My management consulting firm is growing, and we recently won a prime task order for federal work under NAICS 541611, which put us over the $350,000 simplified acquisition threshold. We expect a DCAA audit of our accounting system sometime this year. We have heard that DCAA looks for specific system capabilities, especially for cost-reimbursement contracts. Our current system works for firm-fixed-price contracts, but we are looking at cost-plus contracts now. I want to make sure we are ready. What steps should a small business take to prepare for a DCAA audit of its accounting system, particularly when moving into cost-reimbursement work?
What steps should a small business take to prepare for a DCAA audit of its accounting system?
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To prepare for a DCAA audit, a small business should ensure its accounting system can track costs by contract line item and segregate direct from indirect costs, which is critical for cost-reimbursement contracts. DCAA looks for systems that comply with FAR Part 31, which covers contract cost principles and procedures. Your system needs to be able to accumulate costs by contract, job, or task, and distinguish between unallowable and allowable costs. For cost-reimbursement contracts, you must have a system that reliably accumulates and reports costs for invoicing and audit. This means being able to track labor, materials, and other direct costs to specific contracts, and then allocating indirect costs like overhead and general and administrative expenses consistently. Many small businesses find their initial accounting systems are not robust enough for the detailed tracking and reporting required for these contract types.