In 2012, DCAA reported to Congress that its 2011 average elapsed days for completing 349 Incurred Cost Proposal audits was 965 days. As it relates to incurred cost proposal audits, DCAA’s FY2012 audit plan acknowledged its increasing backlog of unaudited incurred costs and also its use of dedicated audit resources (“virtual FAOs”) to reduce the unaudited incurred costs.
Ironically, DCAA also began to raise the bar in terms of acceptable or adequate contractor incurred cost proposals, rejecting hundreds of previously (long-since) submitted and DCAA determined to be adequate contractor incurred cost proposals. Although DCAA has never issued any publicly available audit policy explaining why it is newly rejecting large and unprecedented numbers of “old year” contractor incurred cost proposals, it’s all about “managing the data”; in particular to report to Congress a miraculous improvement in the elapsed days.
Mike Steen is a Emeritus Advisor with Redstone Government Consulting, Inc. and a specialist in complex compliance issues to include major contractor cost accounting & business system regulations, financial compliance, resolution of DCAA audit issues, Cost Accounting Standards application, litigation support, and claims preparation. Prior to joining Redstone Government Consulting, Mike served in a number of capacities with DCAA for over thirty years, and upon his retirement, he was one of the top seven senior executives with DCAA. Mike Served as a Regional Director for two DCAA regions, and during that time was responsible for audits of approximately $25B and 800 employees. In October 2001, he was selected for the Senior Executive Service and in 2006 he received the Presidential Rank Award. During Mike’s tenure with DCAA, he was involved in conducting or managing a variety of compliance audits, to include cost proposals, billing systems, Cost Accounting Standards, claims, defective pricing, and then-evolving programs such as restructuring, financial capability and agreed-upon procedures. He directly supported the government litigation team on significant contract disputes and has prepared and presented various lectures and seminars to DCAA staff and business community leaders. Since joining Redstone Government Consulting in June 2007, Mike has developed and presented training and seminars on Government Contracts Compliance to NCMA, Federal Publications Seminars and various clients. Mike also is a prolific contributor of written articles to government contracting publications, as well as to our own Government Insights Newsletter. Mike also serves as the director of our training service offerings, with responsibilities for preparing and developing course content as well as instructing our seminars to clients and general audiences throughout the U.S. Mike also serves as a faculty instructor for the Federal Publications Seminars organization. Education Mike has a BS Degree in Business Administration from Wichita State University. He is also a graduate of the DCAA Director’s Fellowship Program in Management, and has a Masters Degree in Administration from Central Michigan University. Mr. Steen also completed a number of OPM’s management and executive development courses.