HigerEd004

Faculty have 9 or 10 month contracts where they can choose to have their pay deferred (accrued) to stretch over 12 months. We are a large research university and have both DoD projects, Government Grants, as well as various other projects and non-Gov Grants. example: 9 month contracted faculty employee makes 120k a year. They work their 9 months and receive 13.33k a month. The choose the deferral option and get paid $10k a month during the time they work, then in the summer while they are not under contract they continue to get paid at $10k. Currently we only bill the months the employees enter time in Costpoint, our Accounting system, while they continue to get paid in the summer at their deferred amount. Any contract type other than FFP we are under billing our Customer/Sponsor for the work performed as we only bill the months they have hours in CP. This does not seem correct to me but our leadership has pointed out: FAR 52.216-7 Allowable Cost and Payment b) reimbursing costs i)Those recorded costs that, at the time of the request for reimbursement, the Contractor has paid by cash, check, or other form of actual payment for items or services purchased directly for the contract; and under DFARS 252.242-7006 Accounting System Administration (c) System criteria. The Contractor’s accounting system shall provide for— (4) A logical and consistent method for the accumulation and allocation of indirect costs to intermediate and final cost objectives; (7) Approval and documentation of adjusting entries; (9) A timekeeping system that identifies employees’ labor by intermediate or final cost objectives; (11) Interim (at least monthly) determination of costs charged to a contract through routine posting of books of account; (16) Billings that can be reconciled to the cost accounts for both current and cumulative amounts claimed and comply with contract terms I am trying to justify billing the months they are not working but so far my argument is not working!

Help with deferred pay, Government contracts and total time accounting! We have several DoD projects and US sponsored Grants and use total time accounting. How do bill deferred pay and it is allowable to do so under the FAR and DFARS acceptable accounting system?