INQUIRY 1: B&P labor – didn’t you say something about recording B&P labor as direct labor?  If so, where can I look that up online to make sure we’re doing it right?  RESPONSE: The FAR at 31.205-18 provides that all contracts...........

INQUIRY 2: Unallowables – I remember you saying something about splitting our unallowables between OH and G&A.  Where can I look to get a clear understanding of how this should be broken down?  RESPONSE: This is referred to, somewhat indirectly, in several FAR clauses with one at the FAR 31.203(c) provision as it reads,.......

We are in negotiations with a large business partner for a new task order, and we have run into a requirement from that business partner which we have not encountered in the past.  They are requiring things that appear to negate the exemption that “small businesses” have from DCAA’s CAS rules, referenced in DCAA Audit Manual, Chapter 8. 103.2 CAS Exemption.  We are looking for a way to convince our prime contractor that we, as a small business, can be awarded cost contracts. Do you have any suggestions on how to resolve this issue?  RESPONSE: I SURE DO and you actually provided the answer........

A lot is being said about the DCAA moving to providing only a Pass/Fail option for a firms accounting system.  Along with this misinformation are many scare tactics designed to influence the small business to invest large sums into the design, setup and implementation of their accounting systems and related controls.