May 19, 2013
DCAA’s annual report to Congress is out and now I am scared. I will let DCAA speak for themselves as they claim they already have the legal right to access accounting records 24/7 and want this authority bolstered:
Access to Online Data. The lack of access to contractor online data is another area where DCAA has recently had growing concern. Read-only access to the contractor’s books and records would greatly assist DCAA to effectively plan and perform all of the audit effort at a contractor location. This is especially important at contractors with highly complex Enterprise Application Integrations environments and Enterprise Resource Planning systems.
Contractors are increasingly generating and storing accounting data and records in a digital environment. Whether it’s an Electronic Timecard System, an Electronic Management Records system storing invoices/vouchers, or an automated General Ledger journal entry posting and reconciliation of accounting records within an enterprise accounting system, original accounting source data and records have become increasingly developed and available solely within electronic environments and formats. DCAA has always maintained that direct access to contractor original accounting “books of entry” or source records, whether manually or electronically generated, is authorized under FAR 52.215-2 Audit and Records—Negotiation. Nonetheless, many contractors have denied DCAA the read-only access to their electronic accounting systems data. Accessing these source records is necessary for DCAA to efficiently perform its audit mission and support the Contracting Officer.
Specificity of the authority for direct and online access to contractor’s data would improve both the audit and DCAA’s ability to support the Contracting Officer. For example, direct, read-only online access would allow DCAA to respond more quickly to contracting officers because we could obtain the necessary data directly rather than having to repeatedly request the data from a contractor representative. Furthermore, the access would decrease the amount of costs and personnel resources needed by contractors to support audit requests for data. In addition, online access would advance DCAA audit efforts by allowing real time contract cost monitoring and continuous risk analysis, including the use ofadvanced data analytics. DCAA is continuing to determine what specific legislative proposal is necessary to ensure that DCAA has appropriate access to a contractor’s online data.