A CASB Disclosure Statement is a form whereby a US Government Contractor discloses its cost accounting practices, for which it is required to demonstrate CAS compliance for the life of its active CAS (Cost Accounting Standards) covered awards. The CASB Disclosure Statement, otherwise known as DS-1, has a very rigid format with eight different parts: […]
DFARS Business System Reviews
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RKI provides a variety of services with regards to a contractor’s cost estimating practices including:
- Design of a compliant DFARS Estimating System including policies, procedures, standardized forms, and training
- Evaluation of a contractor’s Estimating business system for compliance
- Remediation and/or corrective action of deficiencies resulting from DCAA or internal management findings
- Preparation of cost proposals in accordance with DFARS Estimating System requirements
- Other services related to best practice estimating in U.S. Government contracting
DFARS Services
Our team is skilled and experienced in navigating DFARS awards and the potential pitfalls that come with them.
Accounting
RKI routinely performs pre-award and post award accounting system evaluations. Our reports identify significant deficiencies, material weaknesses, and areas for process improvement. Clients most frequently ask for these to satisfy management and/or internal audit interests or have us perform them so that they may use our report as part of a proposal package to demonstrate to the U.S. Government or prime contractor that they have an adequate accounting system suitable to for the award of a contract or subcontract.
MMAS
RKI can perform reviews of your Material Management and Accounting System to determine compliance with defined critera and assit with appropirate remediation plans, as necessary, in managing a compliant system.
CPSR
RKI can perform reviews of your Purchasing System Administration to prepare your organization for a formal Contractor Purchasing System Review (CPSR). We will analyze your system(s) for purchasing and subcontracitng, including make-or-by decisions, the selection of vendors, analysis of quoted prices, and much more, against Purchasing system requirements.
USG Property
RKI can preform reviews of your Property Management System to determine compliance with obtaining, handling, and discarding of USG Property covered under contract. We can assit with appropriate remeidations plans, as necessary, in managing a compliant system, and avoiding "significant deficiencies".
EVMS
RKI can perform reviews of your Earned Value Management System to determine compliance with defined critera and assit with appropirate remediation plans, as necessary, in managing a compliant system.
DFARS Frequently Asked Questions
Our team is skilled and experienced in navigating DFARS, Cost estimating, and associated issues.
Requirements of your accounting system for U.S. Government contracts differ between contract-types. Not all contracts, and hence contractors, require the same level of accounting system capabilities. Per FAR 16.103, “Before agreeing on a contract type other than firm-fixed-price, the contracting officer shall ensure that the contractor’s accounting system will permit timely development of all necessary cost data in the form required by the proposed contract type.” Translated, this means that Contracting Officers must satisfy themselves that a contractor’s accounting system can meet the contract vehicle’s needs to protect the U.S. Government financial interests. In its simplest sense, any contractor performing work under cost-type contracts including Cost Plus Fixed Fee (CPFF) and Time and Materials (T&M) will be required to have an adequate accounting system, as determined by DCAA.
Prior to award of applicable contracts and after award of that contract. The Defense Contract Audit Agency (DCAA) audits your accounting for adequacy prior to award during a pre-award accounting system audit focused on the design of your accounting system and post award accounting system audit focused on the operating effectiveness of your accounting system including reviews of labor charging, project cost accumulation, indirect cost rate methodology, invoicing, and similar. Not having an adequate accounting system is a barrier to entry for a contractor looking to be awarded a cost-type contract.
What Are the Accounting System Requirements?
While a Contracting Officer must satisfy itself that an accounting system meets the requirements of its contract-type, generally there are 2 sets of Accounting System requirements contractors are held to:
1. Pre-Award Accounting System criteria (SF-1408) (Link:
2. Post-Award Accounting System criteria (DFARS 252.244-7001 https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration)
While a Contracting Officer must satisfy itself that an accounting system meets the requirements of its contract-type, generally there are 2 sets of Accounting System requirements contractors are held to:
1. Pre-Award Accounting System criteria (SF-1408) (Link:
2. Post-Award Accounting System criteria (DFARS 252.244-7001 https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration)
While formally defined at DFARS 252.215-7002 (Cost Estimating System Requirements), its intention is provide consistent and reliable cost estimating practices for preparation and negotiation of fair and reasonable prices with the U.S. Government. It focuses primarily on those proposals subject to certified cost or pricing (e.g, Truthful Cost or Pricing, Truth in Negotiations, TINA). The DFARS Estimating business system clause provides the applicable criteria to which a U.S. Government contractor is held during a Estimating System review.
Yes, if you have contracts subject to certified cost or pricing. While DFARS provisions are specific to DoD contractors, DCAA and other U.S. Government audit interests have designed their audit programs around the DFARS criteria. As a result, even if you’re not “required” to comply with the DFARS Estimating business system criteria, they are the criteria to which you would be held under most U.S. Government audits on cost proposals and estimating system reviews.
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