DoD SBIR Accounting System Requirements : High Expectations
We started this series off with:
- Is your organization eligible for a DoD SBIR
- Registration requirement to participate in DoD SBIR
- DoD SBIR Grant Process: What do you give up?
The Department of Defense (DoD) expects a higher level of small business accounting sophistication between Phase I and Phase II. With Phase I DoD SBIR or STTR awards, the Federal government usually expects the small business to have a basic system due to the low dollar amount. For a potentially 10-fold increase in dollars, Phase II contracting officers need to be confident that you have, among other things, accurately estimated your indirect rate. The ability to calculate an accurate indirect rate comes from a good accounting system that differentiates direct from indirect costs while also isolating unallowable costs. It is suggested that companies interested in pursuing Phase II SBIR contracts and other contracts of similar size with the DoD have an adequate accounting system per General Accepted Accounting Principles (GAAP), Generally Accepted Government Auditing Standards (GAGAS), Federal Acquisition Regulation (FAR) and Cost Accounting Standards (CAS) in place.
The accounting system can be audited by the Defense Contract Audit Agency (DCAA). DCAA’s requirements and standards are available on their Website at: http://www.dcaa.mil and click on “Guidance” and then click on “Audit Process Overview – Information for Contractors,” and also at: http://www.dcaa.mil and click on “Checklists and Tools” and then click on “Pre-award Accounting System Adequacy Checklist”.
The general acceptable accounting system your organization uses must provide reasonable assurance that it is:
- Compliant with the applicable laws and regulations
- At minimal risk for misallocations and mischarges
- Consistent for billing procedures in respect to contract allocations and charges
More specifically your system should:
- Segregate Direct and Indirect Costs
- Accumulate all costs under the general ledger
- Have a time keeping system and accurately charge direct and indirect labor correctly
- Provide for at least monthly determination of costs charged to the contract
- Identify and segregate unallowable costs
- Identify costs by Contract Line Item (CLIN)
- Provide reliable date for pricing follow-on acquisitions
Learn more about DoD SBIR Grant Writer Mr. Bard
To go back to Post#3 in this series DoD SBIR Grant Process: What do you give up? click HERE.