
Your company just won a competitive $2.8 million cost-reimbursement contract—your first significant government award after years pursuing federal opportunities. Then DCAA notified you of an upcoming pre-award accounting system survey using Standard Form 1408. Three weeks later, DCAA issued a determination that your accounting system contains significant deficiencies preventing reliable cost accumulation and allocation, recommending contract award be withheld pending system corrections. Here’s what contractors miss about pre-award surveys: winning the technical and price competition doesn’t guarantee contract award—you must demonstrate accounting system adequacy meeting specific regulatory standards before the government will execute cost-reimbursement contracts, and discovering system deficiencies after contract award notification leaves you scrambling to implement corrections under intense time pressure while the customer questions your operational readiness. Understanding how to prepare for, navigate, and successfully complete pre-award accounting system surveys isn’t about gaming DCAA—it’s about building fundamental business systems supporting reliable cost management, demonstrating organizational maturity handling government funds responsibly, and proving you possess the infrastructure required for successful contract performance before taking on reimbursement-based work.
The Legal Framework Governing Pre-Award Accounting System Requirements
Federal acquisition regulations establish specific accounting system standards contractors must meet before receiving cost-reimbursement contracts. FAR 16.301-3(a)(1) requires contracting officers to ensure adequate accounting systems exist before awarding cost-reimbursement contracts, with adequacy determined through DCAA pre-award surveys evaluating whether contractors maintain systems capable of segregating direct costs from indirect costs, establishing labor distribution based on actual activities, accumulating costs by contract, and supporting invoicing requirements. This isn’t bureaucratic formality—it’s the government ensuring you can actually track costs before agreeing to reimburse them.
The accounting system criteria under DFARS 252.242-7006 establish eighteen specific requirements contractor accounting systems must satisfy including: logical and consistent cost accumulation, proper segregation of direct and indirect costs, identification of costs by contract line item, exclusion of unallowable costs, accurate interim billing, and reliable cost allocation methodologies. Defense contracts subject DFARS requirements, while civilian agency contracts apply similar standards through FAR provisions, but fundamental accounting system expectations remain consistent—you need systems proving you can track costs accurately and charge customers appropriately.
FAR 42.302(a)(12) assigns DCAA responsibility for evaluating contractor accounting systems, conducting surveys using Standard Form 1408 (Pre-Award Survey of Prospective Contractor Accounting System) to assess system adequacy. DCAA auditors evaluate whether your accounting system design, policies, procedures, and actual practices satisfy regulatory requirements, examining everything from chart of accounts structure to timekeeping procedures to indirect rate calculations. Understanding DCAA compliance requirements means recognizing that pre-award surveys represent comprehensive accounting system assessments rather than limited financial reviews—auditors evaluate end-to-end processes from time recording through invoicing.
The consequence framework involves contract award delays or denials when DCAA identifies significant deficiencies—problems so serious they prevent reliable cost accumulation and billing. Contracting officers cannot award cost-reimbursement contracts when DCAA determines accounting systems contain significant deficiencies, forcing contractors to implement corrections before contract execution. Minor deficiencies that don’t prevent reliable cost management may permit contract award with corrective action plans, but significant deficiencies stop awards completely until remediation is verified through follow-up surveys.
What Contractors Must Understand About Pre-Award Survey Challenges
Here’s what contractors miss about pre-award surveys: DCAA doesn’t evaluate your accounting system against your industry practices or commercial customer expectations—auditors assess compliance with specific federal cost accounting standards that often exceed commercial requirements in documentation rigor, segregation discipline, and allocation sophistication. Your $2.8 million contract opportunity requires accounting infrastructure that many successful commercial businesses don’t maintain, with survey failure rates exceeding 40% for first-time contractors underestimating federal system requirements.
The timekeeping inadequacy represents the most common survey failure when contractors lack daily time recording, contemporaneous supervisor approval, or adequate project coding structures. DCAA compliance explained emphasizes that weekly or bi-weekly timesheets violate federal requirements mandating daily recording. When your employees complete timesheets every Friday covering the previous week, or submit monthly time summaries, or use generic project codes like “overhead” without contract-specific charging, you’ve failed fundamental timekeeping requirements guaranteed to produce significant deficiency findings. DCAA expects systems where employees record hours daily, charge time to specific contracts using detailed job codes, and receive supervisor review and approval demonstrating management oversight of labor distribution accuracy.
The cost segregation challenge emerges when contractors lack adequate accounting structure distinguishing direct costs chargeable to specific contracts from indirect costs benefiting multiple contracts requiring allocation. This is where audits go sideways—contractors operating with simplified chart of accounts adequate for commercial work discover federal requirements demand separate general ledger accounts for direct labor, indirect labor, fringe benefits, overhead expenses, general and administrative costs, and unallowable costs with clear segregation preventing cost misclassification. When your accounting system lumps various cost types together requiring manual analysis to separate direct from indirect costs, you’ve created the lack of adequate cost segregation that DCAA flags as a significant deficiency.
The indirect rate methodology problem surfaces when contractors either lack formal indirect rate structures or maintain rate calculations that fail basic adequacy tests. Small businesses transitioning from commercial work often have no indirect rate infrastructure, simply marking up direct costs by arbitrary percentages without documented cost pool composition or allocation base logic. Others maintain rate calculations mixing unallowable costs in indirect pools, using inconsistent allocation bases across cost types, or lacking adequate documentation supporting rate computations. Understanding DCAA timekeeping requirements includes recognizing that indirect rates require systematic cost accumulation, rational allocation bases, and comprehensive documentation proving rate calculations produce equitable cost distribution rather than arbitrary markups.
The unallowable cost failure occurs when contractors lack procedures identifying and excluding costs that FAR prohibits charging to government contracts. Without systematic unallowable cost identification, accounting systems accumulate entertainment, lobbying, advertising, and other restricted costs in indirect pools, then allocate portions to government contracts through indirect rates. DCAA views this as fundamental system inadequacy—you must maintain accounting procedures identifying unallowable costs at initial recording, segregating them in separate accounts, and excluding them from indirect rate calculations ensuring government contracts never absorb prohibited expenses through overhead allocation.
The billing support inadequacy manifests when contractors cannot demonstrate how costs accumulate from source documents through general ledger to contract invoices. DCAA auditors trace costs backward from invoices through job costing to original timesheets, purchase orders, and receipts, evaluating whether your system provides clear audit trail supporting billed amounts. When this traceability breaks down—when you can’t easily demonstrate which specific timesheets supported last month’s labor billing or which general ledger transactions compose invoice amounts—you’ve revealed system inadequacy that DCAA flags as preventing reliable billing verification.
The documentation gap becomes apparent when contractors lack written accounting policies, procedures, timekeeping instructions, indirect rate methodologies, or system descriptions. DCAA expects comprehensive documentation explaining how your accounting system operates, what procedures employees follow, how costs flow through accounts, and what controls ensure accuracy. Undocumented systems relying on institutional knowledge or informal practices fail federal requirements demanding systematic, documented processes supporting compliance continuity despite personnel changes.
Five Essential Steps for Pre-Award Survey Success
Step 1: Implement Compliant Daily Timekeeping Before DCAA Survey
Establish daily timesheet systems requiring employees to record hours each day against specific charge codes identifying contracts, indirect activities, and cost types. Configure timekeeping to prevent weekly or bi-weekly summary recording, require daily entries, and generate exception reports identifying late or missing timesheets demanding immediate correction. Deploy Hour Timesheet or similar DCAA-compliant platforms providing required daily functionality, audit trail documentation, and supervisor approval workflows meeting federal standards.
Develop comprehensive charge code structures enabling detailed labor distribution including specific contract identifiers, contract line items when applicable, indirect cost pools (fringe, overhead, G&A), IR&D projects, and unallowable activities. Train employees on proper charge code selection, require project managers to validate time distribution accuracy, and implement controls preventing generic or default coding that fails DCAA adequacy standards. The charge code structure provides foundation for cost accumulation and allocation—inadequate coding granularity guarantees survey failure.
Implement supervisor review and approval procedures requiring timely timesheet approval, documented supervisor sign-off, and management certification that recorded time distribution represents actual work performed. Configure systems preventing payroll processing of unapproved timesheets, escalating approval delays, and maintaining permanent approval documentation supporting audit verification. This approval discipline demonstrates management oversight that DCAA considers essential to reliable labor cost accumulation.
Step 2: Configure Accounting Systems with Adequate Cost Segregation Structure
Redesign chart of accounts providing separate general ledger accounts for major cost categories including direct labor by contract, indirect labor by pool type, fringe benefits, materials and subcontracts by contract, overhead expenses by type, G&A expenses, and unallowable costs. Establish account structure enabling clear cost segregation without requiring manual analysis to separate cost types, ensuring your general ledger directly supports indirect rate calculations and contract cost accumulation.
Implement job costing functionality accumulating direct costs by specific contract, enabling you to answer fundamental questions like “what did Contract ABC cost us last month?” without spreadsheet analysis. Configure systems to automatically post labor costs to contracts based on approved timesheet distribution, charge material and subcontract costs to contracts based on purchase order references, and accumulate other direct costs through proper account coding. This automated job costing provides the contract-specific cost accumulation that DCAA considers non-negotiable for cost-reimbursement contract management.
Establish indirect cost pools with clear definitions including which expenses belong in each pool, how costs flow into pools through account structure, and what allocation bases distribute pool costs to final cost objectives. Document your indirect rate structure explaining pool composition, allocation methodology, and calculation procedures. This rate infrastructure transforms your accounting system from commercial simplicity to federal compliance supporting the systematic cost allocation that government reimbursement requires.
Step 3: Develop Comprehensive Written Accounting Policies and Procedures
Create detailed accounting system description documenting your chart of accounts, cost accumulation methodology, labor distribution procedures, indirect rate calculations, billing processes, and control procedures. This system description provides DCAA auditors comprehensive overview of your accounting infrastructure while demonstrating systematic approach to cost management rather than ad hoc practices.
Develop written timekeeping policies establishing daily recording requirements, charge code selection guidance, approval procedures, correction protocols, and compliance standards. Distribute policies to all employees, conduct training ensuring understanding, and implement acknowledgment procedures documenting that employees received and understood timekeeping requirements. Written policies create the compliance foundation that informal practices cannot provide during DCAA evaluation.
Prepare indirect rate methodology documentation explaining pool definitions, expense classifications, allocation base selections, calculation procedures, and rate application methods. Include supporting rationale explaining why selected methodologies produce equitable cost distribution, reference applicable cost accounting standards, and document management approval of rate calculation approaches. This methodology documentation demonstrates that indirect rates result from deliberate accounting design rather than arbitrary markup percentages.
Step 4: Implement Unallowable Cost Identification and Exclusion Procedures
Establish systematic procedures identifying unallowable costs at initial recording including entertainment expenses, alcoholic beverages, lobbying costs, certain advertising, executive compensation exceeding caps, and other FAR-prohibited costs. Train accounts payable staff to flag potentially unallowable expenses during invoice processing, require management review of flagged items, and code confirmed unallowable costs to dedicated general ledger accounts excluded from indirect pools.
Develop unallowable cost monitoring including monthly reviews identifying expenses potentially violating allowability restrictions, quarterly indirect rate recalculations excluding unallowable amounts, and annual comprehensive reviews supporting year-end rate determinations. Create documentation supporting unallowable cost determinations including FAR citations, management analysis, and exclusion calculations proving government contracts never absorb prohibited costs through rate allocation.
Implement billing controls ensuring direct costs charged to contracts meet allowability standards including purchase authorization procedures requiring contract charging approval before procurement, invoice review validating costs comply with contract scope and FAR requirements, and management certification that billed costs are reasonable, allocable, and allowable. These billing controls prevent direct charging of unallowable costs that indirect cost procedures wouldn’t catch.
Step 5: Conduct Pre-Survey Readiness Assessment and Remediation
Perform internal accounting system assessment before contract award notification using SF 1408 criteria evaluating timekeeping adequacy, cost segregation, indirect rates, unallowable cost procedures, billing support, and documentation completeness. Identify deficiencies requiring correction, develop remediation plans with specific timelines, and implement fixes before DCAA survey rather than scrambling after survey announcement.
Engage qualified consultants to conduct mock DCAA surveys examining your accounting system against federal standards, identifying compliance gaps, and providing remediation guidance. External assessment provides objective evaluation while enabling correction before actual DCAA review, dramatically improving survey success probability. The mock survey investment costs far less than losing contract awards or implementing emergency fixes under DCAA pressure.
Document all accounting system improvements including implementation dates, responsible personnel, and verification procedures proving corrections were implemented effectively. Maintain implementation records supporting demonstration to DCAA that identified deficiencies were corrected, controls were established preventing recurrence, and your system now meets federal adequacy standards enabling successful survey completion.
The Investment in Pre-Award Survey Preparation
Implementing compliant accounting systems meeting DCAA pre-award survey standards costs between $25,000 and $85,000 for small to mid-sized contractors depending on system complexity, current infrastructure adequacy, and remediation scope. This includes timekeeping system implementation, chart of accounts redesign, policy documentation, indirect rate development, and consultant support. Annual maintenance costs typically run $8,000 to $20,000 for ongoing compliance monitoring, system updates, and documentation maintenance.
Let me show you the value: contractors with compliant accounting systems pass pre-award surveys enabling contract awards, avoid the contract delays that damage customer relationships and business reputation, and build infrastructure supporting efficient operations and financial management beyond bare compliance. They compete effectively for cost-reimbursement opportunities that many competitors cannot pursue due to accounting system inadequacy, creating competitive advantages in lucrative contract segments.
Contractors with inadequate accounting systems face contract award denials losing business opportunities after investing heavily in capture and proposal efforts, experience prolonged contract execution delays while implementing emergency system corrections, and suffer reputation damage when customers question operational readiness based on accounting system failures. They incur crisis consulting costs implementing rushed fixes exceeding the investment proper preparation would require, while still risking inadequate remediation prolonging survey resolution.
Understanding Pre-Award Survey Scope Across Contract Types and Agencies
Pre-award accounting system surveys apply primarily to cost-reimbursement contracts where the government reimburses actual costs requiring reliable cost tracking, though certain cost-type fixed-price contracts like time-and-materials may trigger surveys when cost visibility and audit trail become contractually important. Fixed-price contracts generally don’t require pre-award surveys since the government pays agreed prices regardless of your actual costs, though exceptional circumstances involving cost-based pricing or high contract values might trigger reviews.
Department of Defense contracts operate under DFARS accounting system requirements establishing specific criteria and compliance standards, while civilian agency contracts follow FAR provisions with generally similar expectations but potentially different emphasis areas. Your accounting system must satisfy applicable standards for your target customer agencies, with DoD requirements typically representing the most stringent baseline that satisfies most civilian agency needs.
Your Path to Pre-Award Survey Success
The pre-award survey landscape rewards contractors who invest in compliant accounting infrastructure before pursuing cost-reimbursement contracts rather than winning awards then discovering system inadequacy. DCAA evaluates accounting systems against clear regulatory standards consistently applied across contractors, with survey success depending on systematic compliance rather than auditor relationships or negotiation.
For contractors seeking pre-award survey preparation, Hour Timesheet provides purpose-built daily timekeeping platforms meeting DCAA requirements out-of-the-box, enabling rapid compliant implementation without custom development. Our systems provide the timekeeping foundation supporting survey success while integrating with accounting platforms enabling comprehensive cost management.
Your contract opportunities deserve accounting infrastructure enabling award rather than creating barriers. Build compliant systems before you need them, ensuring readiness when opportunities emerge.
Additional Resources
Related Hour Timesheet Articles:
- DCAA Compliance Requirements for Contractors
- DCAA Compliance Explained
- DCAA Timekeeping Requirements
Official Regulatory References:

