To keep the process moving forward as quickly as possible and to obtain resolution at the lowest levels possible, the Department of Defense Procurement and Acquisition Policy (DPAP) issued a memorandum on resolving contract audit recommendations in December 2009; these procedures were furthered clarified in May 2010.
The DPAP memorandum dictates, when the contracting officer has a basis for disagreement with the audit findings, the contracting officer should first attempt to resolve the issues and recommendations identified with the DCAA auditor. In such cases,The contracting officer shall:
Accordingly, DCAA shall:
DCAA issued open audit guidance 10-PAS-015(R) to further clarify procedures to quickly resolve disagreements as they arise. The initial step is a discussion with the FAO Manager and the contracting officer, followed by the Regional Director and the Component’s Senior Executive or Flag Officer in the contracting officer’s chain of command. If the disagreement remains unresolved, Regional Directors should elevate the disagreement to Headquarters, policy for resolution with senior leaders in the Department. DCAA will update Contract Audit Manual Sections 1-403.3 and 1-403.4 to reflect the current guidance.
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