Archive for September, 2009

DCAA Audits – Deficient once Again

Wednesday, September 30th, 2009

The latest report on DCAA by the General Accounting Office (GAO) released September 2009 entitled “Widespread Problems with Audit Quality Require Significant Reform” marks an embarrassing moment for DCAA. The GAO found audit quality problems at DCAA offices nationwide including; compromise of auditor independence, insufficient audit testing, and inadequate planning and supervision.Here are just a few of the highlights:

• DCAA auditors spent 530 hours to support an audit of a non-existent billing system and reported adequate controls
• On another billing system audit an auditor told GAO he did not perform detailed tests because “the contractor would not appreciate it”
• On an accounting system audit, the supervisory auditors directed audit staff to delete some audit documents, generate others, and in one case, copy the signature of a prior supervisor onto new documents making it appear that the prior supervisor had approved a revised risk assessment. The supervisor who approved the altered documents was later promoted.

In total DCAA rescinded 80 audits cited in the last two GAO reports. (more…)

OMB Launches Compliance Website to Aid Small Businesses

Friday, September 25th, 2009

The Office and Management and Budget has established a website designed to provide compliance related assistance to small businesses.  The website offers a variety of information and links to include (1) compliance points of contact at virtually every federal agency, (2) a mechanism for complaining about unfair compliance enforcement, (3) a list of organizations that provide “in-person” support to small businesses, and (4) subject matter links addressing virtually all aspects of legal and regulatory compliance.  All small businesses should continually monitor this blog, and bookmark the compliance website, as both are great “go to” resources for any compliance questions.

Aronson & Company’s Government Contract Services Group is continually monitoring the oversight-laden, compliance-driven federal marketplace.  To ensure that A&C clients understand the requirements and are doing what they need to stay compliant, Aronson offers a GovCon Compliance Checkup.  Contact Hope Lane for more information about this new service, (301) 231-6266 or hlane@aronsoncompany.com.

In Search Of The Lost Opportunity

Friday, September 25th, 2009

With the government fiscal year winding down toward the end of this month, we took a look at the sheer number of solicitations by document type released by the federal government this calendar year. No doubt, folks find it hard sifting through myriads of text to locate the right opportunity.

There were a total of 6 solicitation document types, 3 of them making up close to 98% of all opportunities. As of this writing, the 3 opportunity document types were broken down as follows:

• 52,399 presolicitations
• 48,818 Combined Solicitations
• 9614 Sources Sought Notices

Our detailed analysis for the Top 10 NAICS category in each of those categories can be downloaded as a spreadsheet at this link:

For further details and other new reports such as this one, go to www.fedmine.us or email amehan@fedmine.us.

$4 Billion IT Opportunity Coming Soon as NASA Consolidates IT and Data Services

Wednesday, September 23rd, 2009

NASA’s Information Technology Infrastructure Integration Program will procure services to provide agency-wide management, integration, and delivery of IT infrastructure services.  NASA will release the first of five RFPs as soon as September 22, 2009. The five contracts that NASA plans to compete are: (1) Agency Consolidated End User Services (ACES) contract, (2) Enterprise Applications Service Technologies (EAST) contract, (3) NASA Enterprise Data Center (NEDC) contract, (4) NASA Integrated Communications Services (NICS) contract, and (5) Web Enterprise Service Technologies (WEST) contract. Additional details follow. (more…)

Is your written code of conduct ready for DCAA Audit?

Tuesday, September 22nd, 2009

Defense Contract Audit Agency (DCAA) Accounting System Control Audits incorporate the new Federal Acquisition Regulation (FAR) Ethics Rules.  DCAA issued open audit guidance 09-PAS-014(R) incorporating the new Federal Acquisition Regulation (FAR) Ethics Rules in late July 2009. The guidance incorporates the new FAR Ethics requirements into DCAA System Control Audits. It requires auditors to incorporate procedures to address the requirements in FAR 52.203-13, Contractor Code of Business Ethics and FAR 52.203-14, Display of Hotline Poster. (See more on the Contractor Code of Business Ethics Final Rule in our previous posting).

The additional procedures included in the updated audit work programs include:

1. Verification of the existence of a written code of conduct.
2. Review the code of conduct to ensure it addresses the following:
   a. Ethical business practices
   b. Conflicts of interest
   c. Expected standards of ethical and moral behavior
   d. Indication that the code covers dealings with customers, suppliers, employees, and other parties.
3. Verification that written codes of conduct are periodically communicated to all employees, formally acknowledged and cite consequences for violations.
4. Verification of the Display of Hotline Posters
5. Verification that the manager responsible for the ethics program reports to a high level official (vice president/CFO)
6. Verification that the contractor performs periodic reviews of company business practices, procedures, and internal controls for compliance with the contractor’s code of business ethics and conduct and special requirements of Government contracting.

And much more…..Is your organization’s Ethics program ready to stand the DCAA audit test?

Please contact Nicole Mitchell (301.222.8231) or Thomas Marcinko (301.231.6237) to assist your organization in preparation and implementation of an Ethics program compliant with current FAR regulations.

Revised Form I-9 Now Expires in 2012

Monday, September 21st, 2009

U.S. Citizenship and Immigration Services (USCIS) recently issued an updated version of the Employment Eligibility Verification form known as Form I-9. The old form was amended with a new revision date of Aug. 7, 2009, and is now set to expire Aug. 31, 2012. It contains no substantive changes, according to Jackson Lewis’ Global Immigration practice. Employers can still use the I-9 form with the revised date of Aug. 7, 2009, or Feb. 2, 2009, for all new hires and re-verifications, according to the USCIS web site. The revision dates are located on the bottom right-hand portion of the form; the expiration date is on the top right-hand portion. Employers do not need to fill out new forms for current employees.

Click here to obtain the revised I-9 form or visit the USCIS web site. Employers that do not have computer access can order the Form I-9 by calling the toll-free forms line at (800) 870-3676. (Source: Society for Human Resource Management)

Most Popular Contract Vehicles For FY2010 Procurements

Wednesday, September 16th, 2009

A recent annual government buying survey completed by by the 1105 Government Information Group asked its respondents to identify what type of contract vehicles they intended to use for FY2010 procurements.

 Survey says (top 10):

1. GSA SmartBuy - 34 percent
2. GSA Schedule 70 – 31 percent
3. GSA 8(a) STARS – 16 percent
4. Army ITES-2S — 15 percent
5. GSA Networx – 13 percent
6. DISA I-Assure – 13 percent
7. DOD Enterprise Software Initiatives – 13 percent
8. GSA Alliant Small Business – 12 percent
9. GSA Millenia/Millenia Lite/Alliant – 12 percent
10. Army ADMC-2 – 12 percent

VETS-100/100A Reporting Reporting Due Sept 30th – Get ready for Gov’t Year-End!

Tuesday, September 15th, 2009

Contractors with government contracts entered into or modified on or after December 1, 2003, worth $100,000 or more are required to file the VETS-100A by September 30, 2009.  This requirement includes GSA Schedule contracts. The VETS-100/100A reporting cycle begins annually on August 1 and ends September 30. The U.S. Department of Labor’s Veterans’ Employment and Training Service (VETS) annually collects and compiles the Federal Contractor Veterans’ Employment Report (VETS-100) from federal contractors and subcontractors who receive federal contracts that meet the threshold amount of $25,000 or more prior to December 1, 2003, or $100,000 on or after December 1, 2003. Companies are encouraged to submit reports online; however, reports that are mailed or submitted on a properly formatted CD or disk are still acceptable. (Source: Society for Human Resource Management)

VETS-100/100A Resources (more…)

E-Verify is Finally Here

Thursday, September 10th, 2009

Most Government contractors receiving contracts on or after September 8, 2009 will be required to use the Government’s E-Verify system to verify the employment eligibility of their employees.  E-Verify will not be required for contracts less than $100,000 or to be performed overseas or for COTS products.  E-Verify must be flowed down to subcontracts valued at $3,000 or above.  Contractors subject to the E-Verify requirement must begin using the system to verify the employment status of all new hires and any existing employees assigned to work on that contract.  Generally, contractors will have 30 days from contract award to enroll in E-Verify and another 90 days to begin verifying employment status.  Less time is allotted if the contractor is already enrolled in E-Verify.

 The Department of Homeland Security is conducting series of E-Verify webinars.  The webinar advertisement may be accessed at the following link.

Is Your Back Office Ready for Stimulus Opportunities? Learn more on Sept 16th.

Wednesday, September 9th, 2009

Be aware that your accounting system is likely to be subject to pre-award and annual audits from DCAA and other agencies if your company is planning on capitalizing on stimulus money by moving into the government sales arena. Join Aronson & Company on September 16th to learn more about the specialized accounting rules and procedures that your organization will be required to comply with. Topics at this event will include:

• Proper segregation of direct cost from indirect costs
• Identification and accumulation of direct costs by contract
• Allocation of indirect costs to intermediate and final cost objections
• Timekeeping systems that identify employees’ labor by intermediate and final cost objections

The stimulus package has created a myriad of opportunities for committed and well-prepared organizations, so make sure you don’t overlook this important part of doing business with the government. RSVP today!