Double-Check Requirements

DOUBLE -CHECK REQUIREMENTS
I was pleased to see an article encouraging CPAs and businesses to pursue government contracts (“ Help Clients Get Government Contracts, ” March 07, page 32). Overall, the article was excellent. 

However, there was one error in the section devoted to 8(a) Designated Small Businesses. The article stated that 8(a) firms are not required to participate directly in providing the goods or services. I would encourage all businesses and CPA firms to review the FAR clauses closely as some of these clauses do in fact require a certain level of participation by the 8(a) business for particular NAICS codes. The most significant relevant FAR clause is 13 CFR 125.6.

Additionally, I would recommend any CPA firm interested in expanding into this market contact the nearest Defense Contract Audit Agency branch or review the information at the Web site ( www.dcaa.mil ). DCAA has extensive information for contractors (and CPA firms serving them) that detail reporting requirements. These reports, including accounting surveys, financial capability, incurred cost and others, are a very lucrative and valuable service for a CPA firm to offer. Thanks again for the excellent publication.

Denise Smith, CPA
Athens, Ala.

Author’s reply: Thank you very much for the insightful comment about the DCAA reporting requirements. This is another excellent area for CPAs to provide assistance to small businesses in government contracting that deserved mention in the article.

With respect to 8(a) entities, you are correct that federal regulations encourage 8(a) firms to participate in the performance of contracts awarded under the 8(a) program to the fullest extent possible. However, the standards apply to the joint venture, not the 8(a) entity. The 8(a) joint venture program is designed to help eligible 8(a) businesses build capacity and expertise over an extended period with the goal that they will eventually be able to provide 100% of those products and services in the future. We intended to describe a situation in which a small disadvantaged firm enters into a joint venture with a large firm under SBA’s mentor program. The joint venture, once approved by the SBA, becomes an eligible 8(a) entity for contracting and performance purposes.

Charles Sparks, CPA, Ph.D.
Fairbanks, Alaska