I get a lot of questions from contractors preparing for DCMA review regarding determining accounting system adequacy "to CPSR standards" for Other-Than-FFP awards to individuals and small businesses that have not gone through DCAA audit. It can be a difficult issue to administer especially on quick turnaround efforts which include subcontractors who lack demonstrable corporate-level sophistication with financial aspects of government contracting.
I suggest that there are two main things to keep in mind when determining accounting system adequacy: