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April G. Stephenson Director. Professional Services Council February 25, 2009. Director’s Philosophy. Quality audits must not be sacrificed for any reason Continuous Process Improvement Efficient & effective accomplishment of DCAA mission
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April G. Stephenson Director Professional Services Council February 25, 2009
Director’s Philosophy • Quality audits must not be sacrificed for any reason • Continuous Process Improvement • Efficient & effective accomplishment of DCAA mission • Audits to ensure that the Government pays a fair and reasonable price for goods and services • Back to Basics • Need to understand what you are auditing • Face-to-face communication with the contractor employees • Ask questions, maintain auditor skepticism • Develop sound conclusions
DCAA Initiatives/Current Issues • Audit Guidance on Denial of Access to Records Due to Contractor Delays • Audit Guidance on Significant Deficiencies/ Material Weaknesses and Audit Opinions on Internal Control Systems • Audit Guidance on Limited Scope Audit Reports on Internal Controls
Audit Guidance on Denial of Access to RecordsDue to Contractor Delays MRD 08-PAS-042(R), dated December 19, 2008 • Reason for guidance memo - remind auditors of expectations for access to contractor records and personnel • Expectations • Quality and effective audits require timely access to records. • Documentation supporting the contractor’s assertion should be readily available and provided upon request. • Address some contractors use of “slow roll” response to data.
Audit Guidance on Denial of Access to RecordsDue to Contractor Delays MRD 08-PAS-042(R), dated December 19, 2008 • Expectations (cont.) • Supporting documentation includes access to personnel. • Auditors should generally obtain support directly from the person responsible for the information. • If Denial of Access to Records • Elevate issue in writing to higher level management – if not resolved. • Suspension or withhold costs and question the unsupported costs in the audit report, as appropriate. • If still not resolved, elevate to HQs for pursuing a subpoena.
Audit Guidance on Audit Opinions on Internal Control SystemsMRD 08-PAS-043(R), dated December 19, 2008 • Reason for change in guidance – • Ensure significant deficiency in contractor system is identified and addressed/corrected in a timely manner • Eliminate confusion on inadequate-in-part opinion and suggestions for improvement • Expectations • Audits of contractor internal controls are only performed at large contractors where deficiencies are significant • Clarify that a deficiency is a deficiency – no reason for inadequate-in-part opinion under the FAR or GAGAS
Audit Guidance on Limited Scope Audit Reports on Internal ControlsMRD 08-PAS-041(R), dated December 19, 2008 • Reason for change in guidance – significant deficiencies identified in other than internal control audits could take several years to report depending on the audit cycle • Results in more expeditious reporting of deficiencies • Results in more timely correction by contractors • Expectations • Issue a flash report when condition found (no change); • Establish separate limited scope audit to review control activities related to the control objective; and • If control activities audited are not adequate to assure control objectives are accomplished, report the system as inadequate.
More Information on DCAA • DCAA Audit Guidance Memorandums and Contract Audit Manual (CAM) are available on DCAA’s web site at: http://www.dcaa.mil Questions?