Current DCAA Initiatives. NCMA Boston Chapter March 14, 2012 s March 7, 2012. Recent Events Shaping Current Actions. GAO Reports: July 2008 (GAO-08-857) September 2009 (GAO-09-468) December 2011 (GAO-12-88) GAO Testimony October 2009 (GAO-10-163T)
NCMA Boston Chapter
March 14, 2012
March 7, 2012
July 2008 (GAO-08-857)
September 2009 (GAO-09-468)
December 2011 (GAO-12-88)
GAO Testimony October 2009 (GAO-10-163T)
Commission on Wartime Contracting in Iraq and Afghanistan
Final Report Dated August 2011
Prior DCAA Metrics Abolished
Independent Reference Reviews added
Audit Sample Sizes are Much Larger
Audits Take a Lot Longer to Complete
Fewer Audits Complete
More Auditors are Needed/On the Way
Reduction in Business Systems Monitored (10 to 6)
Previous Audit Work Moves to DCMA
Fin Cap (MRD 11-PPD-007(R))
Pricing Below $10M FFP/$100M Cost
Required the Secretary of Defense to develop a program to provide for the approval/disapproval of contractor business systems within 270 days of the act. It allowed for up to a 10% withhold on payments if one or more systems is disapproved.
DoD issued an interim rule effective May 18, 2011 which mandated withholding a percentage of payments when a contractor's business system has one or more significant deficiencies. Rule now final with minimal change effective February 24, 2012.
A "significant deficiency" is defined as "a shortcoming in the system that materially affects the ability of officials of the Department of Defense to rely upon information produced by the system that is needed for management purposes."
Six business systems are covered by this rule:
Allows the Government to impose withholds for business system(s) with significant deficiencies
Payments could be withheld on--
Withholdings only apply to contracts with the clause.
Complicates billing – two sets of rates/rules
FFP contracts are liquidated upon delivery of product and no longer subject to withhold after delivery
(clarified in the final rule).
Cost Accounting Standards applicability
803 - Extension of Applicability of the Senior Executive Benchmark Compensation Amount for Purposes of Allowable Cost Limitations under Defense Contracts
The prior statute limited reimbursement of top five executives to a cap established annually by Office of Federal Procurement Policy or OFPP (DCAA does the actual computation for OFPP). New law extends the reimbursement cap to all employees.
DFARs Case 2012-D028
A Federal Acquisition Regulation (FAR) final rule amends procedures for closing out contracts effective June 30, 2011
Better Pricing – FPI Contracts
Subject to DCAA Incurred Cost Audit
Fewer Service Contracts
Follow-up Information – Contact
Steven J. Tremblay
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