Audited overhead rates the good the bad and the ugly
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Audited Overhead Rates – The Good, The Bad, and The Ugly. AASHTO Subcommittee on Internal and External Audit 2014 Annual Meeting August 10 – 13, 2014 Savannah, Georgia. MH Miles Company CPA PC. Niche Certified Public Accounting Firm Specialize In Governmental Compliance

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Audited Overhead Rates – The Good, The Bad, and The Ugly

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Audited overhead rates the good the bad and the ugly

Audited Overhead Rates – The Good, The Bad, and The Ugly

AASHTO Subcommittee on Internal and External Audit

2014 Annual Meeting

August 10 – 13, 2014

Savannah, Georgia


Mh miles company cpa pc

MH Miles Company CPA PC

  • Niche Certified Public Accounting Firm

  • Specialize In Governmental Compliance

  • NUTRITION, TRANSPORTATION, EDUCATION

  • TRANSPORTATION

    • State Agencies

      • FAR Overhead Rate Audits

      • CPA Workpaper Reviews

      • Final Costs Audits / Agreed-upon Procedures Reviews

      • Staff Augmentation

      • Training & Consulting Services

    • A/E Firms

      • FAR Overhead Rate Audits

      • Assist management in calculating rate

      • Accounting system set-up and improvements

      • Guidance regarding State examinations & disputes


Agenda

AGENDA

Common issues and findings noted

Facilitate open discussion


Meals

MEALS

Employee Team Building

  • Cost incurred to improve employee working conditions, employee relations, and morale are allowable (reasonable) FAR 31.205-13

  • Often covered by the entertainment cost principle FAR 31.205-14 which overrides all other principles

  • Examples

    • Donuts & coffee on Fridays for weekly department meeting

    • Meal cost incurred at a Quarterly Progress meeting


Meals1

MEALS

Overhead Meals

  • Overhead meals are allowable when the purpose is not in support of projects and relates to the overall normal operations of business

  • Examples

    • A job interview for a project candidate at a restaurant.

    • A lunch meeting held with a company lawyer to discuss trademark filings

    • Corporate strategy meeting with managers over dinner.

    • Catered meal for an open house held to celebrate grand opening of subdivision.


Meals2

MEALS

Business Meetings

  • If a meal is part of a business meeting and incidental to the meeting then it may be allowable.

    • Technical meeting with speaker – allowable

    • Simply discuss some business during meal -unallowable

  • For the meal to be allowable it must be part of the whole meeting, an incidental part (meeting can stand on its own) and the meeting itself is allowable.

  • Meal cost must be reasonable


Meals3

MEALS

The Key is Proper Documentation

Who – employee name and names of all guest

What – was purchased and price (including itemized meal receipts)

When – date meal occurred

Where – place meal occurred

Why – purpose of the meal/meeting


Meals4

MEALS

Common Mistakes

Credit Card statement only

Purpose of meal missing

Meal cost excessive

Alcohol not removed

Misinterpretation of < $75 receipt rule

Poll – State procedure for unallowable costs


Total time accounting

TOTAL TIME ACCOUNTING

  • Requires all hours are recorded

  • No specific regulation that requires TTA

    • FAR 31.201-4: Cost Allocability and Assignability to Final Cost Objectives

    • CAS 401: Consistency in Estimating, Accumulating, and Reporting Costs

    • CAS 418: Proper Allocation Bases for Direct and Indirect Costs


Total time accounting1

TOTAL TIME ACCOUNTING

FAR 31.201-4: Cost Allocability and Assignability to Final Cost Objectives

  • A cost is allocable if it is assignable or chargeable to one or more cost objectives on the basis of relative benefits received or other equitable relationships.

    CAS 418.40: Proper Allocation Bases for Direct and Indirect Costs

  • Pooled costs shall be allocated to cost objectives in reasonable proportion to the beneficial or causal relationship of the pooled costs to cost objectives.

    Implied that all hours worked are needed to correctly determine the beneficial/causal relationship between the cost and the cost objective.


Total time accounting2

TOTAL TIME ACCOUNTING

CAS 401: Consistency in Estimating, Accumulating, and Reporting Costs (Bid = Book = Bill)

  • FAR 31.201-1: Composition of Total Costs - The total cost is the sum of the direct and indirect costs allocable to the contract…

  • FAR 31.203(d): Once an appropriate base for allocating indirect costs has been accepted, the contractor shall not fragment the base by removing individual elements.

    The premise is that consistent application of cost accounting practices will result in reliable cost estimates, and later facilitate comparing the estimated cost of contract execution with the actual cost.


Total time accounting3

TOTAL TIME ACCOUNTING

Common Mistakes

Owners only recording 40 hours/week

Employees stop recording time at 40 hours

Time in excess of 40 hours only recorded if billable

All hours recorded but only direct time is compensated

Poll – State procedure for correcting


Contract purchased labor

CONTRACT/PURCHASED LABOR

  • Accounting treatment varies depending on circumstances which costs are incurred

  • Most likely causes no fringe benefits

    • Labor performed in-house using the consultant’s supervision and facilities (Overhead Allocated)

    • Labor performed offsite under the supervision and control of another entity (No Overhead)

      Does the accounting treatment match billings?


Contract purchased labor1

CONTRACT/PURCHASED LABOR

Common Mistakes

Bill as employee direct labor – Accounted for as ODC or Indirect expense (And Vise-Versa)

  • How do States correct?

    • Redistribute in overhead to match billing practices

    • Make adjustments on individual project basis


Other issues

OTHER ISSUES

CPA firms performing substantial work to produce overhead audit without identifying Internal Control weaknesses

Travel expenses not limited to FTR

Indirect Labor on timesheets not detailed enough to identify unallowable activities.

Rotary and Chamber of Commerce Dues

Common Control Rent

Parent Company Allocations


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