Cost And Accounting, DCAA Relations, Incurred Cost Proposals

Be Fair to DCAA

One of the consequences of the new law requiring DCAA to accept of reject a contractor’s incurred cost submission within sixty (60) days is a possible DCAA conclusion that it must reject the proposal instead of simply calling the contractor and asking a few questions. The loop of question response, question response can eat up the clock pretty quick, especially when about 90% of the proposals are submitted on the sane day.

Some examples I am seeing:

a. Did you really mean that the contract reported on Schedule O is ready to close.

b. Are you missing any contracts on Schedule H, we think you might be.

c. We see that you got labor reconciled on Schedule L but we are not sure how you did it. We will go ahead and reject and let you explain it with the resubmission.

Please feel free to share your examples.

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Cost And Accounting, DCAA Relations, Department of Defense News

DOD OIG Critical of DCMA Followup on CAS Violations

http://www.dodig.mil/pubs/report_summary.cfm?id=7232&utm_source=DoD+IG+Email+Update+-+Reports+and+Testimonies&utm_campaign=1028bc1344-DoD_IG_Reports&utm_medium=email&utm_term=0_3a17f8681e-1028bc1344-277174597

 

“For the 27 DCAA CAS reports we selected, we identified several instances in which contracting officers did not comply with FAR, DoD Instruction 7640.02, or agency instructions. We found:

    • 12 instances in which contracting officers did not issue a Notice of Potential Noncompliance within 15 days, as FAR 30.605(b)(1) requires;     • 16 instances when contracting officers failed to complete all actions on the reported noncompliances within 12 months, as DoD Instruction 7640.02    requires;     • 3 instances in which contracting officers did not have adequate documentation or rationale for determining that the DCAA-reported noncompliance    was immaterial, contrary to FAR 30.602; and     • 8 instances in which contracting officers did not obtain a legal review of their CAS determination, as Defense Contract Management Agency (DCMA),   Instruction 108 requires.

As a result, correction of the reported CAS noncompliances was delayed. In addition, contractors may have been inappropriately reimbursed contractors additional costs resulting from the noncompliance.”

Both Books graphic

Available at DCAA Compliance or Amazon

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