Sign Hawaii Advertising Agreement Template Myself

Document type sign advertising agreement template hawaii myself

good afternoon and thanks for joining washington d.c based jennifer schauss associates in our get far cited and 2020 complimentary webinar series as you know the far or federal acquisition regulations as the rule looked that the federal government must follow in making purchases our webinar series pulls from contracting experts to explain each part of the far it is complementary and recorded we'll post all the recordings on our website and youtube channel where we have over 300 government contracting webinars available for download a special thanks to our webinar partner in the series the national international veterans small business coalition education foundation pleases their website to learn more about the organization we would also like to thank our friends that open the park for their sponsorship if your organization is interested in sponsoring the series or one part please contact hello jennifershouse.com and now a little bit about us we work with primarily large businesses to help them navigate the federal marketplace work with both product and service companies as well as software firms our clients spam the globe and include publicly traded organizations in a variety of sectors we provide market analysis reports contract administration contract vehicle assistance and more all of our services can also be built into a training course for your team learn more about us on our website and now we would like to let you know about some ways to reach the government and government contractors through us we offer advertising and sponsorship opportunities through our weekly newsletter and also in our webinar series for pricing or to place an order please email us email us at hello at jennifershouse.com now let's move on to learn a bit about today's speaker chef shapiro you can find his contact information on the screen here and today we are covering fire park 31 with jeff thank you so much for joining us today we're really thankful for your participation in the series the floors and years please let me know when you're ready for your next slide sounds good thanks so much for the introduction arnold all right let's let's move on and get to today's learning adjustable welcome everyone i'm really glad you can all join me today got a lot to cover in a little bit of time but i'll tell you that typical far the 31 courses can be a day or even a week-long type course so i'm gonna condense that all and give you the nuts and bolts of what you really really need to know but if you need more details you know there's a lot more here to unpack so today we'll talk about the importance of this part and i'm gonna teach you about what the difference is between allowability applicability and reasonableness and related overarching concepts for those we're going to talk about what an expressly unallowable cost and what it means if if you're as if you're a contractor what will happen to you if you get caught claiming them and what and what that means and then we'll get into some specific risky errors of costs and there's about 50 cost principles about specific areas there's obviously not enough time today to cover them all but i want to just cover at least a couple to give you a flavor for what you're in for when you're trying to figure out is this cost allowable so i'm gonna try to get you there today and this is just the beginning and then finally some best practices on how to identify on a lot of costs let's go to the next slide all right so why is 531 so important uh plain and simple it says very in in far 31 103 that that the cost principles and procedures 312 are are to be used and it's going to be used in any cost reimbursable contract cost plus fixed fee ward fee any of those uh tnns we're talking about the reimbursable part the the dollars part not the hours part when you're when you're negotiating indirect cost rates so if you're doing uh provisional submitting provisional rates or any forward pricing rates on allowable costs should be excluded uh from from those pools uh and then when you're proposing negotiating and terminating contracts under terminated contract that's a very specialized area for a whole another day but if you're on a fixed price contract that gets terminated it turns into a cost plus contract uh then we then a bunch of other contracts that's here but i also want to make sure you see that a fixed price contract can be subject to bar 31 cost allowability and that usually comes into when you have to submit a certified cost of pricing data and when you're pricing up your rates your indirect rates or even your your direct rates you need to consider the impacts of unallowable costs all right next slide so how do you determine allowability and that's outlined at thirty one two one two these key factors are what needs to make a cost allowable and i know we're gonna repeat what some of these are in a bit but you need to essentially check all these boxes in order for a cost to be allowable under a cost under in federal government contracts uh the reasonable ability i'll talk about uh momentarily is the cost cash compliance so if you're if you're a contractor in your firm it has to follow the cost of county standards that's what cas stands for uh you need to not only be compliant with what's within the far you also need to be compliant with the regulations within cass and the good news i'm here to tell you that if you're following far it's most you're most likely going to be cast compliant but then are you following your consistent practices that's uh including your disclosure state if you're fully cast compliant anyways so much here to get into and so much to cover uh terms of the contract that's a really big factor whenever you're awarded a federal contract make sure you're really parsing out each of your contracts as awards to make sure there aren't specific clauses that make certain costs unallowable one good example that's almost most in many contracts is overtime premiums so if you have part-time employees or working directly on contracts and you ask them to work overtime you know your normal practice may be to pay those people overtime and you may not be able to collect on the premium that you're paying on those contracts so go look at the terms of the contract when you're allocating those costs to the contract like you should don't don't be looking to build them because an auditor or the government when they're looking at your invoice they see that and say hey wait a second there's a there's a term that says you can't do that so there's often uh indirect rate ceilings whole bunch of different things that could make certain costs unallowable uh you've got to look at your agency's specific uh supplements and any other uh and making sure that any cost that you're you're claiming you need to have the documentation i mean uh i mean this is the mantra and i'll get to it at the end but when you're in government contracting it's all about the documentation and what do you have to back it up to substantiate why this is unallowable if an independent person or the government uh cannot figure out what the cost was why it was charged why it was allowable then this cost part this part of the the far is gonna is it tells this contracting officer to make a determination on your behalf is that the how you want to treat your costs so something to keep in mind all right let's keep going next slide reasonableness uh this to me is all about the washington post test mostly so like you're claiming your cost you know the golden toilet seat and all that kind of nonsense a thousand dollar hammer you know you're charging costs that someone else you know outside your organization goes you paid how much for what you know that's essentially reasonableness uh what specifically says in this far part is about the prudent person and you know that they're responsible when you're you're taking responsibility for what you're doing are you consistently doing it within your company's practices so you know if you're thinking of yourself as a you know profit uh you know earning business you're buying stuff under your cost plus contracts the same way you're doing under fixed price contracts uh you know so because a lot of people see those cost reversible contracts as blank checks and it really should not be done so you should have a certain amount of rigor in your purchasing practices such that you're just you're spending such that you can still stay within budget and you know contracts to have a fixed customer universal plus fix space should incentivize incentivize those practices to keep the cost reasonable uh but not everyone acts the same but bottom line keep that in mind keep these kinds of things in mind when you're when making sure that the costs that you're claiming are reasonable next slide allocability good old accounting term but those who are outside the county may not understand this principle very well this is all about making sure that a certain cost as is incurred gets applied to the contract in an equitable way so you know we hear the term final cost objective and i i didn't actually put that on the slide but final cost objective is a fancy way of just calling a project or a contract so when you're thinking about does this cost belong specifically on a contract or is it an indirect cost think about what the causal or beneficial relationship of the cost if you're incurring a cost to go to training uh you know is that job training for for that specific person is it just for the performance of that one specific contract well it could be you know maybe for that certain contract you know that contract says hey i need you to go to this training session and learn this very specific uh uh interagency requirement yep could be a direct con direct cost however if if it's a training on company-wide ethics or timekeeping well that sounds like that's something that benefits multiple contracts and makes sure that company stays compliant with far hello this is why we're doing this right so then it becomes an indirect cost and probably in most cases belongs and accompanies either g a or overhead pool so yeah so you need to consider that causal beneficial relationship when it comes to allocability and and how whether or not it belongs there so you know you're incurring a cost on behalf of another organization uh you know say you have multiple subsidiaries you're going to have to transfer that cost out of your company and not have it improperly allocated uh to a contract that you're working on all right let's move to the next slide so let's let's better understand it so i think this venn diagram does a good job of showing uh how everything links you know a big concern that the government has is is the spending that you're incurring on behalf of your whole business you know are is the government getting its fair share and you know this especially is it is worrisome when you when a company does commercial business uh you know the biggest concern you know i i work as an auditor for a lot of my time uh in my current position and the biggest thing i tell my teams is uh ari are is that company using government funds to help subsidize an unprofitable uh commercial contract so you know if you're they're doing 25 percent of commercial work and somehow uh you know 90 of indirect costs are getting allocated to government contracts that's probably not equitable so you need to think about that and and make sure that there's an equitable way that costs are being segregated the indirect costs are being segregated between commercial and government contracts um you know that's gonna be something that's always highly scrutinized so the common issues that i list here uh you know also include you know understanding how the use of advanced agreements so uh you know is there a specific way you're accounting for a special kind of cost and are you you know make sure you continue abiding by the terms of that advanced agreement i talked about those rate ceilings you know there may hit a ceiling uh in a certain contract but you can't then just take the rest of the unbilled indirect rate costs and throw it on to another contract that that would be that would be inappropriate and you get caught for doing that and then commerciality so that's an interesting concept that you know usually you use a fixed price uh commercially determined market based price uh for a product for for for your revenue and billing purposes however you still need to allocate costs especially if you're uh working on a government cost-based contract you still need to allocate the costs that relate to the procurement or providing the commercial services or goods in order to uh make it fair and then contract mix oh geez i mean uh there's the allocability between fixed price and cost plus contracts i know there's always a temptation for a contract to figure out you know let me make sure this is something that i can allocate to my cost reimbursable clinton or contract versus my fixed price contract because well of course i want to you know i get reimbursed with each dollar paid and then when you have multiple contracts and multiple customers yeah the dod doesn't want to pay for costs that the doe energy is paying for so lots of different issues here uh got to keep in mind to make sure that everyone is getting their fair share is what it comes out to all right next slide credits i this is one that's hot in the news now just because of the ppp loans just know that for any credit that you receive don't just quickly throw it into miscellaneous income make a determination whether or not it's a credit against a cost that has been incurred if it is then you got to make sure you put that as a credit to the expense account and not to your miscellaneous income account next slide accounting for unallowable costs wow this is very hot topic obviously um how do you actually uh uh account for all the costs and far is not going to be very uh specific on how you do that but generally i'm here to tell you that contractors should have segregated accounts for unallowable costs and then this concept of directly associated costs is very is unique one to government contracting obviously that you know for something that you do in unallowable activity a very easy one and i know some of you listening may not be aware of all the unallowable costs but i'll try to make it simple as possible entertainment as you can imagine you take someone out to a ball game you know you know when we're recording this is the time of covid so hopefully by the time a year from now when we're listening this we can actually do this but anyways you're taking someone to a ball game and yeah you might be talking about business development opportunities and you know from a business standpoint it could be a deductible to maybe a tax deductible expense or at least partially tax deductible expense and it's legitimate business activity but in the day the the per the what you're doing and the activity that's going on is essentially not allowable activities it's entertainment so all the the labor costs that that person puts that time in their timesheet and they probably should uh is an unallowable uh time that the the taxi cab of the uber that the person took to get to the ballpark yep that would be unallowable as well it's all associated with the activity of going up entertaining so i'll give you another example down below all right let's keep going we've got a lot to cover in a little bit of time espresso at all elbow costs i definitely want to take a minute to talk about what an expressly allowable cost why this matters um so i gave you the definition about what what it is and essentially when you read the far there's essentially no question that thou shall not do this uh it says you know such and such is not allowable or it is only allowable when you do this so as seen there like as i talked about there it says leaves little room for differences opinion whether or not it meets the allowability criteria so purchase of alcohol is unallowed says it very simple the cost of entertainment unallowable purchases a gift or on allowable those are all easy examples of expressing on allowable costs you go to the next slide there's some that are essentially implied next slide please so it could also you know so yeah so here's the direct examples like i said that the contributions the alcoholic beverages bad debt there's so many more there's so many of these examples i mean there's also uh examples at the agency supplement levels so for instance uh hhs doesn't allow for independent research and development costs uh you know so you see that clause in your contract realize that any costs allocated to hhs you're gonna have to take out that part of your costs or else be subject to being deemed expressed on allowable costs which i'll explain what happens if you get if that happens to you all all right so next one we'll talk about the indirect next slide we'll talk about the indirect terms so you know for instance there's a where it says for the example of uh for key man insurance you know the cost of insurance are only allowable to the extent that so essentially says you can do this if it if it you know meets this condition if it doesn't meet the condition therefore it's unallowable so that you know again you can plainly interpret that if i claim an insurance that benefits the life of an officer and then and and the company gets paid yep that's an expressively unallowable cause and so if you're having a hard time you know you're thinking about and maybe you're arguing with an auditor about you know whether or not something isn't expressing all the costs well here's the i gave you a link to a memorandum for regional directors about an audit alert for expressing on all costs where you can go see the third via detailed list about what the government sees as being determined when expressing all of of costs all right so what does it mean if a contractor claims an expressly unallowable cost next slide well you could be assessed the penalty so not only do you have to pay back the amount of the unallowable cost a hundred thousand dollars we found in alcoholic beverages wow that must've been a heck of a party well you not only need to pay the hundred thousand dollars but you also have to pay a hundred percent as a penalty so you're going to be paying 200 000 oh by the way yes you're also going to get assessed interest so that out those alcoholic beverages were bought four years ago you're gonna have to pay compounded interest uh on top of that so yeah it's a big deal it could cost your company a lot um and there's even where you can get trouble damages for for costs and which they've been already deemed unallowable prior to submission proposal so say you wanted to propose something you wanted essentially a judgment from the contractors what if we did it this way or you know here's this legal case and you want to get an advance agreement uh from from a contracting officer hey you know if this happens you know would you allow these costs if you get a letter from the contractor's office that says no i would not be need to be allowable costs and then after you get that letter and still submit your control cost submission that includes those costs a contracting officer can interpret that as being that second level of assessment of a penalty so be really careful with those kinds of situations i mean better examples even when other income costs are being negotiated and contract the officer says yeah that's a cost that that that's penalizable well that could also be a situation but good news you know for the little tiny little things here and there that you may not catch everything you know you know hundreds a hundred dollars here and there of a meal that is it that could be deemed as entertainment yeah you might be asked to be paid that hundred dollars back but they may waive the penalty because it says very specifically within that 427095 that you don't the contracting officer has the ability to waive the penalty and there's also that small little thing about unintentional error you're going to have a hard time proving that because you're going to talk about how great your controls are and and you know i don't claim on all the costs well yet something happened how is that an unintentional error so that one's a tough one anyways avoid the penalties take out your expressed and unallowable cost from your indirect costs all right next slide all right so i'm going to quickly go over a couple of risky far clauses like i said we're limited on time so i can't really go into a lot of them so i think talking about compensation those professional services and travel costs are good overviews of more complex principles within far 31 and why like i said you know there's multiple references to these types of costs and there's a lot more judgment that has to be involved with it and lots of documentation oh have you heard that yet about government contracting all right let's go talk about compensation move next slide all right here's all the separate sections within this power principle i'm obviously not going to cover all of them but let's talk about the ones that i see people are challenged with the most next slide usually when you see um the general section of the clause you quickly glance over you're like whatever no big deal this one i i would not be uh so fast in doing that it talks about you know needing to have an established compensation plan and if you make any major changes that you're actually supposed to tell the aco there's no level of the size of business where you know if you're changing how you uh often give bit that give offers on a company-wide basis don't go crazy with this this is an overall thing then you have to know if i very more common is the biggest thing i want to point out here is the one in the middle about because you call it compensation doesn't make an unallowable cost allowable so i i can't tell you how many people have said hey listen you know it's part of his compensation you know we give him ten thousand dollars to go entertain climate uh oh i heard entertain no that part of the compensation is now thrown out so one overriding principle about bard 31 is you know multiple bar clauses may may uh be involved cost principles may be involved but ultimately what is the nature of the transaction and you know you may be doing business development you might be doing some selling but ultimately you know if you're doing that all at a ball game like i said before it's they're probably all gonna get thrown out um other special consideration like i say here it says very specifically that if you're an owner operator owner manager within the company you're you're going to be closely looked at and that's not to say that owners can't be compensated and not be compensated you know you know at the 75th percentile but you're going to get very closely looked at so be careful do your homework do the market research get salary survey data when you're determining what owners should be paid in terms of compensation all right let's move on next slide so it's a reasonableness and like i talked about there's the general far clause about reasonableness called this specific far clause and i first uh cost principle talks about its own reasonableness and this is where usually we talk about executive compensation or at least highly other highly compensated individuals like smees uh the test is supposed to be are you paying these people within a reasonableness standard of people who are in the same size the same industry same geographical energy and doing same kind of work under non-government under comparable circumstances so bottom line what homework are you doing to make sure that what you're paying is indeed within you know a market rate we always throw that number out oh it's the market so what the market allows well well the person at his last job was making this much now we're going to pay him 20 more okay that might be the approach but ultimately is that what the market really pays or is you just so you know want that person so badly you'll pay whatever it takes so do what's right and make sure you have independent data that can substantiate the rate that you're paying especially the higher rate employees and given these circumstances that's exactly what the auditor's gonna have to look for and you're gonna have to substantiate you have to have that document so don't make sure it stays within the compliance files within the hr file wherever you need to keep it that you can't forget about it when the audit happens up to six years later yeah this is a big deal okay let's keep going next slide bonus incentive conversation huge topic in the world uh i can spend an hour just talking about this but bottom line you know you need to pay the bonus incentives are fine but as long as you're doing it consistently and putting essentially something that says that we have a bonus program we we do it either via discretionary or there's this formulaic approach uh you know or whatever it is it's got to be something that's that's consistent and you need to be able to support why you gave certain people the bonuses they have if you're giving significant size bonuses to people who are on performance improvement plans yeah i don't think that's not going to be scrutinized so what i want to make sure i convey here is do you have to have all the rules and exact step by step how you get to each bonus every year and follow that rules no but you should have a regular practice we meet together every year we discuss everyone's performance and you know the highest performers will get this part a bonus and lower performers don't get any whatever it is make sure it's a consistent practice that you can substantiate let's keep going next slide so some best practices like you know i wanna i've outlined here and it can outline a whole bunch of different things um know that it's okay if it says in the employment agreement hey if the ceo grows the company by 15 we will give that the ceo x amount of dollars yep that'll probably be okay as long as overall compensation is reasonable uh you know if it says specifically that bonuses are going to be paid to management discretion in in offer letters well that's that that'll probably work however if you decide to wait at the end of every year decide hmm should we do bonuses every year should we you pay out a bonus or not no you're just making it on a fly i mean yes we all most contractors do have to make a decision you know at the end of the year is happening and and how cash flow is and all those other factors but bottom line it should be part of the culture that every year bonuses are offered not well depends it keeps depends or we're just going to pay it out of price yeah that's probably not going to work all right let's keep going next slide all right uh compensating related uh changes in prices of corporate securities this is an unallowable cost like i said before you're especially unallowable cost so if you're giving out stock options stock appreciation all that kind of stuff that you know tech companies are often using or startups you know this is a great incentive tool it doesn't mean you you can't do it just don't think you can charge the government for the cost of issuing these rights because as you may know there's lots of easy ways to manipulate these costs and the government doesn't want any surprises usually so anyways move on next slide so limitations on liable compensation is very important to know i know this is getting a little bit aged but at this point if you have any contracts issued before 2014 there's one set of rules for how the the cap in which employees can be paid and then another set of rules for those for the amounts be paid after 2014 next slide so here are the outlines of those limits as you can see the pre-2014 limits are a lot higher than what they are today um the more recent uh so as long as so and this depends on when your original contract was left so if you have a five year option contract that was issued june 1st and you just finished it last year you're still under the old compensation limits however any other contract ordered after june 24 2014 your the cost that you claim you know director you know mostly really in this case indirect uh you got to look at the cap amounts that are shown into those are on the right and what i've shown that little table the that as of fy2018 is what's been published at omb is 525 is a cap for for executives we've already we've done the the math for you and even though it hasn't been published the the balanced budget act that made this change and how executive compensation works as government contractors you know we've done the math and we've come up to 540 555 and 19 i'm sorry the second number should say the 22 20 20 cap is uh 555 000. all right next slide all right professional consultant service costs this is a highly scrutinized uh area when otters come in the first thing they'll pick up within g a pool besides executive compensation is professional services and as we all know otters and consultants are out there and charge lots lots of crazy rates and well here i am i'm the consultant that that's probably among those but it's very important that when you're negotiating with these uh consultants that you have a very distinct statement of work that outlines exactly what that consultant is going to do so know that you know as long as they stick to the statement of work the activities within that statement work are allowable activities so again remember i was talking about before you know you have an agreement you follow all the necessities of this cost principle but ultimately that consultant is giving you advice and how to do general advertising brat brand enhancement you this professional service cost might be deemed as an unallowable cost so so know the difference between a professional uh service cost as comp uh contrasted with purchase labor which is someone who's more i would think more like a temp agency type employee versus a subcontractor who's someone who's doing work on on contract so let's not confuse the difference between those so let's move next slide so what are those special considerations when you're looking at a professional service and what are they doing are they providing advice are they providing recommendations you know like i said before it's got to be for allowable activities are they actually managing supervising personnel if they're doing that well they're probably not a professional service anymore they're more like a subcontractor so know the difference between the two um you're gonna have to document well why did you approach this relationship like this why is this a reasonable cost i mean this is all very important no matter what type of cost you're incurring but you need to have that kind of documentation in order to substantiate it let's keep going next slide travel costs uh travel i is also a very highly scrutinized area although these days in uh early mid 2020 not many people are traveling anymore but you know what i i'm confident we're going to travel again we're going to get out there so this power clause talks about all types of travel costs from air air ground and i guess on water too in all the associated miscellaneous costs next slide so so how is travel permitted and you know what regulates what government contractors can do um within conus we're looking at the federal travel legal regulations and the per diem rates outline there if you're doing oconus it goes to the joint travel regulations as issued by the department of defense and if you're doing anything else overseas so oconus really is just uh hawaii alaska and other uh territories whereas totally overseas going to a foreign country you're going to be looking at those state regulations for for some guidance does this mean that government contractors have to follow all this well let's let's talk about that let's move on to the next slide so do they also all government tribals applied all contractors right no not necessarily um the government travel rules are meant for government employees and being a former government employee myself for eight and a half years yeah i got to know the jtr and fdr really well um however as government contractors you're asked to maintain your own travel policies and and ask to abide them but i'll tell them here to tell you remember that reasonableness thing i talked about earlier yeah it's hard not for a government auditor to use the guidelines in which they're look to abide by and compare to what contractors are so something to consider but what's specifically called out in this cost principle is that lodging meals and incidental expenses should be done you know measured against uh maximum per diem rates as outlined that you'll find on the gsa website and the other places for the other rates um but just know you yes you can go over per diem and often there are uh contract terms that say val must get the the core cotr's pre-approval or when you have to go over per diem or even if you have to travel at all so remember remember i said before about allowability contract terms matter if you don't do that the government can come back and even though you did a perfectly planned trip did a great work uh you stayed under per diem you saved a ton of money by finding a great deal for for rental car on a price line whatever it is yeah the governments can still disallow that cost if you didn't get pre-approval from your contracting officers represent so if you look after that anyways keep going next slide so per diem includes what very important to know so if you're traveling domestically lodging taxes laundry would be totally separate whereas if you're going to hawaii you know laundry is actually included within mnie and then they'd be going overseas to indonesia well your lodging taxes are now included within that per diem rate so just so you know on these kinds of items next slide so what are things you need to consider like i said the per diem location i think airfare type is a hugely important issue uh first class travel is generally going to be a no-go no matter what business class could be okay as of now it's you know for certain trips over 14 hours another some other rules on that so make sure that you're following those rules in order to when you're flying or even even taking a train i mean these things are very important that others can be looking out for and and then just following your corporate policies on authorizations and you know if you know when we're allowed to travel if you're going to a conference that's been scheduled for a year and you decide to book it the day before you go well you better have some darn good uh documentation about how someone dropped out and you wanted to fill in that's why you paid so much for that airfare or else you know then governors come back and say why am i spending 500 more in this airfare ticket when you could have booked this months in advance which have been much cheaper so things to think about uh when travel is being claimed keep going next slide so what are my best practices on allowable costs i know you can't be over done and oversaid in government contracting you know not only with contracting itself but it's within accounting document document document uh you know when in doubt document so no for real um lots of these areas that i spoke about today and others you know when you're sitting there thinking you're on the fence about whether or not to claim a cause you may want to attach something else to that voucher or something outside of agreement or something else in the in the vendor purchase about you know why this cost was you know was unusual why there was a substantiate why was it reasonable you got to be able to you know because when this stuff gets audited like i said the government has up to six years out of the stuff and many times you're gonna have some kind of turnover within the accounting or compliance department and they're gonna be like yeah oh i'm here i don't remember why we did that well it better be in that file so that segues into my second tip about training staff regularly on unallowable costs like what are your your firm's uh policies about unallowable costs and yes i mean obviously they should follow far part 31 but i know a lot of my clients you know will say hey listen if anything you know smells like it could be interpreted as an all the cost we're just not going to claim it depends on how you guys going to do it but bottom line uh you know have that regular training and quite frankly you know if you look at the dfar's criteria for having acceptable accounting system you know obviously one of that criteria is about having internal controls to detect and segregate unallowable costs and one way to do that is make sure that staff is adequately trained so not only have the training but document who was there what was the agenda what did you cover and be able to prove out oh there i go talking about my documentation again uh that that that training did occur so look hey government i've done everything in my you know in my power to make sure that we're making sure that unallowable costs are being segregated or not cleaned on federal costs third best practice is you know to be consistent and aim to properly segregate at the time of transaction yes you know one thing i did not talk about and i don't want to confuse you all but you know you could you know allocate you excuse me you could record all costs as they they're incurred and then at the end of the year do statistical samplings in order to to take out unallowable costs you could do that and and you know depending on your volume your transactions your high volume transactions you only do five to ten percent of your work for the government and maybe that's the better way to do it because you get to train an accounting staff of 50 on unallowable costs just for five percent of your business is that really worth it well maybe not so you could do that but many cases if not i would say most cases i think it's best and practiced at the time of transaction entry when you're recording these ap vouchers or journal entries take you know un identify the unallowable cost right up front have formalized policies and procedures all on all albuquerque i can tell you that no matter what size contractor you are you want to have an acceptable accounting system for accumulating reporting and billing uh costs under cost reimbursable contracts one of the first things that an auditor is going to ask for uh pre-award or post award is for your policy and procedures and you're the one the most important policy procedure is going to be about on allowable costs how will your company treat it make sure those unallowable costs that if normally if they were allowable they should have been within a base of a of an indirect rate we'll make sure that stays in in the base of that rate and that's a whole nother topic for another day so but have those positive procedures to to manage that and finally when in doubt throw it out i can't tell you how many calls i get a day that says jeff you know we're we're having this little in this get-together uh you know i really want to improve my team's morale and you know i'm going to buy some snacks for them and we're going to give this employee a an award for being with the company for 20 years so there's lots of little things going on there that yeah you probably could get away with it and you know depending how much is being spent you know if it's a 50 100 you know i come back and say listen you know if you feel like you'd be okay writing that check god for you know someone wants to dig that low for that small amount you know maybe you do it and you can claim it but another great policy i think instead is hey listen if anything is smelling potentially as being something is not allowable just just don't claim it it's just not worth the hassle you're gonna have to spend hours going back and forth with the dca or another auditors explaining why oh no really this was a morale and you know this wasn't actually entertainment we it was in the uh like you really want to go through that pain so keep that in mind all right next slide all right so i've got a handy dandy guide that if you go to go to our website uh which you can actually get to by going to govcon360.com we have a tool that lists out the common uh selected costs that are covered within the far 31 principle and you can get the feel up for you know what's allowable what's unallowable and you'll see going quickly scanning down the list there's plenty cost principles that show examples of allowable and unallowable uh-oh so a lot of it depends and awr meaning allowable restrictions if you can claim this only if blank so yeah so lots of things to think about to consider you're gonna have to read far at times so if you start with this you have this posted next to your desk you're doing your ap vouchers yep that's a good start but you're gonna have to start reading details to try to determine whether or not there's enough gray area for you to claim the cost is allowable and i think that just about wraps us up uh next slide um i'm sorry i wasn't able to interact with you during this session but i would love for to hear any questions you may have um please reach out to me via that email or phone number i love to work with you and help you out if you have any questions about my presentation um otherwise you know i would like to thank jennifer shasta and associates for inviting me to present on bar 31 thanks everyone hope you hope you learned a thing or two right thank you so much for a great presentation jeff really appreciate your time uh to our audience members thank you again for participating with us if you have any questions about this part of the farc specifically uh you know please contact our speaker with the contact information you see on the screen and if you have any questions about federal contracting or need assistance with any of our services please contact us directly thank you again for joining us this concludes today's webinar you