By: John S. Morlu II, CPA
Introduction: The First Review Is Always the Hardest
The first time an 8(a) contractor faces a required Independent CPA Review or Audit is often the most stressful. The SBA’s deadline is fixed, but your books may not be — and the gap between “we keep decent records” and “we’re review-ready” can be significant.
The good news? With a clear roadmap, you can get there in just 90 days and set up your business for long-term compliance and credibility.
Phase 1: Days 1–30 — Baseline Assessment
The first month is about understanding where you stand today.
1. Engage a Qualified CPA Early. Don’t wait until the last month. A CPA experienced in SBA 8(a) compliance can identify what’s missing before it becomes a problem.
2. Review Past Financials. Compare your statements to GAAP, check for missing disclosures, and identify gaps in prior-period reconciliations.
3. Evaluate Your Accounting System. Determine whether QuickBooks or your current software is configured for job-costing, WIP reporting, and contract revenue recognition — and confirm that direct and indirect costs are being separated properly.
4. Identify Compliance Gaps. Make a list of everything needed for the review: schedules, supporting documentation, reconciliations, fixed-asset lists, and so on.
Pro Tip: The earlier you engage a CPA, the more time you have to fix gaps — and the lower the rush fees later.
Phase 2: Days 31–60 — Fix the Foundation
Now that you know what’s missing, it’s time to close the gaps.
1. Clean Up the Books. Post all outstanding entries (e.g., payroll, benefits, accrued expenses), reconcile bank, credit card, and loan accounts, and ensure subcontractor costs are properly coded.
2. Organize Source Documents. SBA-related reviews often require quick access to invoices, payroll reports, job-costing schedules, contract change orders, and bonding and insurance certificates.
3. Address Control Weaknesses. Segregate duties for cash receipts and approvals, set up approval workflows for expenses, and document policies for travel, procurement, and contract compliance.
Warning: Leaving cleanup until the final 30 days typically leads to missed deadlines or a review report with a qualified opinion.
Phase 3: Days 61–90 — Test, Review, and Finalize
The final phase is about polishing and partnering.
1. Do a Dry-Run Close. Prepare a trial set of financial statements and have your CPA spot-check for gaps.
2. Respond to Preliminary Findings. Address any issues while there is still time to correct them.
3. Prepare the Final Package. Include all required disclosures, footnotes, and management representations.
4. Schedule the CPA Review Work. Give your CPA access to all records so they can perform inquiries, conduct analytics, and issue the report on time.
The Payoff of Discipline
Firms that follow this 90-day roadmap avoid last-minute panic, receive clean and timely review reports, build credibility with lenders, sureties, and contracting officers, lower compliance costs in future years as systems stay organized, and gain peace of mind knowing the SBA requirement won’t derail growth.
Case Snapshot (Illustrative)
PrimeBuild LLC, a first-time 8(a) participant at $4.5 million in annual revenue, initially maintained only bookkeeper-level records. After engaging JS Morlu 90 days before their first required review, they cleaned up accounts, reconciled WIP schedules, and documented internal policies. The complete package was delivered to the CPA by Day 75. The result: an unqualified review opinion issued on time — which they then used to increase their bonding line by 25% and win a $6 million contract.
Owner’s Takeaway
A first-time SBA 8(a) review doesn’t have to be a scramble. Treat it as an organized project: Assess → Fix → Finalize. Start early, work in phases, and partner with a CPA who knows the rules.
Ready to Get Started?
If you’re approaching your first SBA 8(a) financial review — or your books are still more “tax prep” than “compliance-ready” — contact JS Morlu today. We’ll help you assess your readiness, map the next 90 days, and guide you through your first review with confidence, so you can focus on winning contracts rather than chasing paperwork.
Author: John S. Morlu II, CPA is the CEO and Chief Strategist of JS Morlu, leads a licensed public accounting and management consultancy firm. He has more than 20 years of professional experience in auditing and advisory work, including service as Auditor General of Liberia and FAR and DCAA compliance work at Unisys Federal Systems. The firm’s technology products include AI-powered reconciliation software (ReckSoft.com), a handyman services platform (Fixaars.com) and advanced cloud accounting solutions (FinovatePro.com), built for finance and operations teams.