The Many Hats of Small Business What to Wear When and Why

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2 The Many Hats of Small Business What to Wear When and Why Breakout Session # C06 Trish Corcoran, CFCM Johns Hopkins Applied Physics Lab Lisa Gough Surface Treatment Technologies, Inc. Monday, July 28, :00pm

3 Topics on the Hat Stand Challenges Policies and Procures Accounting and Audit Incurred Cost Provisional Billing Contract Mgmt. Subcontract Mgmt Invoicing Resources 3

4 So what HAT are you wearing today? Government? DCAA? DCMA? Industry? Large Business? Small Business? Less than 50 employees? 4

5 What s in this for me? While the Small Business contractor is the focus, there are some things that Large Business and the Government can learn: - An opportunity to see the other side when contracting with a small business - Understand the demands placed on a small business when contracting with the Government or Large Business (i.e. Reporting Requirements, Deliverables, Scheduling, Data Rights etc.) 5

6 So what challenges DOES a Small Business face? Government and Large Business have DEPARTMENTS to handle the various aspects of the business Small business contractors may only have ONE PERSON TO HANDLE EVERYTHING! 6

7 More challenges Working with large businesses as a subcontractor to the small business and the bane of your existence clause DFARS and FAR DATA RIGHTS Arduous reporting/deliverable requirements DCAA Audit Backlog Multiple sites to register and maintain to do business with the Government 7

8 Sampling of Sites to Register SAM WAWF SBA VETS100 EDA Access Dun & Bradstreet Joint Certification Program Grants.gov NSF Fastlane DoD SBIR/STTR Submission State/Local agency sites PASSING THE HAT AROUND: Make sure to comb through the solicitation/contract to make sure you are registered with any and all required sites. Make note to look for registration of OTHER sites within a site! 8

9 Key Skillsets Time Management Multi-Tasking Organization Search and Research Putting out fires and policing Patience Priority Scheduling Delegating Being Proactive Questioning and reasoning Communication Discipline The ability to say NO and the GUTS to ask for help! 9

10 The Tripod Accounting Technical 10

11 Policies and Procedures Get your P&P s in order! Write or update where needed Some areas to focus: Accounting Job costing Accounts Payable Accounts Receivable Billing Process General Ledger Postings Allowable and Unallowable Costs Allocable Costs 11

12 Policies and Procedures (cont d) Human Resources (minimally) Employee Handbook Time Keeping PASSING THE HAT AROUND: A key factor in audits is tracking time from person to timecard to payroll to job costing to invoicing. Create and maintain a P&P that provides explicit instructions on this task! 12

13 Policies and Procedures (cont d) 13

14 Policies and Procedures (cont d) Purchasing Track Direct purchases What determines if it is Direct or Overhead (allocability)? Log each PO number with internal charge number How does this flow to the Accounts Payable System? Accounts Payable Note internal job number on invoice Indicate General Ledger Direct COGS number Payment terms upon receipt of funds 14

15 Policies and Procedures (cont d) Direct Charge Bill Customer Requisition Purchasing Receipt of Goods Accounts Payable Pay Vendor PASSING THE HAT AROUND: At the onset of a requisition determine/know the exact nature of what you are purchasing. Have the party giving you the requisition provide you with the end use of the item, at least 2 sources to obtain the item and the applicable direct or indirect charge number. DON T GUESS! 15

16 Policies and Procedures (cont d) PASSING THE HAT AROUND: When writing your P&P s WATCH YOUR LANGUAGE! Be careful of terminology that can be misconstrued to mean something completely different than what you are trying to convey. Offer definitions and avoid using acronyms without identifying (identify it the first time, then use the acronym.) 16

17 Policies and Procedures (cont d) Used with permission by John Hart Studios I know you believe you understand what you think I said, but I m not sure you realize that what you heard is not what I meant. - Richard M. Nixon 17

18 more P&P s to write Access Control and Security Property Management (Yours and the Governments) Safety Government Accounting and Reporting Education and Enrichment Customer Service Program Management Business Management Finance Management 18

19 and STILL more P&P s Operations Sales and Marketing Shipping/Receiving Procedures Travel End of Month/End of Year General Ledger Postings Budgeting and Provisional Billing Rates Monitor Indirect Rates during the year Organization Chart Business meeting minutes 19

20 and STILL more P&P s Shareholders Bids & Proposals Outside Audit of Financial Statements Contract Briefs Etc., etc., etc. PASSING THE HAT AROUND: Once you have written a Procedure, have someone else read it and execute the instructions to make sure it is intelligible, comprehensive and accurate. Verify that the end result is achieved. Ask yourself If I died tomorrow, would someone else be able to come in and wear all these hats? 20

21 SWITCHING HATS Accounting and Audit and our good buddies at DCAA and DCMA 21

22 DCAA and DCMA - Get to know the key personnel - In the past they have been a very good resource - Go to them for guidance 22

23 DCAA and DCMA Relations Contractor Favorable Contractor Unfavorable 23

24 Accounting Among other things, your accounting system needs to: - track costs by job - pool like costs together (i.e Direct Costs, Fringe Benefits, Overhead, G&A, Unallowable costs etc.) - it must be adequate 24

25 Accounting and Audit How do I know if my accounting system is adequate? - If DCAA cannot recommend COTS accounting software products and - I have not had to submit an Incurred Cost Report and - I have yet to be audited - Where do I go? What do I do? Who will save me? 25

26 Some days it s like this 26

27 Accounting and Audit Help can be found in the following places DCAA Contractor Audit Manual (aka CAM) FAR Part 42 DCAA Audit Assist Mentors, NCMA Chapter members and your personal network of go to people! 27

28 Accounting and Audit From the DCAA CAM Audit Objectives The auditor's primary objective is to examine the contractor's cost representations, in whatever form they may be presented (such as interim and final public vouchers, progress payments, incurred cost proposals, termination claims and final overhead claims), and to express an opinion as to whether such incurred costs are reasonable, applicable to the contract, determined under generally accepted accounting principles and cost accounting standards applicable in the circumstances, and not prohibited by the contract, by statute or regulation, or by previous agreement with, or decision of, the contracting officer. In addition, the auditor must determine whether the accounting system remains adequate for subsequent cost determinations which may be required for current or future contracts. 28

29 Audit I wouldn t DARE say THAT to an auditor (Oh, but you can!) - Ok to tell them the timing is not optimal (i.e. Year end closing in progress, vacations, leave of absence, company/plant shut down etc.) - Ok to challenge their reasoning for allowability and/or allocability or not. - Ok to NOT give them every detail/document. Private companies are just that. Private. 29

30 Audit (cont d) Tips for the audit: - Get all of your P&P s in place before the audit is requested - Respond quickly to their requests once the audit is underway - Once underway, if you have not heard from them over a reasonable period of time, contact them to see if there is an issue. - At the entrance conference, give them a brief but detailed summation of WHAT your business does. 30

31 Audit (cont d) PASSING THE HAT AROUND: When an audit is underway, do everything you can to respond quickly, efficiently and appropriately to their requests. Lest you be deemed unresponsive and uncooperative. 31

32 Audit (cont d) PASSING THE HAT AROUND: DOCUMENT! DOCUMENT! DOCUMENT! 32

33 SWITCHING HATS ICE ICE BABY 33

34 Incurred Cost Proposal What on earth is this Alien-THING called ICE or Incurred Cost Proposal? 34

35 Incurred Cost Proposal Any contract that includes the FAR clause , Allowable Costs and Payment Clause, is required to submit an adequate cost proposal within six months of its fiscal year end. The incurred cost proposal is prepared by contractors to document its various indirect Overhead and General and Administrative (G&A) rates for its fiscal year. The Defense Contract Audit Agency ( DCAA ) will audit the Incurred Cost Proposal, if requested to by Contracting Officer ( CO ), and issue a report along with recommended rates to the requesting CO. Failure on the part of the contractor to submit an adequate incurred cost proposal in a timely fashion can result in some unexpected and generally unfavorable results. If the incurred cost proposal is six months overdue, the DCAA will provide a unilateral recommendation on rates or total contract costs to the CO. The CO could then establish final indirect rates based on the provisions included in FAR It would seem obvious that the rate recommended by the DCAA and unilaterally set by the CO would not favor the contractor. - By: Keith Romanowski 35

36 Incurred Cost Proposal The Allowable Cost And Payment clause (FAR ) requires that the contractor submit an adequate final incurred cost proposal together with supporting data, within 6 months after the end of its fiscal year. An illustration of a Model Incurred Cost Proposal is included in section of this pamphlet. The receipt of a proposal by the audit office starts the audit process. This proposal should include a signed "Certificate of Indirect Costs" in accordance with FAR A copy of this certificate may be found at FAR (See Schedule N of the model incurred cost proposal under section ) An adequate proposal should reduce the time required to perform the audit because numerous preliminary steps can be performed before the auditor arrives at the contractor location. 36

37 Incurred Cost Proposal Due 6 months after your company year end Download ICE template from Format the model to suit your company structure Give yourself ample time to complete. You need to have your General Ledger adjusting entries and Year-end entries complete! (Hint: there is a reason this is due 6 months after your year end!) 37

38 Incurred Cost Proposal (cont d) 38

39 Incurred Cost Proposal (cont d) ICE MANUAL INCURRED COST ELECTRONICALLY (ICE) (version 2.0.1c) Schedule Table of Contents \ Required Schedules Listed in Black (required if reflective of your accounting system) TABLE OF CONTENTS (Note - some schedules may not be visible depending on information provided on the Setup tab) SUPPORTING FLOWCHART SCHEDULE A SCHEDULE B SCHEDULE C(x) SCHEDULE D(x) Fringe SCHEDULE E SCHEDULE F SCHEDULE F-1 SCHEDULE G SCHEDULE G-1 Data Needed to Prepare ICE Schedules Flowchart of ICE_Model Workbook Showing Links Between Schedules Sched A - Summary of all Claimed Indirect Rates Generally no data entry is required on this schedule. All data is read from other schedules. Sched B - General and Administrative (G&A) Expenses (Final Indirect Cost Pool) Enter G&A Pool costs on this schedule. Sched C (1) thru Sched C (6) - Overhead Expenses (Final Indirect Cost Pool) Enter Overhead Pool costs on these schedule. ICE will support up to 5 overheads using direct labor as a base and 1 overhead using material as base. Sched D (1) thru Sched D (6) - Intermediate Indirect Cost Pool (ex. Occupancy) Enter Intermediate Pool costs on these schedule. ICE will support up to 6 intermediate pools. Fringe - This is a special-use schedule for allocating Fringe Cost (if applicable) Enter Fringe Pool costs and allocation bases on this schedule. Sched E - Claimed Allocation Bases by element of cost used to distribute indirect costs Generally no data entry is required on this schedule. All data is fed from other schedules. Sched F- Facilities Capital Cost of Money Factors Computation Data on this schedule is generally read from Sched F-1 however there is input required regarding interest rates. Sched F-1- Computation of Average Net Book Values for COM (optional) Enter asset value detail to be used in the computation of Cost of Money Sched G - Reconciliation of Books of Account and Claimed Direct Costs by major cost element Sched G-1- Reconciliation of Claimed Direct Costs to JCL (optional) 39

40 Incurred Cost Proposal (cont d) Model Incurred Cost Proposal Required Schedules Listed in Black Summary Sched H SCHEDULE H SCHEDULE I SCHEDULE J SCHEDULE K SCHEDULE L SCHEDULE M SCHEDULE N SCHEDULE O Summary Sched H - Direct Contract/Subcontract Costs/IR&D/B&P SUMMARIZES SCHEDULE H DIRECT COSTS AND LINKS TO OTHER SCHEDULES Schedule of Direct Costs by Contract/Subcontract and Indirect Expense Applied At Claimed Rates as well as a subsidiary schedule of Government participation percentage in each of the allocation base amounts Sched I- Schedule of Cumulative Direct and Indirect Costs Claimed and Billed by Contract and Subcontract Sched J- Subcontract Information Sched K- Summary of each time-and-materials and labor-hours contract's information including labor categories, labor rates, hours, costs and indirect expense applied at claimed rates Sched L- Reconciliation of Total Payroll per IRS Form 941 to Total Labor Costs Distribution Schedule M- Listing of Decisions/Agreements/Approvals and Description of Accounting/Organization Changes Schedule N- Certificate of Final Indirect Costs Schedule O- Contract Closing Information for Contracts Completed in this Fiscal Year (include contract number, period of performance, contract ceiling amounts, contract fee computations, level of effort, and indicate if the contract is ready to close). 40

41 Incurred Cost Proposal (cont d) Model Incurred Cost Proposal Supplemental Schedules SUPPLEMENTAL A-1 SUPPLEMENTAL A-2 SUPPLEMENTAL A-3 SUPPLEMENTAL A-4 SUPPLEMENTAL B SUPPLEMENTAL C SUPPLEMENTAL O A-1 - Comparative Analysis of Indirect Expense Pools Detailed by Account to Prior Fiscal Year and Budgetary Data - Overhead Expenses A-2 - Comparative Analysis of Indirect Expense Pools Detailed by Account to Prior Fiscal Year and Budgetary Data -G & A Expenses A-3 - Comparative Analysis of Indirect Expense Pools Detailed by Account to Prior Fiscal Year and Budgetary Data - Occupancy Expenses A-4 - Comparative Analysis of Indirect Expense Pools Detailed by Account to Prior Fiscal Year and Budgetary Data - Direct Costs B - General Organizational Information and Executive Compensation for the Five Most Highly Compensated Executives C - Identification of Prime Contracts Under Which the Contractor Performs as a Subcontractor O - Contract Briefings 41

42 Incurred Cost Proposal (cont d) ICE MANUAL 1 Data and Records Needed to Prepare ICE Schedules General Ledger for FY and Prior FY (Refer to Schedules B/C/D/G/G 1/A 1/A 2/A 3/A 4) Cost Element Breakdown of Cost Type, Other Flexibly Priced, T&M, Firm Fixed Price and Commercial Contracts (Refer to Schedule H) Job Cost Ledger (JCL) for Fiscal Years (FY) submitted should reconcile to G/L (Refer to Schedule G 1) Hours and Amounts Billed on T&M Contracts (Refer to Schedule K) Financial Statements for FY and Prior FY (Refer to Schedules B/C/D/G/G 1/A 1/A 2/A 3/A 4) 941 Quarterly Payroll Tax Returns for FY submitted (Refer to Schedule L) Federal Tax Returns for FY submitted Copies of Documents used to Brief Cost Type and Flexibly Priced contracts (See Appendix 2, and Refer to Schedule O) Decisions/Accounting and Organizational Changes (Refer to Schedule M) Written Policies and Procedures on identifying and segregating unallowable costs (Refer to Accounting Manual) If Applicable, FY and Prior FY Net Book Value of Assets, for Cost of Money Computation (Refer to Schedule F & F 1) Schedule of IR&D/B&P Projects if Applicable Cumulative Billing and Contract Closing Information (Refer to Schedules I & O) Documentation to Support Submission Adjustments Reconciliation of claim to tax return Government Participation in Indirect Cost Pools (Refer to Schedule H (Cont)) 2 Data Files Needed for ICE Schedules Accounting System Data Files Converted to Excel or ASCII format. Schedule of Direct Costs by Contract General Ledger/Trial Balance (Showing Chart of Accounts, Account Descriptions, and Account Balances 42

43 Incurred Cost Proposal (cont d) PASSING THE HAT AROUND: Contract briefs (SCH O), keep a paper copy in your file and note any mods or changes to the contract there. This will make for easier preparation/update of the SCH O in the Incurred Cost Proposal. 43

44 Incurred Cost Proposal (cont d) PASSING THE HAT AROUND: Download the model long before you need it. The formulas may not be accurate and you WILL NEED to tweak it to suit your business/accounting system/operations. PASSING THE HAT AROUND: The ICE model is a TOOL to HELP you generate your submission. PASSING THE HAT AROUND: Adequacy checklist print it, follow it, review it before submission of the ICE. 44

45 Provisional Billing Rates FAR Provisional rate or billing rate is an established temporary indirect rate applicable to a specified period (fiscal year) for the purpose of allowing interim reimbursement of incurred indirect costs In addition to preparing the annual budget for the company, it will be necessary to prepare Provisional rates. Creating a budget of the upcoming year is critical to help a new and emerging company plan and help establish the direction in which it is going. Adequacy checklist print it, follow it, review it before submission of the Provisional Billing Rate letter. 45

46 Provisional Billing Rates PASSING THE HAT AROUND: After a few years, you may see that your rates will become fairly consistent. Use your prior year Incurred Cost submission as a basis for the next year. Apply any known adjustments and use that as your Provisional Billing Rates.don t reinvent the wheel! 46

47 Other tips PASSING THE HAT AROUND: Keep a calendar (wall calendars work great!) of all due dates for reports, taxes, recertifications, password reset due dates etc. PASSING THE HAT AROUND: Review and update if necessary on an annual basis your Policies and Procedures. Schedule this for a non critical time of the year. (i.e. when ICE has already been submitted, you are not preparing for the year end, and no major company event is about to occur.) 47

48 DCAA Resources 48

49 SWITCHING HATS Contract Management 49

50 Contract Award BEFORE YOU SIGN: READ and UNDERSTAND your contract!! If you do not understand something ASK FOR CLARIFICATION! 50

51 Contract Award For example: Are there undefined acronyms? The contract has a DPAS rating. What is DPAS? Are there reporting requirements not specifically stated as deliverables in the SOW? Are there requirements for subcontracting? Do you understand the order of precedence? 51

52 Contract Award BEFORE YOU SIGN: Make sure the requirements upon which your proposal is based have not changed and are consistent with the solicitation or with what was proposed and priced If any requirements have changed make sure you have a thorough understanding of the impact to your organization and you can deliver at the price awarded, otherwise 52

53 Contract Award NEGOTIATE! Anything is Negotiable! It s OK to negotiate changes to: the period of performance supplies or services, LOE SOW and/or Specifications Deliverables and reporting requirements Contract clauses and special contract requirements, etc. 53

54 Contract Management Contract Files and Record Retention What should be in your contract files? FAR 4.8 lists the Government s requirements What records should be retained and for how long? FAR lists the various records that need to be retained and for how long. A general rule to keep in mind is 3 to 6 YRS AFTER FINAL PAYMENT 54

55 Contract Management Document 55 Retention Period (1) Records pertaining to Contract Disputes statute actions. 6 years and 3 months after final action or decision for files created prior to October 1, year after final action or decision for files created on or after October 1, (2) Contracts (and related records or documents, including successful proposals) exceeding the simplified acquisition threshold for other than construction. (3) Contracts (and related records or documents, including successful proposals) at or below the simplified acquisition threshold for other than construction. (4) Construction contracts: (i) Above $2,000. (ii) $2,000 or less. (iii) Related records or documents, including successful proposals, except for contractor's payrolls (see (b)(4)(iv)). (iv) Contractor's payrolls submitted in accordance with Department of Labor regulations, with related certifications, anti-kickback affidavits, and other related papers. (5) Solicited and unsolicited unsuccessful offers, quotations, bids, and proposals:. (i) Relating to contracts above the simplified acquisition threshold. (ii) Relating to contracts at or below the simplified acquisition threshold. 6 years and 3 months after final payment. 3 years after final payment. 6 years and 3 months after final payment. 3 years after final payment. Same as contract file. (6) Files for canceled solicitations. 5 years after cancellation. (7) Other copies of procurement file records used by component elements of a contracting office for administrative purposes. 3 years after contract completion unless contract performance is the subject of an enforcement action on that date. If filed separately from contract file, until contract is completed. Otherwise, the same as related contract file. 1 year after date of award or until final payment, whichever is later. Upon termination or completion. (8) Documents pertaining generally to the contractor as described at 4.801(c)(3). Until superseded or obsolete. (9) Data submitted to the Federal Procurement Data System (FPDS). Electronic data file maintained by fiscal year, containing unclassified records of all procurements other than simplified acquisitions, and information required under years after submittal to FPDS. (10) Investigations, cases pending or in litigation (including protests), or similar matters. Until final clearance or settlement, or, if related to a document identified in (b)(1) - (9), for the retention period specified for the related document, whichever is later.

56 SWITCHING HATS Subcontract Management 56

57 Subcontract Management What or who is a subcontractor? Subcontractor means any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor. (FAR ) 57

58 Subcontract Management Creating/Writing the Subcontract - One or More Documents? Advantages and Disadvantages Create a library of documents that can be pulled together for each new award based on contract type All general terms and conditions that are common to every subcontract regardless of type can be in one document Create a set of General Schedule items specific to each contract type Flowdowns can be a separate document and can be tailored to the contract type and ceiling value. 58

59 Subcontract Management Terms and Conditions Should be specific to: The work to be performed, The contract type, The risk associated with the work Include flowdowns from the prime contract 59

60 Subcontract Management Lead Party Interface Lead Party Interface clause is a business decision mechanism your company may want to include in your Other clauses to your subcontractors/consultants. It provides you control of who talks to who. 60

61 Subcontract Management Sample Lead Party Interface clause (Prime Contractor Name) shall be the interface with (Your Customer Name), the customer, and shall coordinate all activities related to the subcontract. If communications are initiated by (Your Customer Name) directly with (Your Subcontractor/Consultant) or its personnel, (Your Subcontractor/Consultant) will coordinate with (Prime Contractor Name) prior to answering such communications. No technical direction shall be taken from (Your Customer Name), without prior approval from the (Prime Contractor Name) Technical POC (Or other POC). (Prime Contractor Name) shall not be liable for work performed at the direction of (Prime Contractor Name). Further,(Your Subcontractor/Consultant) or its personnel, shall not contact (Your Customer Name) directly without the express consent of (Prime Contractor Name). 61

62 Subcontract Management Flowdowns Mandatory: Clauses required by law, the FAR or company policy Desired: Clauses that are not required by any of the above but make good business sense 62

63 Subcontract Management Statements of Work Statements of Objectives Deliverables Each subcontract should contain either a Statement of Work (SOW) that clearly describes the work to be performed, specific deliverables and timelines; or a Statement of Objectives (SOO) that describes the outcomes/deliverables desired and specific timelines. 63

64 SWITCHING HATS Invoicing 64

65 Invoicing Invoices for a prime contract or a subcontract should only include allowable costs per FAR and should comply with the terms of the contract. 65

66 Invoicing - the False Claims Act (FCA) 31 U.S.C types of conduct that result in FCA liability Penalties Civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of the damages which the Government sustains because of the act of that person (and no less than 2 times the damages) A person committing these violations shall also be liable for the costs of the civil action brought to recover any penalties or damages. 66

67 Invoicing - WAWF 67

68 Invoicing - WAWF What is WAWF? Wide Area Workflow (WAWF) is a secure Web-based system for electronic invoicing, receipt and acceptance. WAWF creates a virtual folder to combine the three documents required to pay a Vendor - the Contract, the Invoice, and the Receiving Report. The WAWF application enables electronic form submission of Invoices, government inspection, and acceptance documents. 68

69 Managing and Monitoring Your Subcontractors The prime contractor must manage the subcontract effort in all phases of the subcontract to include pricing, administration and performance. FAR Subcontractor Responsibility FAR 44.2 Consent to Subcontract FAR 44.3 Contractor s Purchasing System Reviews 69

70 Insurance What is required by the prime contract? What risks are associated with performing the work? What is required for compliance with the corporate policies of the prime contractor or the subcontractor? Certificates of Insurance 70

71 Data Rights FAR and DFARS In order to protect your proprietary data you should understand the data rights clauses in the FAR and DFARS Whenever a contractor is using or providing technical data or computer software that was developed fully or partially at private expense data rights should be asserted in the proposal phase of the acquisition to protect the ownership of that data or software. 71

72 SWITCHING HATS Feathers for your cap 72

73 Feathers for Your Cap Build Relationships to Build Your Business COs (KOs) COTRs OSDBUs Small Business Liaison Offices at Large Businesses Mentor/Protégé Programs Professional Organizations 73

74 Feathers for Your Cap Build Relationships to Build Your Business Develop Future Partners Board of Directors Board of Advisors LinkedIn Facebook Alumni, Fraternity or Sorority Associations 74

75 Feathers for Your Cap Join or attend events at professional societies NCMA APMP Association of Proposal Manager Professionals ISM - Institute for Supply Management GWSCPA -Greater Washington Society of CPAs PMI Project Management Institute 75

76 Feathers for Your Cap NETWORK! NETWORK! NETWORK! 76

77 SWITCHING HATS and Pins in your Hat Box 77

78 Pins in your Hatbox Federal Acquisition Regulations: FAR Agency Supplements: DCAA Contract Audit Manual (CAM): DCAA Information for Contractors: DCAA ICE (Incurred Cost Electronically): Various tools and templates: 78

79 Pins in your Hatbox DCAA Assist Requirements for adequate Acconting Systems DCAA Incurred Cost Submissions Presentation issions.pdf SBIR/STTR (Small Business Innovation Research/Small Business Technology Transfer: DCMA, Estimating System Review and Contractor Purchasing System Review (CPSR): 79

80 Pins in your Hatbox DCMA Instruction regarding Contractor Purchasing System Reviews: INST-109.pdf DPAS Ratings: CFR (Code of Federal Regulations): Defense Base Act, Longshore and Harbor Worker s Compensation and War Hazard s Compensation Act: 80

81 AT THE END OF THE DAY. THE ONLY HATS THAT MATTER ARE THESE 81

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83 QUESTIONS? 83

84 Our hats off to you! Thank you for your attention and participation! Enjoy the remainder of the conference! Trish Corcoran Lisa Gough Check us out on LinkedIn! Free State Chapter 84