The ban on using DCAA staff for non-DoD agencies has been lifted. DCAA may once again provide full audit support to other agencies effective October 1, 2016, as posted on September 30th as a Memorandum for Regional Directors (MRD).
DCAA lifted the ban because they reached their 18 month goal to reduce the Incurred Cost Submission (ICS) inventory.
What will this mean for contractors? Will halted previous agency audits rise from the dead? Or will DCAA review accounting and business systems for upcoming proposals? Time will tell if this is more of a sweet treat or terrible trick.
For more information about Aronson please contact Donna Dominguez at email@example.com or (301) 222-8232.
In a recent audit of Federal Acquisition Services (FAS)’s transition to electronic files, the General Services Administration (GSA) Office of Inspector General (OIG) concluded that “FAS has not effectively digitized Federal Supply Schedules contract files.” The objective of the OIG audit was to determine whether: (1) FAS completed all stages of the Federal Supply Schedules (FSS) contract digitization process, and (2) FAS’s official electronic contract files contain all contract documentation in a usable format and structure as required by federal regulations and FAS policy.
GSA Schedule contractors need to pay careful attention to a recent protest decision issued by the Government Accountability Office (GAO) in the matter of AllWorld Language Consultants, Inc., B-411481.3 (GAO Jan. 6, 2016). AllWorld filed its protest in response to the issuance of a task order to SOS International, Ltd. (SOSI). The order was awarded by the General Services Administration (GSA), on behalf of the Department of the Air Force, to acquire linguistic support services to be performed in southwest Asia.
The GAO found that SOSI was not responsive to the requirements of the solicitation because the functional descriptions of the Schedule labor categories SOSI proposed did not meet the technical requirements of the RFQ. The GAO held that SOSI’s quotation did not “contemplate providing personnel qualified to perform the solicited requirements.” This decision affirms several contracting principles relevant to Federal Supply Schedule (FSS) vendors. These principals, if ignored can result not only in rejected proposals but potentially, even where the proposal is successful, a protracted post-award protest.
In its Semiannual Report to the Congress for the period from April 1, 2015 to September 30, 2015, GSA’s Office of Inspector General (OIG) warns the agency faces major challenges in pricing and contractor compliance within the Schedules Program. The OIG reached this conclusion based, in part, on the results of the 30 GSA Schedule pre-award audits performed during the reporting period on contracts with an estimated value in excess of $3.1B. Of the total estimated value, the OIG recommended that $195M be put to better use.
The GSA Schedule contracts continue to generate significant sales and the OIG cites commercial sales practice disclosures and Price Reductions Clause monitoring as significant risk areas. Recently, OIG auditors have also focused their attention on labor categories and ensuring that contractors are fulfilling tasks orders with personnel who meet the qualifications stated on their GSA Contract. Significant findings in the audits from this period included (1) commercial sales practices information that was not current, accurate or complete; (2) proposed labor rates that were overstated; (3) ineffective Price Reductions Clause compliance monitoring; and (4) the use of unqualified labor.
The Department of Labor (DOL) recently formally released the results of their “audit the employee benefit plan auditor” campaign and the results were underwhelming, to say the least. Their report indicates that audit quality is actually getting worse, not better. While this is not shocking to the DOL, AICPA or many practitioners, including accounting firms, it has been shocking to the media and general public. The DOL and AICPA have indicated for several years that there is tremendous concern that benefit plan audits are not being performed in accordance with standards and they insist that employers should be very careful when hiring a plan auditor.
From an auditing perspective, benefit plan audits are very different from corporate audits, and the technical requirements resulting from the IRS Code and ERISA make them very unique. The DOL has long contended that accounting firms need to perform a certain number of engagements to truly be qualified to do the work.