SBA recently issued a significant rule affecting Multiple Award Contracts (MACs) that implements Section 1331 of the Small Business Jobs Act of 2010. Section 1331 focuses on several “tools” contracting officers can use to increase small business participation in MACs. The final rule also addresses procedures related to the “consolidation” and “bundling” of federal contracts. The final rule follows up SBA’s interim rule issued in November, 2011 which made clear that set-asides may be used in connection with the placement of orders under MACs, notwithstanding the requirement that each contract holder be afforded a fair opportunity to be considered. SBA proposed the changes addressed in this final rule on May 12, 2012.
Set forth below are key aspects of the final rule.
The Private Company Council (PCC), an advisory board to the Financial Accounting Standards Board (FASB), continues to offer “Little GAAP” modifications with two new alternatives for private company accounting: interest rate swaps and goodwill accounting.
These are two areas that affect many government contractors, especially come year-end when closing the books and preparing for a financial statement audit. The first, PCC Issue No. 13-03, is a simplified approach to interest rate swap accounting, for private companies who are in arrangements where they receive variable rates and pay fixed. It also addresses private companies whose only derivatives are similar swaps. The second,
And failure to comply will jeopardize the approval of your accounting system! The reimbursement of other direct costs on cost type contracts is governed by FAR 52.216-7 “Allowable Cost and Payment.” Per that clause a cost has to be actually paid before in can be included in an invoice to the government. Hence the phrase “paid to cost.” This used to be a hard a fast rule but it was somewhat relaxed years ago and some contractors incorrectly believe that it no longer applies at all. This is a dangerous misconception.
52.216-7 now reads in part “For the purpose of reimbursing allowable costs the term “costs” includes only those recorded costs that, at the time of the request for reimbursement, the Contractor has paid by cash, check, or other form of actual payment…”
As we grow closer to year end, many companies may be struggling with the decision as to what type of financial statement is right for their company. Audited financial statements are widely accepted in the banking and regulatory industries but if audited financial statements are not a requirement for your company, the cost may outweigh the benefits received.
The American Institute of CPAs just released guidelines to help privately-held businesses determine which accounting framework, including the Financial Reporting Framework for Small- and Medium-Sized Entities, best meets their financial reporting needs. On June 10, 2013, the AIPCA launched the Financial Reporting Framework for Small- and Medium-Sized Entities (FRF for SMEs), a new option for small business financial reporting. The FRF for SMEs helps small businesses prepare relevant and easy-to-understand financial statements without complicating the financials with GAAP-required accounting and cumbersome disclosures that may be cost prohibitive and irrelevant to the end users.
The National Cancer Institute is hosting a unique program designed to foster communication and make connections between eligible small businesses and prime contractors. This application-only event is being hosted on December 4th in Bethesda, Md. and will feature a “Prime Meets Subs” session dedicated to meetings between prime contractors and veteran-owned small businesses, as well as meet-and-greet sessions between pre-matched prime vendors and small business vendors.
Attendees will receive information about upcoming subcontractor opportunities for eligible small businesses, while assisting