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

Recent Short Interview with NMSU on Small Business Government Contracting



Accounting System, Cost And Accounting, Department of Defense News, Running Your Business

A World Without DCAA hits SBIR Phase One

Here are some of the requirements from the Department of Homeland Security’s latest SBIR  RFPs


“Additional deliverables in this phase include the following (templates to be provided later by the federal Program Manager):

  • Monthly Status Reports, including master schedule for Phase II activities, quad chart, table showing each task description, percentage completed, targeted completion date, revised dates (if applies), etc.
  • Monthly Financial Status Report showing reporting month, cumulative costs, allocated financial data for direct labor categories, labor hours, labor rates, consultants/subcontractors cost, travel, materials purchased, etc.
  • Monthly status calls “

Section A-5

I recently participated in a Navy SBIR conference where one of the other panelists encouraged contractors not to worry about the budgets on their SBIR Phase One. It appears that may no longer be the case.

I had a dim memory of the DOD program staff asking for similar reports years ago. I went to look and found one form so old that I cringed at the title: “Fund Man Hours Expenditures”. I imagine an updated version of this is in many small business contractor’s futures.

All of this underlines the importance of doing it right from the start. Contractors starting out should start out with a cost accounting system that will meet their needs and the government requirements.

Accounting System, Department of Defense News, Running Your Business

DFARS Cyber Security for Small Business Contractors

In 1998, I listened to an IT staff member from a large contractor proceed to chew out the contractor’s accounting staff for ‘losing’ a folder stored on the company’s servers containing all of the year-end closing work. He proceeds to call the staff “idiots” and ignorant while glossing over the fact that the IT department’s backup of the critical data had failed the night before.

He noticed my smile and could not decide if I was agreeing with him or laughing at him, so he asked me what the F**K I was smiling about. I replied,

“I want to thank you. For years people have criticized accountants as being unresponsive to the company’s needs, speaking a language no one else understands, and not really caring about the success of the company. People now say this about IT people instead”.

A few weeks later a software consultant, with full access to all of the IT systems, destroyed the company’s general ledger by using direct access to the database to create new balances in 146 general ledger accounts. The consultant then spent months trying to fix the error while hiding it from the company. Nine months later, one of the company’s employees printed out a general ledger report that showed a WIP balance of a little over two million dollars while the subsidiary ledger showed an amount several times larger.

What saved us was the trial balance that I had printed out the day before the consultant screwed up the general ledger. I took the printout with me as a resource for my work for them with DCAA.

As a result of this lesson, and too many others, I started asking myself twenty years ago about the relationship between accounting and IT.  Part of my thinking can be seen in the name I chose for my later technology company: “Accountable Technologies”. I would love to say that Edward Snowden was the final nail in the coffin, but there are thousands of accidental and deliberate Snowdens scattered across American businesses, large and small.

I personally believe that IT personnel should have episodic access to the accounting system; not at will. Perhaps you do not agree with this, fine.

But, you should take advantage of the new cyber security requirements adopted by the Department of Defense to think about the issue, to develop your own policies and procedures.

DARPA put up an excellent guide for small business with links to expanded materials. Take a look and think about it.

By, the way, if you were wondering what happened to the missing folder, an employee visiting from another location to document procedures, had moved the folder to her personal files for future reference thinking she had copied it. We discovered this a couple of hours later when she wandered in to the office.

More at

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

How to LOSE Those PROFITS (What DCAA and the Government Will Do to You)

In the current crisis surrounding DCAA, it is possible to receive a cost type contract requiring an approved accounting system without actually having anyone from the government look at your accounting system.

This may sound like a gift from heaven but it is not. All it does is transfer the risk off the government’s back and onto yours.  Under this increasingly common scenario the contractor assumes the following risks:

The government can come in at any time and evaluate your accounting system with disastrous results to include: suspension of full payments and even contract termination (the latter is extremely rare).

The government can suddenly withhold all or part of your payments until they now decide your accounting system is adequate.  They may even expect you to continue working while the mess is sorted out.

This withhold is now actually part of the Department of Defense regulations and the subject of a recent DOD OIG audit. This audit criticized DCMA for not withholding 5% of total payments after an accounting system was found inadequate.[1]

This is not the 15% of your fee or profit you may have heard about. This is up to 5% of your total billing. Remember, profits on cost type contracts usually average 5% to 7% of costs billed. If the government refuses to pay 5% of your total billing they just eliminated the vast majority of your profits.[2]

Oh, and it can get worse. Applied Physical Sciences, a small contractor, went to the Armed Services Board of Contract Appeals (ASBCA) claiming the government failed to reimburse over a million dollars. The government simply refused to pay them based on an inadequate accounting system, arguing that the inadequacy made it impossible to determine if any of the costs claimed were actually associated with government work. Applied Physical Sciences actually raised the inadequate accounting system as a defense, asserting the government should not have awarded them a cost contract. Alas (or not), the government won.[3]

The lesson is ‘crystal clear’. The government awarded the contract in complete disregard of the government’s own standards and the contractor paid for it.

The lesson is ‘crystal clear’. The government awarded the contract in complete disregard of the government’s own standards and the contractor paid for it. The contractor paid for it not because of the government’s failure to approve the accounting system, but because there was no adequate accounting system to support the contractor’s claimed costs.

They can also hold up any future contracts awaiting the now necessary approval.

Even as the government has lost in way in how to enforce compliance, contractors need to understand the importance of excellent accounting systems to the government.


Time and time again I am surprised by contractors who believe that accounting for government dollars on their part is unnecessary and a waste of time. A few years ago, I declined to work with a government contractor who bragged about getting DCAA to approve his accounting system without a general ledger system and his refusal to comply with the standards (or as he put it: “ridiculous demands”).

He wished to engage me to prepare and submit the billing on a cost type contract based on what he told me to bill. When I declined the ‘opportunity’, he accused me of being scared. When I told a friend about his comments; she teased me, stating that I was ex 82nd Airborne and not scared of anything. “No,” I replied, “I am scared, not of the government, but him”.

Your accounting system is important because the government says so, even if they come back after three years to punish you.

Each year the government spends billions of dollars with contractors providing vital services for our country. All of this money, to include classified work, is ultimately accountable to taxpayers (we all remember the stories about $400 hammers purchased by the Defense Department). The good contractors reading this book have no desire to make the front page of the papers (or worse the bench in front of a federal judge) because of their lack of accountability.

Almost immediately after publishing the new regulations[4] about contractor business systems, DCMA hit Lockheed Martin with a reduction of 5% in payments for the F-35 fighter. Last time I checked the total withholding was over 47 million dollars. If five percent does not seem like a lot, it represents almost all of the profit Lockheed planned on the F-35. Until they get their business systems approved they are working for free.

It is not only the Defense Department that is tightening down on contractor accountability, look at a recent Department of Energy regulation:

Contractor business systems and its internal controls are the first line of defense against waste, fraud, and abuse. Weak control systems increase the risk of unallowable and unreasonable cost on Government contracts. When a contract includes these business systems clauses, it will require the contractor to meet business system criteria for its estimating system, accounting system, earned value management system, purchasing management system, and property management system. When the contractor has acceptable business systems that comply with the terms and conditions of the contract, this will improve contract performance. Under certain conditions, if the business system has significant deficiencies, the contracting officer will be able to withhold a percentage of payments until the significant deficiencies are corrected.

Taxpayers demand accountability and the government will demand accountability from you, not stories, not promises.

[1] Evaluation of Defense Contract Management Agency Actions on Reported DoD Contractor Business System Deficiencies (Project No. D2013-DAPOCF-0201.002) DODIG-2016-001

[2] Lockheed Martin just finished three years of fee withholding for a noncompliant estimating system.

[3] Armed Services Board of Contract Appeals (ASBCA) 56581 and 58038

[4] We will discuss the regulations later in the chapter.

Excerpt from Surviving a DCAA Auditavailable on Amazon

Accounting System, Running Your Business

The Good Lord Forgive Me, My Favorite Embezzlement Story

Audit Firm Victim Of Embezzling

June 23, 1995|By Matt O’Connor , Tribune Staff Writer.

Arthur Andersen & Co., which helps set up internal controls for companies to prevent employee theft and fraud, itself was victimized by a longtime employee who embezzled $2.3 million over five years, authorities alleged Thursday.

During 21 years with the Chicago-based firm, Raymond R. Parcon, 42, of Naperville, rose to become a tax manager in the firm’s U.S. Tax Group, from which position he engineered the clever scheme, according to charges filed in federal court.

Among his duties, Parcon had authority to issue checks to federal and state tax authorities to pay Andersen’s employee tax obligations, prosecutors said.

On repeated occasions between mid-1989 and early 1994, he falsified paperwork to make it appear sizable checks had been sent to the Internal Revenue Service and Illinois tax officials to cover the company’s withholding obligations, prosecutors said.

In reality, Parcon submitted those checks, sometimes for hundreds of thousands of dollars at a time as payments on his personal tax debt, and then claimed huge refunds from the IRS and the Illinois Department of Revenue, the charges alleged.

When the money was refunded to him, Parcon deposited the funds in his personal bank accounts, the government said.

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

Your Tax Accountant is Our Friend – A Natural Partnership

We do not

  • Prepare tax returns
  • Audit

We do

  • Government contracting compliance (to include helping with compliance audits)
  • Cost accounting

Often, small business government contractors require all of these services. The written tax code numbers in the thousands of pages as do the laws and regulations relevant to government contracting compliance. Few accountants make the attempt to keep up with both areas and even within larger accounting firms the specialties (tax and government contracting compliance) are split among different practitioners.

One of the many pleasures in our practice is working with the contractor’s tax accountant or bookkeeper. The contractor benefits by having access to two professionals with a bit of crossover for the same price. Two opinions in harmony, most of the time.

An Example

I flew in to support a contractor on an accounting system audit in conjunction with his tax accountant. DCAA showed up and we began one of the strangest audits in the almost thirty years of work in this area. If I told all of the story, DCAA would attempt to send my old unit from the 82nd Airborne after me, but I will tell part of it.

Toward the end of the rather strange audit, the DCAA auditor went on a rampage about small business contractors keeping their books on a cash basis.

This is not an unusual complaint made by some DCAA auditors, but I had never heard contractors referred to as idiots for the practices, especially in front of one of these “idiot” contractors.

I went on my usual contractor defense, explaining to the auditor the history of accrued accounting and the very classical utilization of the GAAP accounting cycle which allowed you to keep the books on a cash basis during the period and make the accruals as part of the closing process.

In this case, as in too many others, my purpose was to remind and educate the auditor not to rush to judgement and to expand their knowledge of the accounting world beyond the limited field of DCAA auditing. I sought to gently argue that the DCAA auditor’s strong comments were not only wrong but displayed a lack of knowledge on how accounting is actually practiced in the trenches.

The client’s tax accountant took a different approach, and I loved it.

He turned to the auditor and told him in no uncertain terms that the contractor kept his books on a cash basis because he, the tax accountant, recommend the contractor do so and that any small business owner that did not do so was an idiot and paying thousands of dollars in unnecessary taxes.

The room fell silent and I managed to keep a straight face as I backed the tax accountant up and said that not only was he correct, it was common sense, and allowed under GAAP as I previously outlined (cash converted to accrual during period close).

The DCAA auditor quickly packed up and left. I held my breath for a couple of days until DCAA approved the contractor’s accounting system, even though I knew that both the tax accountant and I made strong arguments in defense of the contractor’s practices.

This is simply one of the countless examples of where we worked hand in hand with the contractor’s tax accountant and/or bookkeeper to move the contractor’s business forward.

Indeed, many of our referrals actually come from the contractor’s outside accountant and I am happy to return the favor when one of my clients is seeking tax or audit work.

I will direct the reader to a previous article about cash v accrual accounting for the specific accounting arguments at

Both Books graphic




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

The Small Business Contractor


You know who you are. Yes, you, the one trying to figure out just when DCAA is going to enter your life, or worse, a non DCAA auditor or government official is assessing your operations and accounting system. Perhaps, just perhaps, you already had the pleasure and are reading this simply to improve the experience (read: “recover from disaster”).

Why You?

If You Want the Money

Federal regulations require an approved accounting system before the government can award a cost type contract.[1]

  • Cost type contracts are those contracts where the government reimburses the contractor for the contractor’s approved costs, director indirect, and sometimes a fee. The government recently expanded the definition to include fixed price contracts that allow for “progress payments”.
  • Cost contracts make up almost half of the contracts issued by the federal government and the majority of service contracts.

Two Presidents, Regan and Obama, started out their presidencies trying to reduce or even forbid government cost type contracts. In both cases, the number of cost type contracts actually grew.

There is a wealth of government created documents justifying the use of cost type contracts. Most of them center on the necessity of the government to assume the risks associated with the contract. Since cost type contracts are a reality, let me just make two observations and move on:

  • Cost type contracts require greater management and involvement on the government’s parts. They are involved in every aspect of the contract as opposed to simply writing a check upon delivery. DCAA has gone so far as to request from Congress in their annual report 24/7 access to contractor’s accounting systems. Greater government involvement translates into a larger number of government employees to manage an audit the process at all steps. In short, cost type contracts keep government employees ‘busy’ and ‘over worked’. DCAA continues to add new positons each of the last several years.
  • You hear about cost overruns and this is one of the ‘selling’ points for cost type contracts. If you run over budget the government will send you a check. It happens, but there is a lot of paperwork involved and a lot of compliance requirements. More often than not, the opposite happens and contractors do not make as much money on cost type contracts as they would on fixed price work. This translates into an excellent reason why the government likes cost type contracts – the actual amount paid to the contractor is reduced and paid to the bureaucrats instead in the form of salaries and other benefits (see point one).

One of the bizarre results of the crisis government contracting entered into in the year 2008, is the increased award of cost type contracts to small contractors without an approved accounting system despite the requirements forbidding this. It started out by contracting officers just ignoring the regulations in order to get the critical contracts issued, but now some of them are actually ‘approving’ the accounting systems after the contractor fills out a form.

Of course contractors may pay for this action by the contracting officers. Recent Armed Services Board of Contract Appeals (ASBCA) decisions that asserted that a lack of an approved accounting system was no defense for the contractor[2] and contractors with cost contracts and an unapproved accounting system appear to be holding all of the risks.

I am not telling contractors to turn down contracts, I am just pointing out issues for consideration.

Your solution may be as simple as taking the contract and making sure your accounting system is fully compliant in anticipation of the day DCAA or another auditor working for the government shows up.

The process of adopting and implementing an accounting system that would win government approval reduces the contractor’s risk and provides critical information to help them identify and manage costs.

Excerpt from Surviving a DCAA Audit available on Amazon 

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[1] FAR (16-301-3(a)(3)) “(3) The contractor’s accounting system is adequate for determining costs applicable to the contract or order…”


[2] ASBCA 56581 and 52593