Revised Treatment of Incomplete or Inadequate Prime Contractor Cost
The Defense Contract Audit Agency (“DCAA”) issued revised guidance on the treatment of incomplete or inadequate prime or higher-tier (hereinafter referred to as “prime”) contractor cost or price analyses during a forward pricing proposal audit. This new guidance, effective immediately, cancels the previous guidance established in 2009 and in 2017. Federal Acquisition Regulation (“FAR”) 15.404-3(b) requires the prime or higher-tier contractor to conduct cost or pricing analyses to establish reasonableness of the proposed subcontractor costs. Under the previous guidance, if the prime contractor did not complete and submit the required subcontractor cost or price analyses with its own proposal, DCAA classified. Read More.
DCAA 2018 Hot Button Highlights
By: Curt Smith , Manager Each year Cherry Bekaert addresses topics that effect the Defense Contract Audit Agency (“DCAA”) in our DCAA “Hot Buttons” webinar. A summary of the January 17, 2018, webinar is presented here. The webinar is replay is also available on our YouTube channel. The webinar is available for replay on our YouTube channel. Section 803 of the 2018 National Defense Authorization Act (“NDAA”) Section 803 of the 2018 NDAA contains several provisions reforming defense contract auditing. Perhaps the provision with the greatest impact on DCAA directs the Department of Defense (“DoD”) to begin using private auditors to perform incurred cost audits to reduce the current backlog. The provision intends to focus DCAA resources on forward-pricing audits, which are considered. Read More.
Topics: Cost Accounting Standards "CAS", DCAA, DCAA Audits, DCAA Memorandums for Regional Directors, Defense Contract Audit Agency "DCAA", Department of Defense "DoD", Federal Acquisition Regulation "FAR", Generally Accepted Government Auditing Standards "GAGAS", Incurred Costs, National Defense Authorization Act "NDAA"
2018 NDAA: Changes to TINA Threshold and Incurred Cost Audits
In November, the conference committee for the National Defense Authorization Act (“NDAA”) for fiscal year 2018 completed one of the final steps in the NDAA process filing its report reconciling the differences between the House version and the Senate version of the legislation. Shortly after the reports were reconciled, the conference report was officially enacted into law as the fiscal year 2018 NDAA. This bill authorizes fiscal year 2018 appropriations and sets forth policies for Department of Defense (“DOD”) programs and activities. One of the major changes in the fiscal year 2018 NDAA, Section 811, is the increase in the. Read More.
No More DCAA Performing ICS Audits?
No more Defense Contract Audit Agency (“DCAA”) auditors auditing your company’s incurred cost submission? It could happen! As a result of the 2018 National Defense Authorization Act (“NDAA”) signed by President Trump on December 12, 2017, it is a real possibility for an independent accounting firm to audit your incurred cost submission instead of auditors from the DCAA. Under the NDAA, which outlines defense spending priorities for the new fiscal year and established federal funding levels, there is a provision for the Department of Defense (“DoD”) to start using private auditors to perform some incurred cost audits. The idea is. Read More.
Topics: 2018 National Defense Authorization Act, audits, Defense Contract Audit Agency "DCAA", Department of Defense "DoD", Generally Accepted Government Auditing Standards "GAGAS", Incurred Cost Submission "ICS"
DODIG Report on DCMA Actions Regarding DCAA Incurred Cost Audit Reports
In a recent report from the Department of Defense Office of Inspector General (“DODIG”) (DODIG-2017-055, dated February 9, 2017) the DODIG found several instances when the Defense Contract Management Agency (“DCMA”) contracting officer’s (“CO”) actions did not comply with Federal Acquisition Regulation (“FAR”), DoD Instruction 7640.02, or DCMA instructions. The findings resulted from a review of 22 incurred cost reports judgmentally selected from a pool of 1,072 Defense Contract Audit Agency (“DCAA”) incurred cost reports issued between September 2013 and July 2015. In its review, the DODIG evaluated the appropriateness of DCMA actions on DCAA findings reported in the 22. Read More.
Topics: contracting officers, Defense Contract Audit Agency "DCAA", Defense Contract Management Agency "DCMA", Department of Defense Office of Inspector General, DoD Contract Audit Follow-up System, Federal Acquisition Regulation "FAR", Incurred Costs
Can Contractors Rely on Previous DCAA Audit Findings?
By: John Ford , Senior Consultant, Government Contractor Services Group One of the more frustrating things that contractors face is Defense Contract Audit Agency (“DCAA”) auditors changing their minds about the allowability of costs. This is particularly troublesome if the contractor has been including the cost in its indirect cost pools for years without DCAA questioning the allowability of the cost, then, without warning, DCAA questions the cost and alleges that the cost is expressly unallowable. Compounding this is the fact that the claim by DCAA is asserted several years after the cost was incurred. In the meantime, the contractor has included. Read More.