The price of non-compliance can cost you an SBIR award. Are you making any of these easily preventable mistakes?
Government contracting can be a challenge; when you’ve cleared one hurdle, another one awaits, like finding a government-approved accounting system.
When COVID-19 hit, North Carolina’s BioMedomics made a tremendous impact on the world by introducing their groundbreaking COVID-19 rapid test.
From their experience developing a rapid test to diagnose sickle cell disease through the SBIR program, BioMedomics was able to help combat the pandemic by slowing down the spread of contagion with their rapid COVID tests.
Now, we want you to picture a scenario where these rapid COVID tests didn’t exist because of an oversight. What if the folks at BioMedomics failed to seize the federal seed funding needed for their initial research and development? And what if it was all because of something as simple as having an inadequate accounting system?
If BioMedomics didn’t have their ducks in a row when they started their SBIR journey, this could have been the outcome. There are many pitfalls in traversing the SBIR program, and so many of them are easily avoidable.
There’s a good chance you’re reading this blog because you have a solution to today’s most pressing technological and scientific needs, and you don’t want to jeopardize your idea over something as trivial as accounting.
Let’s look at some of the most common mistakes SBIR awardees make to sabotage their hard work.
Not having an acceptable and compliant accounting system.
If it feels like we’re constantly going on about the importance of government-approved accounting systems and Federal Acquisition Regulation (FAR) compliance, it’s because we are. And that’s for good reason.
Too often, we see dreams dashed because a small business owner’s accounting system wasn’t adequate. Unfortunately, oversight agencies, like the Defense Contract Audit Agency (DCAA) or the Defense Contract Management Agency (DCMA), aren’t forgiving for non-compliance among government contractors.
The real shame is how easily avoidable these failures are. Having a FAR-compliant accounting system means you are following the BEST accounting practices. And practicing excellent accounting should be second nature.
Awarded SBIR grants are cost-reimbursable, but your accounting system must be compliant with FAR Part 31. This particular regulation establishes cost principles and procedures and helps you determine which costs are reimbursable, and you’ve accounted for them.
Typically, the first phase of the SBIR program is a firm-fixed-price (FFP) contract which is not subject to any adjustments, so your chances of having the DCAA breathing down your neck about compliance are relatively slim.
However, this doesn’t mean you should wait until the last minute to ensure everything is in line with FAR requirements. These government watchdogs will check your accounting system before Phase II, and you can still lose an award for non-compliance no matter how much work you put into Phase I.
Proposing too low F&A or indirect rates.
You may think proposing a low, conservative estimate of your Facilities and Administrative (F&A) costs might give you a leg up when it comes to winning over the government. But, this kind of thinking could land you in hot water.
F&A, or indirect costs in a grant, can include electricity, internet, rent, and administrative services (and more). Unfortunately, we often watch small business owners create SBIR proposals with inaccurate indirect costs.
Incorrectly projecting indirect costs can lead to all sorts of cash flow nightmares. For example, if the amount you spend on indirect costs winds up exceeding the amount you projected, you’ll be responsible for paying the remainder out of pocket.
Not everyone has thousands of dollars lying around, which means grantees may have to tap into their bank accounts or take out a second mortgage. This, of course, can have devastating effects on your business.
On the flip side, if your rate is much lower than what you projected, you run the genuine risk of committing inadvertent fraud by overbilling the government.
Estimating indirect rates can be an uphill battle, but it is your responsibility to project these costs in your proposal accurately. You’ll need to know all of your company’s expenses (direct and indirect) and understand how to charge costs in your accounting system appropriately.
Here’s a great place to start: list all of your company’s costs (don’t worry about whether they’re direct or indirect at this point.); your profit/loss statement or your income statement can help.
Not only do you need to understand the differences between direct costs, indirect costs, and even unallowable costs, but you must also thoroughly track your indirect rates to avoid any nasty surprises that could spell financial ruin.
Improper timekeeping and uncompensated overtime issues.
Sometimes, the idea of having to fill out a timesheet can feel too micromanaging. You or your employees might find punching in for the workday an unnecessary task better suited for people working menial jobs. But this is far from the truth.
Timekeeping is a vital cog in the accounting machine. Payroll is one of your most significant expenses, and keeping track of the hours worked is crucial. By documenting the actual amount paid to you and your employees, you can allocate these costs to the various billable and non-billable tasks performed in your project.
“A contractor is responsible for accounting for costs appropriately and for maintaining records, including supporting documentation, adequate to demonstrate that costs claimed have been incurred, are allocable to the contract, and comply with applicable cost principles in this subpart and agency supplements. The contracting officer may disallow all or part of a claimed cost that is inadequately supported.”
Yes, once again, we stress the importance of being FAR compliant. And yes, once again, this means employing BEST practices.
An audit will heavily scrutinize your timekeeping procedures. To ensure things go smoothly, make sure your company has documented policies and procedures, a labor charging system for hourly time, specific accounting and billing system properties, and a staff trained in DCAA compliance.
Here is what you’ll need to do to get your timekeeping system up to speed:
- Create a policy detailing the timekeeping requirements for ALL employees
- Record EVERY hour of the workday, including leave
- Have every employee track their time DAILY
- Make sure you sign off and approve employee timesheets
- Keep all timesheets (including timesheet corrections) for at least two years
Having a transparent, organized timekeeping system is one way to ensure you won’t lose that hard-fought SBIR award. It will also ensure you don’t run into the costly issue of uncompensated overtime. Uncompensated overtime is the excess hours worked by employees exempt from the Fair Labor Standards Act (FSLA) (salaried employees) in a 40-hour week without additional compensation, and it is an oversight that can cost you dearly.
Thinking you can do the books yourself.
The SBIR program is aggressively competitive, and the government’s expectations can seem insurmountable.
Having a detailed Excel spreadsheet and QuickBooks is beneficial, but there is only so much those tools can do. For example, they can’t cover things like rates, labor distribution, and accurate timekeeping.
You probably think you can’t afford the costs of accounting services to bring you into compliance. It’s understandable. But what are your innovations and ideas worth? You can’t afford to have your solutions shelved because of flimsy and inadequate accounting.
FAR compliant accounting systems are complex and unique. Your time is best spent focusing on the research and development of your project. Not tracking indirect expenses, reconciling books, monitoring job costs reports, developing timekeeping procedures, and keeping checks and balances.
Team 80 is on a mission to help innovators like you succeed. We’re also on a mission to eliminate SBIR failures. We understand the nuances of government-approved accounting and FAR requirements, and our outsourced accounting solutions are affordable so that you won’t be breaking the bank.
Why are you waiting? Let us take over the accounting aspects so you can focus on turning your vision into a reality! Get in touch today!