Tag Archives: DCAA

Government Contracts Pricing Webinar: Issues, Challenges, and Systems

Berkeley Research Group and K&L Gates co-hosted a webinar on September 18, 2013, discussing the latest issues and challenges faced by contractors when pricing government contracts. The session included a discussion of the increasing trend in FCA investigation and DCAA/OIG audit activity as it relates to contract pricing and some of the issues that arise during audits and investigation of pricing matters.

In addition, the session discussed challenges faced by contractors in complying with pricing requirements of both FAR Part 15 and commercial item acquisitions. Finally, the session provided an overview of system requirements and best practices to consider when facing the complexities of pricing government awards.

Click here to view the program.

DCAA Access to Contractor Employees

On July 30, 2013, the Defense Contract Audit Agency (DCAA) issued a Memorandum for Regional Directors (MRD) (13-PPS-015(R)) addressing the recent debate over auditors’ access to contractor employees. While DCAA continues to maintain that access to contractor employees is essential for its audit activities, many contractors are pushing back, arguing that FAR Part 52.215-2 grants DCAA access to records but not necessarily employees.

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DCAA Audit Guidance on Placing Reliance on Scanned Images

On August 15, 2013, the Defense Contract Audit Agency (DCAA) issued a Memorandum for Regional Directors (MRD) (13-PPS-016(R)) providing new guidance on testing contractors’ document scanning/imaging processes in order to establish reliability of scanned documents in lieu of hard copy originals. FAR 4.703 permits the use of scanned images in lieu of original documents for record retention purposes.

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DCAA Audit Guidance on Detecting Instances of Fraud in Attestation Engagements

By: Kayla See

On July 30, 2013, the Defense Contract Audit Agency (DCAA) issued a Memorandum for Regional Directors (MRD) (13-PAS-014(R)) regarding “Audit Guidance on Detecting Instances of Fraud in Attestation Engagements.” This memo reiterates the requirements for DCAA audit teams to design examination engagements to detect instances of fraud and other noncompliance with applicable laws, regulations, and contract and agreement terms and conditions that may have a material effect on the subject matter. The memo supplements previously updated language within the DCAA’s Contract Audit Manual (CAM 4-702) and associated training provided to auditors in March and April of this year.

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Government Contracts Pricing: Issues, Challenges, and Systems Webinar

September 18, 2013
12:00 – 1:00 PM EST

Berkeley Research Group and K&L Gates will co-host a one-hour webinar discussing the latest issues and challenges faced by contractors when pricing government contracts. The session will include a discussion of the increasing trend in FCA investigation and DCAA/OIG audit activity as it relates to contract pricing and some of the issues that arise during audits and investigation of pricing matters. In addition, the session will discuss challenges faced by contractors in complying with pricing requirements of both FAR Part 15 and commercial item acquisitions. Finally, the session will provide an overview of system requirements and best practices to consider when facing the complexities of pricing government awards.

Click here to register.

Update on Unallowable Costs for Ineligible Dependent Health Care Benefit Costs

By: Mary Karen Wills

On February 17, 2012, Shay Assad, the director of Defense Procurement and Acquisition Policy (DPAP), issued a memorandum regarding “Unallowable Costs for Ineligible Dependent Health Care Benefits.” This memo reiterated that costs incurred by contractors for ineligible dependent healthcare are unallowable as they represent invalid claims made by employees. The memo affirmed that DoD would not pursue penalties under FAR 42.709 related to these costs, but that DoD intended to amend the DFARs in this regard to enable it to pursue penalties in the future.

Fast-forward to March 28, 2013: DCAA issues Audit Guidance Memorandum 13-PAC-004(R) transmitting the DPAP guidance to its auditors (http://www.dcaa.mil/mmr/13-PAC-004.pdf). DCAA affirms that auditors should not pursue application of penalties under FAR 42.709 related to questioned ineligible dependent healthcare benefit costs. In addition, DCAA auditors are instructed not to cite contractors for CAS 405 noncompliance when they fail to exclude these costs from Government contracts.

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