Partial CUI Compliance
1 NIST 800-171 gaps detected. Not FedRAMP authorized. Popular among very small GovCon firms. Full DCAA-compliant project cost accounting starting at $295/month.
PROCAS Accounting
by PROCAS
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Accounting
Overview
PROCAS is a cloud-based project cost accounting system designed specifically for small government contractors. It offers DCAA-compliant timekeeping, indirect rate calculations, and project cost tracking at an accessible price point. Not FedRAMP authorized.
CUI Risk Assessment
Not FedRAMP authorized. Popular among very small GovCon firms. Full DCAA-compliant project cost accounting starting at $295/month.
Using PROCAS Accounting in a Defense Contractor Environment
PROCAS Accounting presents significant compliance challenges for defense contractors handling CUI due to its lack of FedRAMP authorization. This tool typically processes financial CUI including labor cost data linked to specific contracts (CUI//FEDCON), proprietary cost models (CUI//PROPIN), and personal information from timekeeping records (CUI//PII). In CMMC Level 2 environments, PROCAS would fall within the CUI processing boundary due to its role in project cost accounting and indirect rate calculations required for DCAA compliance. Without FedRAMP authorization, contractors must implement extensive compensating controls including data encryption at rest and in transit, multi-factor authentication, audit logging, and contractual security requirements with PROCAS. DCMA/DIBCAC assessors consistently flag non-FedRAMP accounting systems during CMMC readiness reviews, particularly when these systems store historical project data containing CUI. Recent DIBCAC assessments have identified PROCAS usage at small contractors as a common finding, with assessors questioning the security posture of vendor-hosted financial data. The tool's popularity among small GovCon firms (sub-$10M revenue) creates a compliance gap where cost-effective DCAA compliance conflicts with cybersecurity requirements. Assessors evaluate data flow diagrams to determine if project cost data containing CUI flows through PROCAS, making system boundary documentation critical.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
PROCAS Accounting lacks FedRAMP authorization. Using this tool for CUI processing violates DFARS 252.204-7012 requirements. Defense contractors must evaluate FedRAMP-authorized alternatives or implement and document compensating controls in their POA&M.
Migration Guidance
Defense contractors using PROCAS Accounting must migrate to FedRAMP authorized alternatives to achieve CMMC Level 2 compliance. Migration timeline: 12-16 weeks including 4 weeks for vendor selection, 6 weeks for data migration and configuration, 4 weeks for testing and user training, and 2 weeks for compliance documentation updates. Critical data export considerations include extracting 7+ years of historical project cost data per DCAA requirements while ensuring CUI markings remain intact during transfer. Export labor hour details, indirect rate calculations, and project cost pools in CSV format, then sanitize any CUI before temporary storage on contractor-controlled systems. User training requires 20+ hours per accounting staff member due to interface differences between PROCAS and FedRAMP alternatives. Recommended migration targets include Unanet GovCon Cloud (FedRAMP Moderate) at $200-300/user/month, or Deltek Costpoint Cloud (FedRAMP High) at $350-450/user/month. Update System Security Plan to remove PROCAS from CUI boundary and revise authorization boundary diagrams. Create POA&M entries for migration milestones and close NIST 800-171 findings. Total migration cost estimate: $25,000-$45,000 for small contractors (10-50 employees) including software licensing, data migration services, training, and compliance documentation updates.
Migration Checklist
- 1ISSO must remove PROCAS Accounting from the CUI authorization boundary in the System Security Plan within 30 days of migration decision per DFARS 252.204-7012 requirements.
- 2Contracts officer shall review all active contracts to identify DCAA audit requirements and coordinate migration timeline with government contracting officers.
- 3Sysadmin must export all project cost data from PROCAS including 7+ years of historical records required for DCAA compliance before account termination.
- 4ISSO shall evaluate FedRAMP authorized alternatives including Unanet GovCon Cloud and Deltek Costpoint Cloud based on contract CUI requirements and budget constraints.
- 5Legal counsel must review PROCAS data processing agreement to ensure secure data deletion post-migration and compliance with CUI handling requirements.
- 6ISSO must update POA&M to include migration milestones and target completion dates for NIST 800-171 control 3.13.8 remediation.
- 7Sysadmin shall configure new FedRAMP authorized system with equivalent DCAA-compliant features including indirect rate calculations and project cost tracking.
- 8ISSO must conduct user access reviews in new system to ensure least privilege principles per NIST 800-171 AC-6 requirements.
- 9Accounting manager shall validate data integrity post-migration by reconciling project costs and indirect rates against DCAA audit trails.
- 10ISSO must update authorization boundary diagram to reflect new FedRAMP authorized accounting system and submit revised SSP to authorizing official.
Compliance Cross-References
PROCAS Accounting's non-FedRAMP status creates direct violations of NIST 800-171 control family SC (System and Communications Protection), specifically SC-7 (Boundary Protection) and SC-13 (Cryptographic Protection) due to inadequate vendor security controls. The primary compliance trigger is DFARS 252.204-7012 which mandates adequate security for CUI processing systems, while 252.204-7021 requires cybersecurity compliance assessments covering all contractor information systems. Under CMMC Level 2, PROCAS usage impacts the Access Control (AC) domain through inadequate system boundary definitions, the System and Information Integrity (SI) domain via uncontrolled external connections, and the Configuration Management (CM) domain through unauthorized software deployment. The tool's violation of NIST 800-171 control 3.13.8 (Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission) stems from unknown encryption standards in vendor-hosted environment. This creates a compliance chain reaction: inadequate boundary protection (SC-7) leads to CUI exposure risks, triggering incident response requirements (IR-4) and necessitating POA&M entries for risk mitigation, ultimately affecting the contractor's CMMC Level 2 certification eligibility.
NIST 800-171 Violations
Using PROCAS Accounting for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Frequently Asked Questions
Is PROCAS DCAA compliant?
PROCAS provides DCAA-compliant timekeeping and cost accounting features. However, it is not FedRAMP authorized, so if financial data includes CUI, document this as a risk acceptance.
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