Percentage of Completion Revenue Recognition, August 2012

By Bob Greco and Barb Ferneyhough

The Financial Accounting Standards Board in conjunction with the International Accounting Standards Board (IASB) has issued an exposure draft, which will likely take effect for fiscal years commencing after January 2015, that addresses revenue recognition. This update to the standard (topic 650) has direct applicability to government contractors and may affect the timing and amount of revenue recognized under long-term contracts. In particular, the updated standard serves to clarify a key element in the recording of revenue, namely; the transfer of ownership and control of the asset or service to the customer. This transfer may occur “over time” or at “point in time”. This is perhaps easily understood for tangible goods but less clear for services.

Read more: Percentage of Completion Revenue Recognition, August 2012

Executive Compensation Developments, July 2012

By Bob Greco and Barb Ferneyhough

In April 2012, the Office of Federal Procurement Policy issued a revision to their cap on executive compensation. The cap effective for costs incurred after 1/1/11 is $763,029. Compensation is excess of this limit is deemed unallowable. The 2010 limit is $693,951. Fiscal years not on a calendar year basis are prorated based on these amounts.

Without regard to the benchmark compensation amount, the allowable compensation costs for each affected executive are still subject to the Federal Acquisition Regulation and the Cost Accounting Standards as applicable and appropriate to the circumstances, e.g., reasonableness and allocability.

Contractors awarded cost reimbursement contracts (including cost-plus-fixed-fee and time and material contracts) are typically subject to FAR 52.216-7, Allowable Costs and Payments (see also FAR 31.201-3 and FAR 31.205.6).  Upon government audit, the audit agency will determine reasonableness based upon a number of factors and surveys that support executive compensation responsibility.

Read more: Executive Compensation Developments, July 2012

Affordable Health Care Act, June 2012

ByBob Greco and Barb Ferneyhough

The U.S. Supreme Court held that the individual mandate was within Congress's power under the Constitution's Taxing Clause. The Court concluded that the individual mandate is not a legal command to buy insurance, but rather a tax on the choice to forgo buying insurance. It does not apply to people who are not required to file income tax returns. The fact that the Patient Protection Act calls it a penalty instead of a tax was not controlling, the Court said.

Several health-care-related elements of 2010's health-care reform legislation (the Patient Protection Act and the Health-care and Education Reconciliation Act of 2010, P.L. 111-152 (the Reconciliation Act)) are already in effect, and the Court's decision allows them to continue. These include:

  • a temporary high-risk pool for individuals with preexisting health conditions,
  • a prohibition on lifetime dollar limits for essential benefits in insurance policies, and
  • a requirement that dependents be allowed to stay on their parents' health coverage until they turn 27.

Read more: Affordable Health Care Act, June 2012

BKH Core Competencies

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