Is DCAA on the right track?

[Gnatman]

I guess this topic is directed to the Government COs out there who rely on DCAA to perform audits of proposals, and rates to price contract actions. More than not, these contract actions are time dependent, are large dollar, are not competitive or commercial, and cost and pricing data is required. The ground rules & time limitations for the CO have not changed while DCAA has changed significantly.

DCAA HQ had issued a guideline in April 2010 for testing the adequacy of all proposals before an actual audit can be started. Add two or more weeks for this effort and expect the number of qualifications and limitations of the audit opinion to increase.

Next DCAA issued another guideline in June 2010 pertaining to audit comments when DCAA has not reviewed the rates within an existing FPRA. It is now DCAA policy to not comment of show the resultant cost or positions with respect to unreviewed FPRAs. The negotiator will be cautioned to wait for Audit results of the rates. In our current situation, the CO and his price analyst negotiated the FPRA after 2 months review and DCAA has not provided a rate audit after 6 months. Never mind this timing dynamic, Audits will comply with the guidance and negotiations will be that much harder.

I'm sure that the audit agency is on a quest to perfrom audits in accordance with GAGAS, but the potential delay and increased qualifications in audits are traps for each CO and the negotiation process. I have hopes that other COs will comment or list their problems and solutions.