Attachment D6 Accounting System Questionnaire .pdf

CONTRACTOR ACCOUNTING SYSTEM DISCLOSURE QUESTIONNAIRE

THE PENALTY FOR MAKING A FALSE STATEMENT IN THIS DISCLOSURE IS PRESCRIBED IN 18

U.S.C. § 1001

Per the Commerce Acquisition Manual (CAM) 1316.1 Section 5.3(c) Business entities performing as contractors for the Government must use an accounting system that is adequate for determining costs related to its contracts.

1. People completing this questionnaire are to describe the contractor and its contract cost accounting practices.

2. The Statement must be signed by an authorized signatory of the Contractor.

3. The questionnaire should be answered by marking the appropriate box, yes or no, which describes the contractor’s cost accounting practices.

4. A number of questions in this Questionnaire may need narrative answers requiring more space than is provided. In such instances, the reporting unit should use the attached continuation sheet provided. The continuation sheet may be reproduced locally as needed. The number of the question involved should be indicated and the same question asked in the Questionnaire should be used in presenting the answer on the continuation sheet. Continuation sheets should be inserted at the end of the Questionnaire. On each continuation sheet, the Contractor should enter the next sequential page number for that Part and, on the last continuation sheet used, the words "End of Continuation Sheet" should be inserted after the last entry.

5. Where the cost accounting practice being disclosed is clearly set forth in the contractor's existing written accounting policies and procedures, such documents may be cited on a continuation sheet and incorporated by reference at the option of the contractor. In such cases, the contractor should provide the date of issuance and effective date for each accounting policy and/or procedures document cited. Alternatively, copies of the relevant parts of such documents shall be attached as appendices to the pertinent Questionnaire response. Such continuation sheets and appendices should be labeled and cross-referenced with the applicable Questionnaire number and follow the page number specified in bullet 4. Any supplementary comments needed to adequately describe the cost accounting practice being disclosed should also be provided.

6. Questionnaire must be amended when Contractor’s cost accounting practices are changed with or without knowledge of the Government.

Company or Reporting Unit

Name: ___________________________________

Street Address: ___________________________________

City, State, & Zip Code: ___________________________________

Division or Subsidiary of (if applicable): ___________________________________

Official to Contact Concerning this Statement

Name: ___________________________________

Title: ___________________________________

Phone number (including area code and extension): ___________________________________

E-Mail: ___________________________________

CERTIFICATION

I certify that to the best of my knowledge and belief this Questionnaire as amended in the case of a revision, is the complete and accurate disclosure as of the above date by the above-named organization of its cost accounting practices.

(Preparer’s Printed Name) (Preparer’s Signed Name)

(Title) (Date)

U.S.C. § 1001

Has your accounting system been audited by the Defense Contract Audit Agency (DCAA) or another Government Agency within the past three (3) years?

If Yes, please furnish NOAA with a copy of the DCAA or Government audit report. If No, please answer the questions below.

YES NO

Does the Contractor Accounting System perform the following functions?

Accumulate contract costs by cost element by contract, project, task or cost objective for each cost element (labor, materials, subcontracts, other direct costs, fringe, overhead and G&A) as well as actual direct costs by labor category, contract and job.

YES NO

Account for and track unallowable costs and exclude such costs from billings, claims and proposals YES NO

Make certain direct costs and indirect costs are controlled by the general ledger YES NO

Capture pre-contract costs separately YES NO

Maintain homogeneous indirect cost pools and allocate indirect costs to contracts, projects, tasks or cost objectives based on a beneficial, causal and equitable basis

YES NO

Comply with financial clauses such as Federal Acquisition Regulation (FAR) 52.232-20 Limitations of Cost, FAR 52.232-22 Limitation of Funds and FAR 52.232-16 Progress Payments clauses

YES NO

Make interim accumulation of costs in the books of account, at least monthly YES NO

Track costs by contract line item YES NO

System is secured so only the proper people can make changes to entered data YES NO

Inception-to-date job or task detail YES NO

Proper segregation of direct costs from indirect costs YES NO

Segregation of pre-production, production, and post-production costs YES NO

Provides internal audit reports YES NO

Maintain all relevant historical data YES NO

Maintain an adequate timekeeping system capable of identifying employees' labor by intermediate or final cost objectives

YES NO

Maintain adequate labor and accounts payable distribution systems YES NO

Tracking of employee labor by intermediate or final contract objectives YES NO

Tracking of uncompensated overtime YES NO

Detailed labor distribution and cost allocation including direct and indirect labor to the appropriate cost centers / cost pools

YES NO

Requires that all contractor employees must account for all hours worked YES NO

Every contractor employee must record their time daily. (Under manual systems time must be recorded in ink. Recording time in advance or days after the fact such as at the end of the week is not acceptable.)

YES NO

U.S.C. § 1001

Contractor employees must record all vacation, sick, holiday and other leave time to the proper accounts. YES NO

Overtime must be approved in advance and be evidenced in writing. YES NO

All project names or job codes that appear in the system should be initiated by finance or the system administrator. Project names or codes must be provided to employees authorized to work on a given project.

YES NO

All contractor employee time must be approved by the employee’s supervisor. YES NO

All time charges must be the employee’s own. All time must be recorded properly based on work completed. Under no circumstance may personnel work on one project and record time to a different project. Under no circumstance may personnel work on indirect tasks and record time as direct costs to a project or vice versa.

YES NO

All contractor employees are provided at least annual documented time keeping training awareness whether by formal or informal means.

YES NO

Time sheets and all corrections must be maintained for a period of at least 2 years. Additionally, project records under a government contract must be maintained for audit purposes for a period of three years after final payment. The requirements for record retention are contained in the FAR Subpart 4.7.

YES NO

Periodic monitoring of compliance with time keeping requirements should be conducted by audit or floor checks.

YES NO

Use of an audit trail feature documenting all transactions in the timekeeping system is required. This includes all employees, time charges, dates, project numbers, time stamped submission and approvals. For corrections, it records changes made, employees involved including who made the change, date, approvals, reason for change etc.

YES NO

To secure an adequate accounting system, a labor distribution must be maintained documenting hours and dollars by employee, by project name or job code and indirect accounts. This labor distribution should be reconciled not less often than monthly to general ledger labor accounts

YES NO

Per FAR 16.205-3(b) is your current accounting system adequate for price redetermination? YES NO

Per FAR 9.104-1 (e) Does your organization have the necessary organization, experience, accounting and operational controls, and technical skills, or the ability to obtain them (including, as appropriate, such elements as production control procedures, property control systems, quality assurance measures, and safety programs applicable to materials to be produced or services to be performed by the prospective contractor and subcontractors). (See FAR 9.104-3(a).)

YES NO

In order to be compliant with DCAA and to be able to pass a potential audit, a company must have documented policies and procedures that are followed to the letter. The contractor must also employ a system that includes labor charges for hourly time, certain accounting and billing system properties, and employees trained in certain aspects of compliance (such as tracking their time on a daily basis).

https://www.acquisition.gov/far/current/html/Subpart%204_7.html#wp1082800 https://www.acquisition.gov/far/current/html/Subpart%209_1.html#wp1084088

BASED ON THE ABOVE ANSWERS TO THIS QUESTIONNAIRE, I HEREBY SELF CERTIFY THAT (INSERT CONTRACTOR)’S ACCOUNTING SYSTEM USED TO TRACK COSTS FOR CONTRACT (INSERT CONTRACT NUMBER HERE) MEETS ALL NECESSARY REQUIREMENTS OF A CONTRACTOR OF THE UNITED STATES OF AMERICA.

Certification: Under penalties of perjury, I declare that to the best of my knowledge and belief this Questionnaire is true, correct, and complete.

PREPARED AND CONCURRED BY:

PREPARER’S SIGNATURE DATE

CONTRACTOR’S AUTHORIZED SIGNATORY DATE

CONTRACTING OFFICER’S SIGNATURE DATE

ATTACHMENT - Blank Continuation Sheet

CONTRACTOR ACCOUNTING SYSTEM DISCLOSURE

QUESTIONNAIRE

CONTINUATION SHEET

NAME OF REPORTING UNIT

Item No.

Item description