Posted November 18, 20159 yr comment_28958 A few years ago, the responsibility for determining adequacy of a Contractor's CAS Disclosure Statement transitioned from DCAA to DCMA. Prior to that, when DCAA would review for adequacy, they followed a checklist of sorts to review the form part( vs. the Continuation Sheets) that contractors also found helpful. It is no longer in the DCAM, and I can't find something like it in DCMA instructions. Does anyone have an old copy of this tool that they would be willing to share? I am trying to use it for training purposes. Thanks.
November 30, 20159 yr comment_29038 govtacct02, I have an Excel template I used to test disclosure statement interrelationships several years ago in a DCAA D/S adequacy audit. If you are a DCAA employee and would like me to send you the template, please reply with your name as listed in the Global address book and I will send it to you. Regards, srterral
December 2, 20159 yr comment_29062 morning, www.dcma.mil has a policy page on Cost Accounting Instructions, resources I think policy 120 scroll down to conformity I think that might be what you're looking for.
December 3, 20159 yr Author comment_29071 I am not a DCAA auditor. So srterral, I won't be able to take you up on your offer. Thank you anyhow. Joan - I do not see the term "conformity" in DCMA Instructions on CAS Compliance...or in Policy 120. Can you provide a more specific link? Thanks.
February 12, 20169 yr Author comment_29909 As a follow up - my local DCMA office provided the adequacy review program, that includes conformity. If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had.
February 12, 20169 yr comment_29915 28 minutes ago, govtacct02 said: As a follow up - my local DCMA office provided the adequacy review program, that includes conformity. If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had. Can you qualify this? I understand it to be that, while DCMA has determination responsibility, they rely on DCAA to perform the review and compliance. At least in my recent experience.
February 12, 20169 yr comment_29917 JMG, not so much. DCAA has formally abdicated responsibility for determining whether a contractor's D/S is adequate. It was always the ACO's responsibility to make a formal determination (similar to how Business Systems work) but now that determination is based on DCMA's work and not DCAA's work. DCAA does perform a review, and does assess adequacy as part of that review, but the auditors no longer express an opinion on the D/S adequacy. Quite honestly, I have no idea what value the DCAA review adds to the process anymore. The new process is confusing to all parties. H2H
February 12, 20169 yr comment_29918 Thanks Help. Interesting. So DCAA will still review but just provide objective results? I tend to think DCMA lacks the local knowledge to perform such reviews; they would have to reach out to a cost/pricing center or other team (similar to CPSR).
February 13, 20169 yr comment_29927 JMG in my experience the DCAA auditors read each section of the D/S and confirm that the contractor has provided an answer. Then they stop. For example, suppose the contractor has to identify whether the security function is direct, indirect or both. If both, the contractor must describe the circumstances for its differing treatment and identify the affected indirect pools. The auditor checks to see whether the contractor checked "direct" or "indirect" or "both" and, if "both" was checked, then the auditor makes sure that the contractor identified the affected cost pools. The contractor shrugs and answers the questions asked. The auditors shrug and do what they are told. The DCMA folks shrug and approve the D/S. At least, that's how it seems to me. I should add, though, that I've seen a few Cost Monitors and Price Analysts really dig into what the contractor is disclosing, and really try to understand what they should expect to see in proposals and invoices. That's a separate process from the D/S review, but it seems to be happening with some regularity. It makes me more comfortable with the D/S review "process".
