Expressly Unclaimed/Unallowable Costs

Believe it or not, I have been busy and traveling more than I probably should have over the last year. DCAA, while largely sentenced to working from their dining room tables, has also been busier than the previous several years.

When I published my first book back in 2012, the newest version of the DCAA guidance, The Contract Audit Manual contained numerous references in the core chapter five (5) on training – 108 to be precise. The major rewrite to the chapter in 2018 contained not a single reference. The current version contains 6 all focused on estimating systems.

Given this emphasis on training, I made it a critical part of my book with discussion and model policies and procedures. All of my writing supporting DCAA anticipated focus on contractor training.

Several year pass, countless accounting system audits, incurred cost proposals, and other procedures and never a word about training.

Until last week when an auditor demanded proof that employees were trained on unallowable costs.

I am not saying there is a future wave coming of DCAA demanding training, but……

Here is a quick and easy reference I put together – a “Expressly Unclaimed/Unallowable Costs Quick Reference”. Employees can look at it for a first pass to see if there might be an issue, a second pass to look up the regulations, and a third pass if they feel they need to call me.

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