Ensuring Compliance with Federal Contracts
The Changing Landscape
Tim A. Di Guiseppe
www.tdgovernmentsolutions.biz
814-242-2410
High-Visibility Procurement & Audit Issues
• Impact on DCAA interaction with contractors after GAO
reports
– No longer providing interim audit results
• Limits ability to take corrective actions before issuance of audit report
– No longer advising on how to remedy audit issues
• Recommendations limited to “correct it” – not how to correct
– Internal control audits are now limited to “Pass-Fail”
• No discussion on the significance of an internal control deficiency
• Eliminating Flexibility and Auditor Judgment
– Forces any and all audit observations into an audit report
– Protects DCAA from claims of failing to report audit issues
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High-Visibility Procurement & Audit Issues
• Business Ethics & Conduct and Mandatory Disclosure
– FAR subpart 3.10 Contractor Codes of Business Ethics and Conduct
(COBEC)
• Any contract over $5 million – COBEC must be in place with appropriate training of
personnel and adequate policy and procedures
– FAR subpart 9.4 Debarment, Suspension and Ineligibility
• Mandatory disclosure of certain violations to agency OIG
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fraud, civil false claims act , significant overpayments on government contracts
Based on creditable evidence (not defined)
In a timely manner (not defined)
Any cited violation know by contractor up to three years after final payment
Some OIGs have provided disclosure forms on their public websites
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High-Visibility Procurement & Audit
Issues
• Contractor Financial and Management Internal Controls
– Financial and Management internal control audits
• More stringent application of audit procedures in assessing compliance with DCAA
control objectives
• More audit findings deemed significant regardless of materiality
– DCAA audit guidance
• Internal control weakness that result in or could result in miss charging – reported
as significant deficiencies and material weakness
• “Inadequate in Part” no longer allowed – Adequate / Inadequate only
– Inadequate – auditors to encourage CO to suspend a portion of billed costs
• Limited Scope Internal audit –
– If an internal control deficiency is found during non-internal control audits
– Must pursue a limited scope audit of the identified deficiency
– If proven – entire system could be deemed inadequate
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High-Visibility Procurement & Audit Issues
• Control Environment and Overall Accounting controls
– DCAA has often challenged “gaps” between contractor procedures and
DCAA Internal Control Matrix, which include DCAA expansive and selfdefined controls (not expressly stated in FAR)
– Expect DCAA to use the rewrite of FAR Part 3 and Part 9 to their
advantage in citing contractor systems as inadequate
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High-Visibility Procurement & Audit Issues
• Billing Systems
– Based on what we have discuss so far, this functional system we
believe will generate more audit attention going forward, with
possible outcomes of disallowing/suspending billed costs, revocation
of direct billing privileges, challenge of provisional indirect rates, and
returned incurred cost proposals as inadequate.
– DCAA will focus on Contractor systems’
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Ability to provide adequate and timely incurred cost submissions
Adequacy of system for capturing unallowable costs
Ability of system to ID overpayments and prompt return of funds
Adequate tracking of actual incurred cost for flexibly-priced contracts
Timely adjustments of invoices for year-end final indirect rates
Adequacy of written procedures
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High-Visibility Procurement & Audit
Issues
• Labor Charging and Timekeeping
– DCAA trends in challenging labor charging internal controls include:
• Employment of uncompensated overtime practices (salaried personnel), to include
all employees regardless of materiality
• Use of highly-detailed work authorization forms, to include information ordinarily
not captured on such forms (such as contract scope)
• Ability of contractor to identify changes in submitted time charges, especially
within an electronic timekeeping environment
• Prompt employee certifications and submission of daily time charges , with the
definition of “prompt’ at the auditor discretion
• Expectations that employees will know where the hotline posters are located as
well as be able to confirm that the employee has been trained in COBEC
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High-Visibility Procurement & Audit Issues
• Pre-award and Post-award Accounting Systems
– Contractors not considered “major” are often subject to financial and
cost accounting systems internal control audits.
• Areas of focus include:
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General practices of direct and indirect cost allocation
Capturing unallowable cost
Billing costs out of the system
Accurately capturing cost by project
Financial stability of the company regardless of size
– DCAA will consider written procedures as mandated for all cost
accounting and contracting functions
– Contractors should revisit existing formal procedures before such
audits
• Are they adequate
• Are all procedures formalized
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High-Visibility Procurement & Audit Issues
• Accounting for Unallowable Costs
– DCAA has appeared to embrace a much more narrow interpretation of
FAR 31.201-6 and the provisions incorporated from CAS 405
• DCAA has shown a reluctance to accept less formal cost accounting systems for
identification of unallowable incurred cost
• DCAA has deemed systems that do not have specific GL accounts for capturing
unallowable cost as not compliant with FAR and CAS
• Contractor must be prepared to demonstrate their system is compliant
• Contractor need to become familiar with FAR 42.709 which establishes guidelines
for assessing penalties on unallowable indirect costs (42.709-1(a)), to ensure DCAA
has properly followed the guidelines
– Which contracts are subject to penalties
– When waivers of penalties are mandated (42.709-5)
– DCAA will continue to aggressively recommend penalties on
unallowable cost.
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High-Visibility Procurement & Audit Issues
• Allowability of specific costs
– Organization Costs
• Unallowable under FAR 31.205-27 – documentation is important
– Professional and Consulting fees
• While allowable FAR 31.205-33(f) requires adequate documentation such as
– Agreement
– Detail invoices
– Work products
• While FAR has a loose definition of documentation, DCAA sets it own higher standard, so
be prepared
– Public Relations and Advertising
• High focus area for DCAA – triggers are
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Open house to general public
Anything that looks and smells like a trade show
Direct selling activities (allowable) where evening events/business meeting are conducted
Any PR/advertising activity conducted during the time frame of a merger or acquisition
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High-Visibility Procurement & Audit Issues
• Allowability of specific costs (con’t)
– Business meeting and conferences
• A target of DCAA especially if there is a hint of recreation associated with the activity
– Employee business travel
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Viewed as a high risk are by DCAA
Constraints in FAR 31.205-46 add to the fun
Must follow the FTR/JTR
DCAA has tried to apply the constraints of FAR 31.205-46 to consultants or
subcontractors. The FAR is by no means clear on this issue
– Executive Compensation
• An area where DCAA likes to claim it survey proves such compensation as unreasonable
• While an annual salary ceiling is set by OFPP, DCAA evaluates work performed to salary in
determining reasonableness – DCAA interpretation
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High-Visibility Procurement & Audit Issues
• Allowability of specific costs (con’t)
– Employee Bonuses
• Less likely to be challenged if awards are paid in accordance with a documented
agreement (policy or plan), consistently followed and the amount of the awards are
supported.
– Legal fees
• FAR 31.205-47 – complex regulation – component must audited involve cost related
to proceedings involving a government (federal, state, local, foreign)
• Depending on outcome, many cost may be unallowable
• If allowable under FAR 31.205-47(e)(3) recovery limited to 80%
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High-Visibility Procurement & Audit Issues
• Adequate and Timely Incurred Cost Proposals
– Proposals will be rejected under the following circumstances
• Not submitted within six months of year end
• Not prepared in sequenced schedule format or not inclusive of all schedules and
data as identified in Chapter 6 of the DCAA Information for Contractors Pamphlet
• Include amounts which should but do not tie to other schedules
• Include any cost which appear to be unallowable
• Not submitted in electronic form
• Not certified as required by FAR 42.703-2
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High-Visibility Procurement & Audit Issues
• FAR Part 31 Reasonableness Criteria
– Based on experience, DCAA will continue to elevate the use of
reasonableness as a basis for questioning incurred and billed costs and
in passing judgment on a contractor’s accounting practices and related
internal controls.
• Allocability Issues
– DCAA has shown a trend in applying CAS allocability provisions on
non-CAS covered contractors (such as CAS 403 Home Office Allocation)
– DCAA often challenges Allocability of cost after the fact claiming that
a different methodology is a better or best allocation
– No requirement to use the “best” allocation methodology, only that
cost are reasonably assigned to cost objectives based upon causal and
beneficial criteria
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High-Visibility Procurement & Audit Issues
• Resolution of Audit Issues
– The trend continues where DCAA does not provide any or sufficient
data in writings that clearly defining the basis for questioned costs or
inadequate internal controls, nor are contractors given sufficient time
to evaluate and respond to audit findings
– Contractors are entitled to satisfactory explanations and ample
opportunity to review and respond to audit challenges.
• Chapter 5 of the DCAM requires auditors to discuss audit issues and basis of their
finding with the contractor
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DCAA and Access to Contractor Records
• DCAA reasserts and redefines its access to records an intentional
disregard of the requirement in clause FAR 52.215-2
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Examples
• Request all data on code of conduct violations and consequences – not required under
FAR 52.213.(b)(3)(i) which cites specific violation that must be disclosed
• Request that contractors provide data on violations to DCAA and ACO within 5-10 days –
The mandatory disclosure rules explicitly state that disclosure is to the Agency IG with a
copy to the CO
• DCAA requests contractors furnish documentation to “verify that the external CPA does
not provide accounting services to the contractor – This pertains to PCAOB Independence
standards for which DCAA has no authority
• Available data should be provided to DCAA “upon request” and that DCAA have direct
access to contractor employees – internal documents suggest 3 to 5 days
– Not supported by the FAR – particularly access to contractor employees
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Proposed DFARS Rule: Withholding Payments to
DoD contractors
• Background
– Late 2008 FAR (mandatory disclosure) required contractors to disclose
certain violations of law, Civil False Claims Act and significant
overpayments
– DCAA made a fundamental shift away from cooperation with government
contractors
– 2008 and 2009 DCAA audit guidance memoranda imposed rigorous
• New timelines for responding to audit request for records and access to contractor
personnel
• Auditors could no longer find contractor “internal control systems” inadequate “in-Part”
but must find the entire system inadequate and take action to suspend payment of
invoices where a single control objectives was not met
• Established procedures to quickly escalate pressure on contractors who fail to
immediately comply with records request or who denied auditors access to personnel
– “Brave New World” auditors exercise less discretion and demonstrate
more “skepticism”
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Proposed DFARS Rule: Withholding Payments to
DoD contractors
• Proposed Withholding Rule
– Defines six separate business systems and states that a CO “will
immediately withhold ten percent of each of the contractor’s payments
under this contract” based on the CO’s determination that any of those
business systems is deficient,
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Accounting Systems
Earned Value management Systems
Estimating Systems
Material Management and Accounting Systems
Property Management Systems
Purchasing Systems
– If a contractor submits an acceptable corrective action plan within 45 days
of receipt of a CO’s notice of intent to withhold, but has not completed
the corrective actions, the CO will reduce the withhold to 5% of each
payment until the CO determines that the contractor has corrected the
deficiencies
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Proposed DFARS Rule: Withholding Payments to
DoD contractors
• Proposed Withholding Rule (cont)
– A CO may withhold payments for deficiencies in more than one
business system, but the cumulative percentage of payments withheld
is limited to 50% of contract payments.
– Nonetheless, if the CO determines that there are one or more system
deficiencies that are “highly likely to lead to improper contract
payments being made, or represent an unacceptable risk of loss to the
Government” then the CO “will withhold up to 100% of payments”
until the CO determines that the contractor has corrected the
deficiencies.
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Proposed DFARS Rule: Withholding Payments to
DoD contractors
• Summary
– COs allowed to withhold 10%, 50% or even 100% of Interim payments
to contractors where the CO determines that a contractor’s “business
systems” are deficient.
• Poses a significant business risk to DoD contractor of all sizes
• Continues a trend of increasing compliance burdens
– Contractors should
• Reevaluate the cost of compliance
• Review current business systems for potential deficiencies
• Make any identified corrections before being threatened with withholding
of payments
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Proposed DFARS Rule: Withholding Payments to
DoD contractors
• Recommendations
– Consider performing an external audit or other assessment of internal
controls related to the business systems subject to the proposed rule
– Such exercises will allow contractors to address any potential
weaknesses in advance of an audit, hopefully avoiding “inadequacies
in business systems”
– Maintaining well-functioning business systems provide visibility over
critical contract metrics and allows contractors to manage workload
and costs
– Contractors must consider the increase risk and cost imposed by the
proposed rule and make informed decisions about the business tools
they invest in and the types of contracts for which they choose to
compete
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Contractor Business Systems and Internal
Controls
• The proposed DFARS rule on Payment withholds
– defined contractor business systems
– Will implement compliance enforcement mechanism
– Allows for withholding up to 100% of payments for deficiencies
• While the rule clearly assigns the decision making authority to the
CO, they rely on DCAA to identify deficiencies
• The expectation for business systems is:
– Provides reasonable assurance of compliance to laws and regulations
– Data is reliable
– Risk of misallocation and mischarges of cost are minimized
• It fails to define any new measurable objective standards
– Except those already defined (e.g. MMAS inventory accuracy 95%)
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Contractor Business Systems and Internal
Controls
• The Government views the withhold provision of the proposed rule as
necessary because
– Despite DCAA interpretations, current regulations do not provide for administrative
withholds for deficiencies
• As proposed, a contractor could find itself without payments based upon
no actual mischarges or overbilling, but merely a deficiency which is
“highly likely to lead to improper contract payments”
• If “highly Likely deficiencies” are found, one would think a moderately
skilled auditor could find actual mischarges, thereby eliminating the need
to impose withholdings based auditor’s interpretation of what qualifies as
a “highly Likely deficiency”
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Contractor Business Systems and Internal
Controls
• While FAR 52.203.13 imposes internal control requirements on contracts
in excess of $5 million and exempts small business
• The proposed DFARS rule does not set a dollar minimum or exempt small
business
• Thereby imposing higher standards on DoD contractors than those
imposed on civilian agency contractors
• There is significantly more to this propose rule than has been covered so
far. We encourage contractors to read the propose rule.
– Go to www.regulations.gov search for DFARS-2010-0001-0001
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Ensuring a compliant cost accounting system
• The changing environment in which DCAA conducts it system
audits puts a contractor at greater risk of audit findings such
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Improper allocation of costs to final cost objectives
Questionable treatment of unallowable costs
Questioned indirect rate structures
Reasonableness of allowable and allocable costs
Inadequate internal controls
Non compliance with FAR and if applicable to CAS
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Ensuring a compliant cost accounting system
• How to reduce the risks
– Ensure your key employees have a through understanding of the rules as
outlined in the FAR and CAS and how and which one apply to your
business
– Obtain an understanding of what DCAA looks for in an Accounting Systems
audit
• Refer to Chapter 5 of the DCAA audit manual, and
• Contractor Information section of the DCAA website
• Both can be found at www.dcaa.mil
– Perform a self assessment of your accounting system, or
– Have an outside source perform a mock DCAA Accounting systems audit
– If your business is such that it is not cost effective to have full time staff
with the skill levels necessary to perform the above steps, look to outside
experts. The little bit of money spent on such experts could save you
significant dollars in the future
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Prime Contractor Management of
Subcontractors
• A significant shift in DCAA expectations for prime contractor
compliance with FAR 42.202(e)(2)
– Primes are being held to a higher standard for “management” of
subcontractors
• Shifting towards the prime auditing the subcontractor when an auditable
subcontract is awarded
• Insisting that the prime flow down the same access to records clause (52.215-2) to
its subcontractors as applies to the prime
• The prime is to gain and document an understanding of a subcontractors
accounting and billing system and to verify invoices to the subcontractor books and
records
• Monitor subcontractors provisional billing rates and ensure timely submission of
incurred cost proposals
• Internal Control Questionnaire – number of employees, direct and indirect
headcount, segregation of unallowable costs, job cost reconciliation, billing internal
controls, etc.
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Prime Contractor Management of
Subcontractors
• While the FAR does not really answer the question of what is
expected of the prime in managing subcontractors, DCAA is pushing
the prime to ask for substantially more information and more
access to subcontractor records.
• Subcontractors are being forced to decide if and how a prime will
have access to its books and records
• Attributable to DCAA decision to reverse it long standing role with
respect to audits of subcontractors
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Prime Contractor Management of
Subcontractors
• Nothing in FAR 42.202 suggest that the prime’s management of its
subcontractors includes audits subject to Government auditing
standards or generally accepted auditing standards
• FAR 42.202(e)(2) provides for only three exceptions in which the
prime’s management role would be expanded
• (2) The prime contractor is responsible for managing its subcontracts. The
CAO’s review of subcontracts is normally limited to evaluating the prime
contractor’s management of the subcontracts (see Part 44). Therefore,
supporting contract administration shall not be used for subcontracts
unless -• (i) The Government otherwise would incur undue cost;
• (ii) Successful completion of the prime contract is threatened; or
• (iii) It is authorized under paragraph (f) of this section or elsewhere in this
regulation.
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Major Defense Acquisition Program and
Technical Data Packages
• DoD interim rule (effective 2/24/10) implements Section 202
of the Weapon Systems Acquisition Reform Act which requires
all MDAP programs include measures to ensure competition
or the option of competition, at prime and subcontract levels.
• The rule also requires that acquisition plans for MDAPs
include measures that document the rational 1) for selection
of subcontractor tier or tiers; 2) measures that will be used to
ensure competition, or the option of competition
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Major Defense Acquisition Program and
Technical Data Packages
• Measures to ensure competition or options for competition
include such specific items as:
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Competitive prototyping,
Dual-sourcing,
Unbundling of contracts,
Funding of next-generation prototype systems or subsystems,
Use of open architecture to facilitate upgrades,
Use of build-to-print approaches,
Acquisition of complete technical data packages,
Periodic competitions for subsystems upgrades,
Licensing of additional suppliers, and
Periodic system or program reviews addressing the competitive effects
of program decisions
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Major Defense Acquisition Program and
Technical Data Packages
• To ensure fair and objective “make-buy” decisions by prime
contractors, contractors must:
– Give “full and fair consideration” to outside sources for the
development of subsystems and components
• The rule also requires that:
– solicitations and contracts must provide for government surveillance
and assessment of the process and the extent to which prime
contractors gave “full and fair consideration” to all potential sources
– Source-of-repairs awards for maintenance and sustainment services
on major weapons systems should be made on a competitive basis to
the maximum extend practicable
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Major Defense Acquisition Program and
Technical Data Packages
• What does this all mean
– The number and availability of MDAP related prime and subcontracts
awards on “Sole Source or Limited Competition Basis” is likely to decrease,
triggering increase overall competition
– DoD will increase its use of methods and strategies to increase
competition, such as unbundling of contracts, use of open architecture,
and dual sourcing
– DoD will also increase competition by requiring delivery of complete
technical data packages.
• Contractors may find it increasingly difficult to withhold proprietary data or unduly
restrict the DoD’s rights to data delivered under MDAP contracts
– Contractors will feel an increased burden to document and justify
noncompetitive “make-buy” decisions that seem self-serving, such as a
contractor’s decision not to source work to outside entities
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How to Survive a DCAA Audit
• Surviving a DCAA audit can be tricky if you do not take the
necessary steps to ensure that you
– Understand the scope of the audit
– Manage the audit process
• Documentation
• Personnel
• Within Scope
– Respond appropriately to DCAA request
• Timely
• Within Scope
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How to Survive a DCAA Audit
• What is a successful audit?
– Contractor and contractor systems are compliant with all appropriate
regulations and statues
– A successful audit at a minimum meets the following criteria
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DCAA applies the audit procedures objectively
The audit is conducted in accordance with the audit plan
The company plans for support during the audit are appropriate
The audit is fair and balance highlighting both positive and negative aspects of the
audit subject
• DCAA audit findings are adequately documented and presented fairly and
appropriately in the audit report, and
• DCAA audit process presents a minimum disruption to the contractor’s normal
operations
– A successful audit = No Findings that significantly impact operations
and finance
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How to Survive a DCAA Audit
• Surviving a audit means not standing by and letting it happen
– Plan head
– Understand the types of audit DCAA performs
• The types of audits and audit programs can be found at DCAA website
www.dcaa.mil
– Understand your status as a contractor
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Small, medium or large
Are your contracts competitively awarded or negotiated or a mix
Commercial item contracts
Are your contracts Cost Accounting Standards (CAS) qualified
– Understanding your status as a contractor will help in planning for the
types of audits you would be subject to
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How to Survive a DCAA Audit
• Once the types of audits your company is subject to have
been identified, the planning process should include at a
minimum the following steps
– Insist on an entrance conference
• What specific areas of the company’s financial or operational procedures and
records are to be audited?
– Ensures that everyone understands the specific scope of the audit and agrees not to exceed it
– Insist that the auditor be specific so management can plan, prepare, and respond appropriately to the
scope of the audit and the auditor’s request
• What approach does the auditor intend to use?
– Enables company management to begin compiling the required records
– Helps in understanding how the auditor intends to work, ensuring there will be no surprises
» Limited audit or full scope
» Sampling techniques or 100% transaction audit
» Rely on company assessment of inventory values or insist on observing in-process transactions
and random physical counts
– These questions should be discussed in the entrance conference
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How to Survive a DCAA Audit
– Insist on an entrance conference (cont)
• Which company personnel need to be available?
– Advise functional managers and employees of the pending audit so they can be prepared and available
as needed
• What is the timing of the audit?
– Knowing the length of the planned field work helps minimize interference with normal operations
• Other parameters?
– If there are unique issues about the organization or the proposed audit that could impact the audit, you
should resolve them during the entrance conference.
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Offsite facilities or special access facilities
Will the auditor use specialist to focus on one or more areas of audit
• Appoint an internal liaison
– Appoint a single point of contact
• Selecting and preparing the right individual for this job is one of the most important
issues in controlling the success of audits and minimizing their impact on company
operations
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How to Survive a DCAA Audit
• Appoint an internal liaison (cont)
– Responsibilities and goals
• Maintain a log of all information and documents provided to the auditor during the
audit
• Purpose is to facilitate the audit process
• When the auditor needs access to people or documentation, the liaison informs the
appropriate managers and staff that they need to make themselves available and
that certain records and documents must be ready
– Attributes of successful internal liaisons
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Tenure within the organization and good overall understanding of operations
Experience in several different departments
An understanding of the products and/or services the company sells
Exposure to, or experience with DCAA audits
An appreciation for both the financial and the operational sides of the organization
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How to Survive a DCAA Audit
• Assemble the management Team
– Prevent surprises
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The management team plays a crucial role in a smooth audit
Unprepared managers cause many serious audit problems
Inform the managers of all affected departments about the nature of the audit
Remind them to cooperate in all respects within company and regulatory policy, in
a timely and responsive manner
• Inform the team of the agreed upon audit scope, and caution them to keep the
audit within those bounds
– Coordinate Internally
• An effective way to streamline an audit is to tell managers and employees ahead of
time how to prepare for the audit
• To minimize interruptions, managers should have the liaison schedule all meeting
and request for documentation
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How to Survive a DCAA Audit
• Establish an accurate, accessible record-keeping system
– Know how to access documentation
• Once the audit approach is known, gather and organize the required records
• Establish and maintain a record keeping system that meets the needs of the organization
and complies with the record retention requirements of the FAR
– Review section 4.7 of the FAR
• Covers the minimum retention requirements for certain types of documents and records
• Operating under the rules of compliance is one thing
• Organizing those records and making them accessible for the auditor is another
– Establish a record retention system that will meet audit objectives
• The focus of DCAA audits is on the final cost objective, which means they generally work
from the contractual document back to individual transaction records.
• Record retention system should follow this path
• E.G., if you use a job cost system, you may want to group all records related to a
particular contract
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How to Survive a DCAA Audit
• Be Responsive
– Maintain a positive relationship
• Through the liaison, provide requested information in a timely fashion, while
allowing a reasonable time for function or department manager to gather the data
• When appointment are schedule with the auditor, be punctual and respond to
questions in a clear and concise manner
– Ensure internal cooperation
• Be sensitive to conflicting responsibilities
• Supporting audits is not typical for most employees
• Managers may need to help employees handle their normal workload while they
participate in the audit
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How to Survive a DCAA Audit
• Maintain a detailed log
– Here are some reasons why it is essential to maintain an accurate log
of every document provided to the DCAA auditor
• The auditor may change his or her opinion upon review or lack of review of
documentation
• The auditor may lose or temporarily misplace documents
• The auditor may not accurately account for the documents, and thus may claim
non-receipt of an item
• The auditor may misinterpret information in documents
• It is important for management to know and understand what information the
auditor relied upon in reaching the conclusions in his or her report
– Protect your interest
• Never give the auditor original documents, always copies
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How to Survive a DCAA Audit
• Do not allow the audit to exceed the agreed scope
– Control the audit process
• Use the following tips to control the audit scope in accordance with the plan you
agreed on during the entrance conference
– The internal liaison should retain a list of the areas to be audited as outlined in the entrance conference
– If the auditor makes any request that appear to extend beyond the agree-upon scope, tactfully refer to
the list
– If the auditor fails to work within the agree-upon scope, contact and discuss the issue with the auditor’s
supervisor
– Avoid creating unnecessary documentation
• Do not develop documentation or analyses your company does not normally
maintain, even if requested by the auditor. e.g.
– For example, suppose an auditor begins work on an issue related to the labor required to weld Product
A, which is one of your companies products. The company normally only produces reports that indicate
the total welding hours incurred by all weld shop employees for all components manufactured. The
auditor questions whether the average hours in this report represents the average hours for Product A
and request you to develop a report for Product A only. If your company does not ordinarily extract and
analyze this information, you are under no obligation to create that information for the auditor
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How to Survive a DCAA Audit
• Insist on a list of required interviews
– Control access to company personnel
• Require a list from the auditor of employees to be interviewed
• Ensure the internal liaison is present at each interview and that a log is maintained
of the relevant points discussed
– Manage spontaneous interviews
• A type of spontaneous interview is where the auditor venture onto the production
floor to interview randomly-selected employees.
• Spontaneous audit procedures should still allow the internal liaison to coordinate
with department managers so workers are minimally disrupted
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How to Survive a DCAA Audit
• Review the preliminary findings at the function/department
level
– Functional/department representatives should have opportunities to
discuss and respond to any conclusions the auditor has reached
– This is a two stage process
• Stage #1 Summarize findings – Once the auditor has reviewed a function, he/she
should sit down with the functional manager and summarize the findings. This
provides the manager the opportunity to review the summary and if necessary,
question the auditor’s conclusions
• Stage #2 Prepare preliminary report – At the end of the audit, the auditor should
prepare a preliminary report covering all of the findings resulting from the audit.
This report provides a second opportunity for management to questions and
discuss errors and provide written responses to the audit findings
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How to Survive a DCAA Audit
• Insist on an exit conference at the company level
– Review the preliminary audit report
• Insist on a thorough exit conference with the auditor and the auditor’s supervisor
and the company’s audit management team to hear purported findings and ensure
that they are consistent with the evidentiary documentation provided to the
auditor
– Follow the routine
• An exit conference should be part of the standard routine of an audit. In fact, the
DCAAM specifically states general procedures regarding the entrance and exit
conference
– Read the audit report carefully
• Company management should take every opportunity to look at the written report,
provide input based upon the observations and discussions during the audit and
demand that the findings appear correctly
– Resolve inaccurate findings
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