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11/02/2019
Accounting system review or SF 1408 pre-award survey – What is the difference?
During this past quarter of relentless proposal writing, our clients frequently asked for assistance with approving their accounting system for federal government work under cost-reimbursable contracts. Requests for Proposals (RFPs), which require an adequate accounting system per FAR 16.301-3(a)(3), solicitation provisions may often demand evidence of “acceptability,” “adequacy,” or “approval” as a condition of award. Prime contractors may also request the same from their subcontractors to meet their subcontract monitoring requirement.
We see RFPs being issued with either SF 1408 (Pre-Award Survey of Prospective Accounting System) or Accounting System Review (ASR) requirements as a pre-requisite to a contract award that third- party CPA firms can perform. Sometimes RFPs are not clear on what the government wants. Understanding RFP requirements and draft-contract clauses are tantamount to enabling a successful proposal submission. In many instances, primes may ask for a higher-level assertion of the accounting system, then the contemplated contract requires. Understanding these requirements is extremely important in negotiating contract requirements with prime contractors.
We see RFPs being issued with either SF 1408 (Pre-Award Survey of Prospective Accounting System) or Accounting System Review (ASR) requirements as a pre-requisite to a contract award that third- party CPA firms can perform. Sometimes RFPs are not clear on what the government wants. Understanding RFP requirements and draft-contract clauses are tantamount to enabling a successful proposal submission. In many instances, primes may ask for a higher-level assertion of the accounting system, then the contemplated contract requires. Understanding these requirements is extremely important in negotiating contract requirements with prime contractors.
What should contractors know about accounting system assessments?
Does the RFP require you to have an adequate accounting system that can perform on a cost reimbursable contract (SF 1408) or an acceptable or approved accounting system based on the 18 accounting-system criteria presented in Defense FAR Supplement (DFARS), clause 252.242-7006?what can contractors do?
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For more information please contact Kiran Pinto, Senior Manager, at kiran.pinto@cohnreznick.com or (703) 847-4458 or Kristen Soles, Partner, at kristen.soles@cohnreznick.com or (703) 847-4411.Subject matter expertise
Kristen Soles
CPA, Partner - Managing Partner, Advisory - Global Consulting Solutions and Government Contracting Industry Leader
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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.