Internal Control
CB&H Seminar: Building a Foundation for Government Contracting (Vienna, VA, 1/12)
Accounting System Adequacy Requirements All of the luck and good fortune cannot maintain a viable business and provide for success without a strong accounting systems foundation. Contracting with the Federal government enforces this requirement through well-defined criteria for accounting systems adequacy and stringent audits to ensure compliance. Non-compliance cracks in this foundation can lead to significant penalties including debarment and suspension from future contracting with the Federal government.
GAO Issues Two Bid Protest Decisions About Inadequate Accounting Systems
On December 19, 2008, the DCAA issued MRD 08-PAS-043(R), addressing significant deficiencies and material weaknesses on contractor systems of internal controls. This MRD directed DCAA auditors to cease issuing audit reports that found contractor systems to be inadequate in part if there were significant deficiencies or material weaknesses relating to contractor systems. As a result, DCAA audit reports on internal controls can now only state that a contractor’s system is adequate or inadequate. Because of the revised guidance in the MRD on what constitutes a significant deficiency or material weakness, many contractors are now having their systems deemed inadequate whereas. Read More.
DCAA’s New Approach to Internal Controls
In 2008, the DCAA issued three policy memoranda addressing reporting on contractor internal controls. The new DCAA policies announced in these memoranda have caused contractors significant concern. In our view, the DCAA is overreaching in its new aggressive approach to internal controls and is not in compliance with Generally Accepted Government Auditing Standards (GAGAS) promulgated by the Government Accountability Office (GAO). Further, these memoranda are inconsistent with the DFARS requirements for contractor internal control systems. The first memorandum was Memorandum for Regional Directors (MRD) 08-PAS-011(R), Audit Guidance on Reporting Internal Control Deficiencies, issued March 3, 2008. This MRD stated that. Read More.
GovCon Seminar: FAR Ethics Compliance Solution (Virginia Beach, VA)
You have no doubt heard about the new FAR requirements for contractors to: Have a written code of business ethics and conduct within 30 days after a trigger contract award; Within 90 days have an ethics and compliance training program; Promote an organizational culture that encourages ethical conduct and compliance with law; Have an internal control system that facilitates timely discovery and disclosure of improper conduct and ensures corrective measures are promptly instituted and carried out;
GovCon Seminar: FAR Ethics Compliance Solution (Vienna, VA)
You have no doubt heard about the new FAR requirements for contractors to:
GovCon Seminar: Understanding Government Audits in Today’s Environment (Raleigh, NC)
If you thought you understood government audits think again. The government audit environment has changed. Today’s audits are not “your fathers” audits. They are much more black and white and very little gray. Almost all internal control audit findings, especially in larger contractors, are significant or material weakness, making your internal controls inadequate; these inadequacies can create a domino effect on all of your other interrelated internal control systems (e.g. if your timekeeping system is inadequate then your billing system and accounting system are also inadequate). Become aware of the new audit environment and how it can and will impact. Read More.