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Risk-Based Initiative for Contract Closeout: One CMO’s Perspective. Presented By: Pam Gouldsberry, Contracts Group Chief Corlee Brown, ACO Linda Rowe, ACO Shirley Leonard, ACO. Agenda. Background – DCMA VA Closeout Overview from DCMA VA Perspective T&M Initiative
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Risk-Based Initiative for Contract Closeout:One CMO’s Perspective Presented By: Pam Gouldsberry, Contracts Group Chief Corlee Brown, ACO Linda Rowe, ACO Shirley Leonard, ACO
Agenda • Background – DCMA VA • Closeout Overview from DCMA VA Perspective • T&M Initiative • Alternative Closeout Approaches • High Risk Contractor • Anteon Closeout Initiative
Background – DCMA VA Challenges: Unique Situation • Workload Staffing Priorities Aggressive Goals
0-12 Months Varies due to circumstances Varies 6 Months 12-24 Months 4 Months Physical Completion CLOSED DCAA Actuals 8 –12 months DCAA Actuals 30 Days Audit of Final Incurred Cost Proposal Due Review/Process Final Voucher Contractor FY Ends Final Voucher Due Final Incurred Cost Proposal Due Process Payment of Final Voucher Industry DCAA DCMA DFAS Services Settlement of Final Rates Flexibly Priced Closeout Timeline From Physical Completion to Closed OPRs
DCAA DCMA Coordinate all Closeout Actions Indirect Cost Props Final Inv/Vchrs Pkg Refund Checks Reconciliation Final Payment Industry DFAS Contract Closeout Key Players Services Achieving the Goal Together Additional Funding Property Disposition Replacement Funds Acceptance Indirect Cost Audits Final OH Rates Subcontract Audit FV Review ONE FOCUS
T&M Initiative • What is it? • Risk-Based Approach • Utilize fixed labor rates • Accept provisional G&A rate • Streamlines the Contract Closeout Process • Settlement of Rates not required • Abbreviated Final Voucher • Expedites payment and closeout 60% T&M Contracts
T&M Initiative – Teaming for Success • Contractor Participation • DCMA/DCAA Kickoff meeting for initial low risk contractors • Lack of individual contract audits is an incentive • Communicate conflicting priorities (canceling funds, etc.) DCAA
T&M Initiative Process • Selection of contractors for participation • Performance of risk assessments • Getting contractors to participate • Timely submission of final vouchers • Sampling of final vouchers
Risk Business Judgement Partnering Benefits DCAA • Reduced audit effort on low risk contractors DCMA • Reduced reconciliation effort allowing ACO to focus on active work • Prevents funds from canceling • Contract closes within FAR mandated timeframes Contractor • Abbreviated final voucher process saving time and dollars • Submit Final Voucher before Final Rate Settlement • Integrated Effort - DCMA, DCAA, Contractors
Results!!! • Contractors approved (low risk) 23/55 • High risk contractors (alternative approach) 4 • Contracts closed 3,151
High Risk Alternative Approach • Background • Contractor Cooperative • Billing System Deficiencies • Significant G&A Costs Questioned in prior audits • Contractor unable to generate sufficient volume of final vouchers/monthly basis
Overview of Risk-Based Process Memorandum of Agreement Between DCMA, DCAA, and Contractor • Identified 341 IDIQ Delivery Orders with rates settled • DCAA determined increment/decrement factor for each IDIQ contract • Unbilled amount< $50,000 contractor waived payment at Basic Level • All credits were refunded to Government
Benefits/Results • Contractor • Reduced Final Voucher Preparation • Closeout Backlog Decreased • Government • <60 days over 340 Delivery Orders closed • Wynne Phase III contracts closed (app. 200) • Replacement funds not required • Excess funds returned to Services
Anteon Closeout Initiative • Background • Low Risk Contractor • Multiple Acquisitions • Large Number of Overage Contracts with Delinquent Final Vouchers • Challenges • Close Large Number of Contracts (2,000+) • Meet Regulatory Requirements • Satisfy DCAA and DFAS Internal Operational Requirements ALL
Anteon Closeout Initiative • Process • MOA Between DCMA and Contractor • Agreement with DCAA and DFAS • Streamlined Submission Format • Accelerated Cumulative Allowable Cost Worksheet (CACWS) Audit
Anteon Closeout Initiative • Submission Format • Use Spreadsheet Format (CACWS) • Group Like Vouchers (Credits, Debits, Zeros) • Streamlined Final Documents • Form SF1034s, Releases, Assignment of Refunds, Rebates, and Credits) • Deviation for Form DD 1597 (Closeout Worksheet) • Concurrent Audit by DCAA
Anteon Closeout Initiative • Results • Final Vouchers with Documentation • 2,056 Contracts • Provided by Contractor in 30 Days • DCMA Reviewed 1,702 Final Vouchers • Currently in Payment Process • 734 Contracts • Closed 968 Contracts in 3 Months