Automated Contract Writing for Commercial Items
The Department of Defense (DoD) has proposed to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to utilize automatic contract writing systems in the acquisition of commercial items and to specify flow down of clauses to commercial subcontracts* . The DoD believes the use of automatic contract writing systems will save time and governmental resources in the acquisition process for commercial items. Currently, DFARS 252.212-7001 requires Contracting Officers manually ‘check the box’ in commercial item acquisitions to denote applicable clauses. The proposed amendment would allow automatic contract writing systems to select these clauses, removing such efforts from the hands of. Read More.
GAO Upholds DCAA’s Inadequate Accounting System Determinations
With the Defense Contract Audit Agency (“DCAA”) taking an aggressive stance on what is an adequate accounting system and the promulgation of the Defense Federal Acquisition Regulation Supplement (“DFARS”) business systems rule, including DFARS coverage of what is an adequate accounting system, contractors must pay close attention to their accounting systems. This internal scrutiny should be heightened by the fact that many solicitations are requiring offerors to submit evidence that they have adequate or approved accounting systems. Recently, the Government Accountability Office (“GAO”) has become involved in this process through a series of bid protest decisions involving the question of. Read More.
DCAA Performance of Timely Forward Pricing Assignments
Recognizing that the timely completion of pricing audits are critical to the procurement process, DCAA has issued an MRD on February 23, 2012 entitled “Audit Guidance on Agreed to Dates Performance Measure for Forward Pricing Audits (12-PPS-005(R)). DCAA and the Contracting Officer are to establish a mutually agreed to date for completion of a pricing audit considering associated risk, audit scope, the needs of the Contracting Officer, report review, auditor experience, scheduled leave and holidays. Once sufficient data is obtained, DCAA will measure the percentage of time the due dates were achieved and not achieved so that best practices may. Read More.
DCAA Compliant Lodging, Meal & Incidental Travel Cost Reimbursement
The DCAA compliant reimbursement for lodging, meal and incidental travel costs and the determination of the allowability of such costs on government contracts seems to remain an issue with contractors both large and small and emphasizes the need for established travel cost reimbursement and identification of unallowable cost policies. The regulatory requirements are defined in the Federal Acquisition Regulation at FAR 31.205-46, Travel costs, which states in part at: (a)(1) Costs of lodging, meals, and incidental expenses may be based on per diem, actual expenses, or a combination thereof, provided the method used results in a reasonable charge. (a)(2) Costs. Read More.
DCAA Access to Internal Audit Reports
The Government Accountability Office (GAO) stirred the pot of compliance stew in December 2011 when it issued a report entitled “ DCAA Contract Audits – Actions Needed to Improve DCAA’s Access to and Use of Defense Company Internal Audit Reports ”. The report states that “by not routinely obtaining access to relevant company internal audits, DCAA auditors are hindered in their ability to effectively plan work and meet audit standards for evaluating internal controls.” Court decisions have placed limits on DCAA’s right to access to internal audit reports  but GAO continues to assert that DCAA needs full access to a contractors internal audit reports and related working papers to adequately meet generally accepted government auditing standards (GAGAS) and improve. Read More.
DCAA Build-Up – DoD Return on Investment
According to a recent article in the Washington Post , both the Defense Contract Audit Agency (DCAA) and Defense Contract Management Agency (DCMA) are preparing a build-up in auditors in an effort to reduce the government audit backlog that has grown since 2011.