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Calendar Year End Prep for Government Contractors

The end of 2022 is fast approaching, and there’s a lot of work to be done to make sure everything is wrapped up nicely for 2023. The better you’re able to get things in order now, the less catch-up you’ll have to play next year.

In this article, we’ll talk about some things you can do to get ahead of the game and be prepared for a successful next year.

First Thing First – Take a Moment to Breathe and Reflect

It’s hard to believe that the clock is just about to turn to 2023. To be honest, we’re still processing 2020. But here you are, ready to turn the page onto another year and start fresh to make these coming months your most successful yet.

Take a moment to reflect on this past year. What were your biggest wins? Did you land some contracts that really elevated your business? Dig into your successes and analyze what you did that worked, and what you could do better. Be as honest as you can about your failures as well as your wins, and take a long, good look at how you could have done things more efficiently, professionally, and successfully.

Experience is one of the most powerful tools in government contracting, so make sure you’re getting the most out of yours while looking ahead to the new year.

Know Your Deadlines

Government contracting is a very deadline driven industry, so it’s important to have your due dates and requirements written down somewhere in an easily accessible format. You don’t want to be scrambling at the last minute or miss out on contracts because of a poorly organized system.

Perform a Cash Flow Analysis

It’s important to have a good idea of how much money you’ve got coming in and where you sit financially before planning ahead. Analyze your cash flow so that you can prepare a budget and know where you’re at going into the end of the year.

One way to go about this is to track your cash in and your expenses on a monthly basis. This will give you a good idea of where your money is going and what areas you can cut back on.

If your CFO is up to their neck in work, you can use a consultant to help you with your analysis while saving your own staff time for more pressing things. This is also a good idea if you’re not sure where to start or if your financial situation is more complex. At BOOST, we can help you get a clear picture of your financial situation heading into the new year.

The bottom line is that you want to ensure that you’re using your cash as efficiently as possible for your business objectives and goals, tax planning, and capital injection needs. Having a clear view of your cash flow will help you accomplish that.

Plan Your Company’s Budget for the Next Calendar Year

Once you have a good handle on your cash flow, it’s time to start preparing a budget for the next calendar year.

There are a few things to keep in mind when doing this:

-Your company’s overall financial goals

-What worked and didn’t work in the current year’s budget

-Changes in the market or industry that could impact your company’s finances

-Any big projects or initiatives that will be taking place in the next year

It’s also a good idea to get input from your senior leadership when putting together the budget for next year. They may have ideas of where money can be saved or areas where they’d like to see more investment. You should also select a budgeting process that fits your way of doing things, i.e. a bottom up vs. top down process, etc. 

Prep for 2022 Taxes

Before doing anything, know that you’ll want to work closely with your CFO and your tax accountant when doing your tax prep. They’ll be able to help you figure out what deductions and credits you’re eligible for, as well as give you an estimate of how much you’ll owe.

The first step is to get your books in order. This means making sure all of your expenses are accounted for and that your revenue is accurate. You’ll also want to make sure you have all of the relevant documentation for your expenses. This can include receipts, invoices, and bank statements.

Getting your books in shape will go a long way towards making tax time less stressful. You’ll have everything you need and you won’t be scrambling to find documentation at the last minute.

The next step is to start thinking about deductions and credits. There are a lot of different deductions and credits that businesses can take advantage of, so it’s important to do your research and figure out which ones apply to you.

Your tax accountant will be able to help you with this, but it’s a good idea to have an idea of what’s available. That way, you can make sure you’re taking advantage of everything you’re eligible for.

Some common business deductions include:

-Office expenses

-Travel expenses

-Employee benefits

-Business insurance

-Interest on business loans

There are also a number of different tax credits that businesses can take advantage of. These can include credits for hiring employees, investing in research and development, and more.

Again, your tax accountant will be able to help you figure out which credits you’re eligible for. But it’s a good idea to have an understanding of the different types of credits that are available.

The last step is to start estimating how much you’ll owe. This can be tricky, as there are a lot of different factors that go into it. But your tax accountant will be able to give you a good idea of what to expect.

At BOOST, we can help you get your taxes in order and make sure you’re taking advantage of all of the deductions and credits you’re eligible for. We’ll also help you estimate how much you’ll owe so that you can plan ahead.

BOOST Can Help You Prepare for 2023

At BOOST we’re a team of experts dedicated to helping small and mid-size government contractors handle their back-office operations, so you’re free to focus on the more important stuff. We’ll help you stay compliant and stay on top of everything from human resource operations to your accounting.

If you’re a government contractor, and you’re looking for some help, contact us today and let’s talk about what BOOST can do for you.

Leading Your Troops

Editor’s Note: This Article Has Been Updated November 9, 2022

Much has been written about management versus leadership.  There are many overly shared images about what characteristic leaders have versus those who are considered ‘just’ being a boss. Many books have been written on the subject yet we still find an abundance of poor leadership.

GovCon Management vs. GovCon Leadership

But what does it mean to be a leader in the GovCon world?

How can you lead a team of folks who mainly work on the government site and tend to identify with their customers (i.e. going native)?
How do you lead when your re-compete is up and you’ve got to reduce your team’s salaried personnel by 25% to win?
How do you enforce the rules and compliance in an overly regulated industry that doesn’t always make sense?
How do you continue to motivate and push your staff when you are beholden to 2% cost of living raises and a focus on keeping the multiplier down?

As you can already tell, there are a variety of situations that compound the already overwhelmed concept of leadership in GovCon. I believe there are many theories out there, but two common themes that have resonated with me are communication and authenticity.  At the heart of practically every conflict or issue in this world is communication.  If you cannot effectively communicate as a leader, even with the best intentions, you will fail.

Communication in GovCon Leadership

What is effective communication?  Saying what you mean, leaving nothing for wild interpretation and being authentic in your message.  Hollow sentiments or glossing over issues will only come back to bite you.  Having hard conversations is never easy, but it’s part of the job.  If you must cut salaries to be competitive on a bid, say it.  Say it clearly and unequivocally.  Provide your rationale and allow for feedback, but make it clear that you are responsible for this decision. Take ownership and allow those looking to move on, an opportunity to volunteer if possible. Communication is vital but so is being authentic.

Read more about communication and internal controls in your GovCon.

Authenticity in GovCon Leadership

What is authenticity? Providing and promoting an image that is sincere and true to your character as a leader or a company.  Employees, stakeholders, partners and clients can all spot a fake.  You can fake it for a bit, but eventually your true colors come out and the damage will be near-impossible to correct.  Instead of hiding your personality, embrace your strengths, and be yourself. The effort that it takes to hide or cover your personality can be better spent on leadership decisions and building a reputation on trust and authority. It is much easier to act on the truth than it is to remember and perform on a fallacy.

Regardless of your journey to leadership once you find yourself in a position of authority focus on solid communication and reputation based authenticity. Most companies that find themselves consistently winning awards and crushing the re-compete are those that excel in communication and authenticity. To effectively lead your troops into the GovCon space you must be clear and focused, always.

Let us help you recruit strong leadership for your GovCon with our GovCon recruiting services.

How to Keep Your Timesheets DCAA Compliant

The key to a successful DCAA floor check audit is an accurate and up-to-date timekeeping system. This includes the DCAA Pre-Award survey, which must be completed before you can be awarded a cost reimbursement contract. The survey assesses whether your accounting system can accurately track costs in accordance with contract terms. If you fail the survey, you will not be able to receive the contract.

Maintaining Job Code and labor category segregation compliance is crucial to passing any DCAA Pre-Award survey, and your timekeeping records are how you show that. In other words, proper timekeeping is essential to stay compliant with government regulations, avoid financial penalties, and improve your project’s bottom line. Below, we’ll present the regulations that will keep you in compliance.

Basic DCAA Timekeeping Requirements for GovCons

There are some basic rules and requirements for timekeeping as set by the DCAA. The rules themselves aren’t all that complicated or convoluted, but there are a number of them and it can be easy to lose track of whether or not you’re following them.

Here’s the basic list:

  • You must charge every hour worked exactly to the corresponding charge code.
  • Every day, every employee is responsible for logging their own time within the system. A manager cannot record an employee’s time unless the employee is unable to do so themselves (for example, if they are out sick or traveling for work).
  • Employees can’t log their time before the job or task is actually performed.
  • Each employee is only given one timecard or timesheet per work period. Most timekeeping is electronic, not paper. 
  • All time changes must be made in ink or in digital format and include the following: description of change, reason for change, initial time of change, and date/time of corrected change.
  • Employees and their supervisors must each sign off on all timesheets in order to ensure their accuracy.
  • For labor distribution reasons, timesheet records must include the employee’s name and both hours and minutes worked. Monthly labor distribution should be reconciled, making it critical to establish job codes in the tracking system.

It’s a good idea to keep a checklist of these basic rules and to regularly go through it and ensure that you’re in compliance. Messing up your timesheets can cause a massive headache in the case of a DCAA audit, including fines and disqualification from future contracts.

If You’re Not Using Electronic Timekeeping, Here Are Some Tips

Most GovCons are using electronic timekeeping systems these days, and those have their own set of additional rules. If you’re not yet transitioned to electronic timekeeping, here are some general rules for compliance. 

Luckily, most of these rules are common sense and probably already covered by your timekeeping system, but it’s always good to double and triple check to be sure. Again, failing a DCAA audit because of timekeeping can be expensive on multiple levels.

Here are the rules for electronic timekeeping systems:

  • To deter potential hacking, each employee must have a unique password which changes every six months.
  • To prevent any accidental or unauthorized changes, employees are accountable for their timesheets and must keep control of them at all times.
  • Employees are not permitted to work for hours that have not yet been compensated under the terms of the aforementioned legislation. They must track their hours on a daily basis, but they are not to do so in advance.
  • A contractor’s system needs to have an audit trail function that documents all changes including the following:
    • Dates
    • Time Changes
    • Employees
    • Project Numbers and Charge  Codes
    • Project/Timesheet Approvals
    • Time-Stamped Submissions
    • Correction Changes

BOOST Can Help You Stay Compliant

At BOOST, keeping government contractors compliant is a big part of what we do. We understand the unique challenges and complexities that small and mid-size government contracting businesses face, and we have the experience and knowledge to help you stay within the bounds of regulations so that you don’t get hit with any nasty surprises during a DCAA audit.

Contact us today to learn more about how we can help your GovCon business succeed with accurate and compliant accounting.

Build Loyalty Within Your Company

Cultivating a sense of loyalty amongst your employees is one of the most important things to be doing right now. We say right now because there’s a global talent shortage that’s hitting companies everywhere, GovCons not excluded. So retaining your people is more of a priority than ever.

But there are other reasons you want the loyalty of your employees.  People who are emotionally invested in their work tend to do it better. They also go above and beyond when the company needs them to.

Essentially, you want your people to want to come to work each day, or as close as you can get to that.

Below, we’re going to talk about some ways that your government contracting company can work to build loyalty within your organization.

Your Company Culture Is the Foundation of Loyalty

The first step to building loyalty is ensuring that your company culture is one that people want to be a part of.

Your company culture should reflect the values that you hold as an organization. It should also be a place where people feel like they can be themselves, and where they feel supported by their colleagues.

If your company culture is strong, your employees will be more likely to feel a sense of loyalty to the organization.

Make sure that you’re regularly communicating your company’s values to your employees, and that you’re living those values in the way that you operate.

And it’s true that there’s a stigma about government contractors not having much of a culture. Of course we know that’s not the truth of things, but there’s no denying that the perception is there. Be the GovCon to change that perception. Keep things interesting, and keep your people invested.

Give Your People What They Want

True, you might be investing a lot into your employees, but are you really giving them what they want?

Your employees want to be challenged at work, and they want their accomplishments to be acknowledged by their bosses and their peers. They want to feel like they’re learning and growing in their roles. They also want to have a good work/life balance and feel like their job is flexible enough to accommodate the rest of their life.

You’d be surprised how many government contractor companies are throwing benefits and perks at their employees without accomplishing those things. Could be that your company is doing just that and you don’t even know it. For example, maybe you’re buying lunch for everybody twice a month from Joe’s Big Beef Shack while being totally unaware of the fact that a third of your employees are vegetarian.

So the question now is how do you go about finding out what your employees really want? It’s actually very easy. You ask them. Or, more specifically, you work with your HR department to find a way to ask them.

Once you know what it is that your employees really want, you can start working on providing it to them.

Foster Pride in Your Mission

When it comes down to it, government contractors are working for the people of the United States.  That’s a pretty big deal, and it should be something that your employees are proud of.

Make sure that you’re constantly communicating the mission of the company to your employees, and make sure that they understand how their work contributes to that mission.

You can do this by sharing stories about how your company has helped achieve success on a project, or by sharing articles or blog posts about the work that you’re doing.

When your employees feel proud of their work, they’ll be more likely to feel loyalty to the company.

We Can Help You With Recruiting and Retention

At BOOST, we help government contractors by providing an array of back-office services. Whether your company is looking to recruit the best candidates, or you need to keep the people you have, we’re the right team for the job. Contact Us today, and let’s talk about how we can assist.

Protest Basics: Pre-Award, Post-Award & Case Examples

Join BOOST’s Director of Contracts, Robin Desmore and Maria Panichelli of Obermayer Rebmann Maxwell & Hippel LLP for the first of a two-part virtual series on the Protest Basics: Pre-Award, Post-Award, and the Process.

Our presenters will discuss:

• The Bid Protest Process
• The Types of Protests
• What Issues ARE Protestable
• Protest Scenarios
• and the Answers to Audience Questions

 

Corporate Housekeeping

As we turn our attention to back to school sales, last summer vacays, finishing up our trashy beach novels and start shifting towards the fall, it’s a good time to take a minute and do some general housekeeping. Face it – it will be the holidays before you know it!

GovCons, you are in the lull between the storm – proposals are submitted, awards are forthcoming but not here yet. It’s a great time to catch up on some of the mundane, but necessary parts of doing business.  It’s boring, and always gets pushed to the back burner as more revenue-generating opportunities come in.  But ignore these at your peril – they always come back to haunt you at tax time, during a transaction or with any litigation.

We’re kind of like sour patch kids, here at BOOST. Now that we’ve given you a bit of a gut punch, here’s a quick checklist to keep you sane:

1. Org Chart
When was the last time you actually updated it?  Do it now before you onboard all the new contract wins.  This way it’s readily available.  Now might also be time to consider if folks are really in the right positions/titles.

2. Articles of Incorporation
Time to dust it off and make sure it’s still legit and up to date.

3. Board meeting minutes
For privately held companies, this can feel like an administrative task you don’t want to do.  Remember that these board meeting minutes come in handy when you are looking toward a sale, are in litigation/disputes and are just plain good practice.

4. Tax Filings
Given all the changes, are you structured the way you should be?  If your uncle is still providing all of your advice, it might be time to get a second opinion.  Are you maximizing your tax status for your long-term strategy?

5. State filings
We always forget that when we add new employees in new states, we suddenly must start filing taxes.  Be proactive about registering and don’t let it be a nasty surprise year in arrears.

6. Insurance
When was the last time you sat down and went through what you are covered for and where you might have gaps?  I absolutely HATE this practice but make myself (and another person to get a different perspective) sit in the excruciating meeting and review everything.  Line by freaking line.  It’s horrible, my broker hates us, but we’ve discovered multiple things that weren’t covered or that we didn’t need to pay for.  It’s worth the investment of time (and sanity) once a year to know your risks.

 

If you need help with anything, we’re happy to give you our advice or introduce you to others that have that specialty.  Don’t slack off as we head towards the fall.  It will only come back to haunt you when you least expect it (or have time to deal with it!).

SCA and ACA…. WTH?

For our readers who have SCA (Service Contract Act) contracts, please keep reading…there’s a whole other level of compliance we’ve gotta get smart on.  For those of you who don’t have SCA contracts, thank your lucky stars, vow that you won’t go after this work without serious soul searching, and move on (Take this as our warning to you!).

Okay, everyone still with us?  As you know, SCA compliance is tedious and painful.  That’s our baseline.  Let’s now talk compliance with ACA (Affordable Care Act).  One thing to remember – ACA applies to all employers, not just those with 50+ employees.

First, SCA  H&W dictates that a certain dollar amount, now $4.80 effective July 5, is the new bona fide health and welfare (H&W) rate for all covered contracts executed or bid on after the effective date.

This means:

• If a contract has a new option year, the new SCA H&W rate may be applicable.

• For any new work bid on, the updated SCA H&W rate must be included.

• For those contracts covered by the sick leave EO 13706, the new rate is $4.41/hour.

• Companies will want to contact their Contracting Officer for each SCA contract requesting the timing of the updated SCA H&W rates for the specific contracts

• Remember to ask whether a modification to the contract will be issued (yes!!) or if the SCA H&W rate will be updated at contract renewal/option year (boo!).

Secondly, in regulation with ACA, employers are required to offer minimal essential coverage with their benefit offerings, just like employers with non-SCA staff or pay a fee to the IRS.

• SCA H&W by design was implemented in order to require employers to provide benefits instead of cash in lieu (CIL).

• Technically, not offering benefits could be non-compliant with SCA.

• DOL has provided guidance saying that under ACA, employers will no longer be able to pay all cash (ARE YOU HEARING THIS CIL FOLKS?) in lieu of offering benefits.

 

Finally, with this information come certain risks under ACA and SCA.  Some key elements to consider:

• Offering CIL payments in lieu of benefits does not meet the ACA requirement.

• Employees can potentially waive benefits to receive the CIL and still not have benefit coverage under another qualifying plan.

•Not having a waiver on file could make the employer non-compliant with the ACA mandate.   So yes, insist on the documentation, regardless of what story the employee may tell you.  No documentation = considered not otherwise covered in the eyes of the employer, IRS, and DOL.

• Not offering an ACA compliant plan that meets minimal essential value or minimal essential coverage could put the company at risk.

 

Along with these stormy clouds. We bring you some sunshine in the form of how to combat these risks:

• Offer benefits that are ACA compliant and follow SCA definition of a bona fide fringe benefit.

• Ensure each plan meets minimal essential value and minimal essential coverage.

• Work with brokers and other SCA/ACA experts on the outside if there isn’t someone at the company who understands the SCA H&W complexities.

• Be sure to obtain waivers (proof of insurance) from employees who waive benefits.  Unfortunately, you just can’t take their word for it.  If you’re audited and no documents on file means you’re paying fines.

 

If you’ve made it this far into reading about SCA H&W compliance, you deserve another cup of coffee (or something stronger depending on where you are in the process). BOOST can help with that too! BOOST LLC is sponsoring the September 25th govmates Institute that will focus on how you can CYA in SCA. (Breakfast and lunch with beer are included! We told you we had you covered.) Register for the govmates institute or contact BOOST for more information, [email protected]

How to Manage a Pricing Schedule

Why a proper pricing proposal schedule matters.

You’ve been preparing and actively developing capture strategies for an upcoming bid and eagerly awaiting the draft or final RFP to drop. Finally, it drops! All proposal functions swing into action. The proposal manager’s first job is to develop a schedule and hold everyone accountable to it. Very seldom do we get a proposal manager to ask us for a “Pricing Schedule”. However, we always insist.  Here’s why:

Price/Cost volumes these days require a lot more facilitation and coordination with other volume leads than most people realize. 

  1. Basis of Estimates. Many cost volumes require a complete basis of estimates to be written and tied to the price tables. The question is “How is the pricing manager going to be able to do this without coordinating with the technical/management volume leads?” The Basis of Estimates (BOE) and technical schedules MUST be in sync with the cost volume timelines. We recommend that the pricing manager set this schedule. This includes giving out deadlines to the BOE writers and standardizing the BOE data calls.  This is usually a standard template organized to capture the various work breakdown structure (WBS) elements that feed the various Contract Line items (CLINS).  It is critical to understand that unless these estimates can be produced and relayed into the pricing tables in due time, the whole proposal WILL be at risk. It is never an easy task to take in estimates at the last minute and develop pricing tables and submit the proposal within a day. We recommend that the first cut of these estimates be provided to the pricing team right after red team is done on the technical volumes. Then a review and updates are to be provided after the final review of the technical volume.
  2. Subcontractors. If the RFP requires subcontractor rates and sealed bids, this must be coordinated in advance. This timeline must be set and adhered to early on. Not only for compliance, but also for finalizing rate strategies. Sealed bids also require a few extra days of preparation by your subcontractors. They need instructions and active management of this timeline. Often these rates also impact your small business plan numbers that must be submitted. All these pieces must be accurate and in sync by the time the cost volume is finalized. Pick up the phone and get everyone aligned, early.
  3. Management Review. Management reviews are a soap box item for many pricing managers. If you don’t give your pricing team enough time to cycle through the technical and rate updates, how do you expect them to be ready for a proper management review? If management has to make the final decisions on fee/profit, workshare, key personnel, and any other ways to finalize the price, they need the best models with the most accurate information in order to do so. Bad or incomplete technical estimates make for bad pricing models. Plain and simple. So, get them done in time! Organize and coordinate with the BOE writers, hold them accountable for the pricing timelines. You may also need to hold the management team accountable, so that they realize that any changes made at the last minute (yes Gold Team reviewers we’re looking at you), have cascading effects on the pricing volume.  All final decisions should be made during Green Team (which should happen a few days before Gold team, if possible).

We have seen many cost volumes developed in a rush in the final days of the proposal stage, and this puts the entire proposal at risk. Mitigate this by being aware of missed opportunities to refine/review a smartly developed and compliant proposal.  With good schedule management, the pricing volume can be a proper, accurate and complete document that will be a part of the winning proposal. Don’t make your pricing volume the reason for your proposal loss.

BOOST has pricing experts at the ready, but don’t wait until it’s too late. (See point b, above.) Get connected with us now so that when you need us you already have our number on speed dial. [email protected]

How to Survive a DOL SCA Wage and Hour Audit

Editors Note: This was updated on 12/20/2022

Our Experience with SCA Audits

On a late Friday afternoon in May, just before I am about to leave for a three-day holiday weekend, my phone rings at the corporate office in Maryland and it is the voice of a woman who is the last person I wanted to speak to at the end of a long week – a Department of Labor auditor.  The woman seemed nice enough until she says, “a report has been made against your organization in North Carolina and I have been assigned to oversee the audit.  I will be emailing you momentarily all of the documents I will need.”  I receive the email and immediately called her back to ask, “Three days? I have three days to bring you payroll reports, rosters, and time cards for a workforce of 200 employees?” That is when she informs me if I do not comply with the SCA audit, the company will be in violation of her records request which could cause the organization to be assessed fines.  So, my team and I pulled together all SCA policies and procedures, 2 years of employee records, a month’s worth of payroll records, and time cards for 6 months for 200 employees. All over a holiday weekend.  It was a feat to be had, but the team pulled together and by Tuesday I was driving to North Carolina with 5 large bankers boxes to meet with the auditor on Wednesday morning.

Wednesday comes and the SCA audit begins.  Two weeks later theSCA audit is over, and I receive my findings. They were good, but not great.  The company was assessed almost $200,000 in back wages, but we were found to not be negligent in our practices, policies and procedures.

Tips to Survive an SCA Audit

  • Be nice and play nice with the auditor. She can make or break the SCA audit’s findings.  By playing nice with the auditor and offering assistance, she shared the reason for the audit – someone was not happy about not receiving their vacation benefit after being away from the contract for more than six months.  I explained that the FAR clause pertaining to vacation benefits does not dictate length of separation when determining an anniversary date and vacation payout.  The company set a generous policy that was in writing as to what would constitute a separation from the contract.
  • Make sure you understand the FAR clauses. Especially those associated with SCA and wage & hour as it pertains to an SCA contract to include health & welfare benefits. By demonstrating knowledge of the FAR, we were able to justify the policies and procedures put into place and that the company put a considerable amount of thought in how to implement the corporate policies. The auditor in charge of an SCA audit may be able to be swayed to your line of thinking, assuming there is no specific rule against the action you’re taking.
  • Be prepared for employees to talk to the auditor. The SCA auditor will request that you provide a number of employees to speak with her.  Our auditor spoke with approximately 25 employees.  We were able to identify 10 employees with the remainder identified by the auditor.  The company was not aware that the auditor would speak to employees as we were told originally it was just a document request and management interview, so be aware of the changing requirements as your SCA audit goes on.
  • The auditor is not limited in scope. The auditor will ask questions that are within the scope of DOL wage and hour and SCA.  They are not limited to the complaint that was filed.  We found out from employees who came to us asking why the auditor asked specific questions about pay practices, how we handled policy infractions, and more, all of which falls under an SCA audit, even if what your GovCon is being accused of has no bearing on the rest of the questions asked.
  • The auditor will be reviewing ALL aspects of wage & hour and SCA compliance. The auditor asked questions of corporate, program management, and employees on topics such as how employees are paid, how they are compensated, are they compensated fairly under the wage determination based upon their labor category, do they work overtime, and do they receive all benefits in accordance with the SCA.  Our auditor found that even though there was no overtime required on the contract and that we had a strict no overtime policy, employees were still using their own time to do tasks such as making copies at home or buying supplies for their workspace.  It was deemed that this was in direct violation of overtime laws.
  • The auditor will assess fines, penalties, damages, and lost wages. The fines, penalties, and damages are at the discretion of the auditor (this is where the “be nice and play nice” rule applies).  Our SCA auditor felt that since we were forthcoming with information, knew our FAR clauses and how to apply them, and there was no willful misconduct by the organization that she would not assess fines or penalties under wage and hour or SCA.  Yes, there could have been fines and penalties under both labor laws! However, the company was required to pay back wages of uncompensated overtime to 200 employees.
  • The auditor will determine the amount of lost wages and when those wages must be paid. Our auditor made a determination and created a calculation of how much potential overtime was reasonable to be paid to the employees (both current and past employees) who had worked in the prior 22 weeks. For most employees who were employed for that entire look-back period, they received just over $1,000 in back overtime wages which had to be paid out within two weeks of DOL’s notice.  If the company had been found to be negligent in violating SCA and/or wage and hour laws, punitive damages would have been assessed and paid to the employee.  To put this in perspective, punitive damages are two times the amount of lost wages, intensifying the strength of the loss your GovCon will face.

Critical Takeaways for SCA Audits

This is how I survived and what I learned during a Department of Labor SCA Wage & Hour SCA audit.  If I or my team had taken the stance that DOL was the enemy, if the company was not clear or consistent in SCA policies and practices or was found negligent in our understanding and application of SCA wage and hour laws, the outcome would have been catastrophic.  The company did a review of a worst-case scenario and found that the end result would have been over $1,000,000.00 in punitive fines, damages, and back wages that would have been owed to either the DOL or to the employees.  That’s a huge chunk of change for an up and coming 8(a) business.  The company would have had to shutter their doors and more than 200 people would have lost their jobs.

Avoid being a “worst-case scenario” story by making yourself aware of the SCA Wage & Hour requirements on every contract, and hopefully you’ll be able to avoid an SCA audit altogether. If you would like guidance on where to start and how to focus, email BOOST LLC. [email protected]

Accounting Keeping You Up At Night?

It’s the middle of the night, and you are wide awake…from a nightmare about the state of your GovCon accounting system. It happens all the time. The accounting system struggle is real for government contractors.  Your accounting system is the backbone of your company.  If your accounting system is in pain, the effects are felt in all areas of your company.  And let’s get real…nobody wants to hear from an employee that their paycheck was incorrect (again) or hear from a customer that an invoice has to be resubmitted because the proper format wasn’t followed.  Never mind the impact on cash flow!

Do you have any clue what is really going on inside your accounting system?

  • Are you panicked, wondering if it is DCAA compliant?
  • Do you have an accurate understanding of your indirect rates? Where do things stand from a cash flow perspective?
  • What about did you fudge on a proposal that your system is DCAA compliant and you have no idea if it is?
  • Are your invoices a nightmare to produce? Are you preparing them manually in excel?
  • Is your timekeeping system cumbersome, clunky or not syncing correctly?
  • Are your managers not approving timesheets when they are supposed to?
  • Is payroll a stressful event that everyone dreads?
  • When is the last time your books were closed?
  • Do you have the financial reporting to guide your company?

It can be difficult to see the big picture of your accounting system when you are in the weeds.  Hence the need for an accounting assessment.  Process improvement is best done by an outside party to evaluate what you currently have in place. GovCons should work with companies that have expertise in govcon accounting (not only for an assessment but for all things accounting).

What can you expect from an accounting assessment?
A good accounting assessment will evaluate:

  • current accounting system (chart of accounts, AR/AP, general ledger)
  • systems information and set-up (timekeeping, payroll, bill pay, expense reimbursement)
  • reporting capabilities (balance sheet, profit/loss, cash flow, income statement, job costing)
  • banking, 401K requirements (what reporting is required, what is being submitted)
  • timekeeping system (project codes, approvals, prime/sub timekeeping)
  • invoices (process, how they are generated, accuracy, timeliness)
  • policies and procedures (what is currently being documented)

An assessment final report should provide you with insight into your current system overview, what can be streamlined for greater efficiency and what is needed for DCAA compliance.  The report should include recommendations for resolving any identified issues.

BOOST can help you with an accounting assessment. This assessment will provide insight into your accounting system, a plan forward for fixing any issues and creating a seamless, fully functional, effective accounting department.  This will give you peace of mind and help you sleep better at night.  Or at the very least, you won’t be able to blame your accounting system for your lack of sleep.