, Incurred Cost Proposals, Running Your Business

Really? Meals and Entertainment Expenses

While working on another project this morning, I recalled that twice in the last year; two separate DCAA auditors working thousands of miles apart, asked why the contractor had separate accounts for Meals and Entertainment in their Chart of Accounts.

Enough said?

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