Double Jeopardy – Incurred Cost Audits

DCAA’s (Defense Contract Audit Agency’s) policies and procedures for sampling low-risk incurred cost proposals, while certainly helping to reduce the Agency’s incurred cost backlog, has not been without its detractors in the contract administration community. There are anecdotal stories out there where contracting officers try to initiate their own reviews of incurred costs after receiving notification from DCAA that a particular contractor submission has been deemed low risk and should be relied upon to close contracts for that year. Contractors were understandably upset because of the apparent “double audit”. The problem became significant enough that the Defense Department amended its FAR Supplement (DFARS) to, in effect, tell contracting officers to knock off the second-guessing of audit results.

Source: PNWC’s Government Contracting Update: Double Jeopardy – Incurred Cost Audits