redstone government consulting dfars business reviewThe new DFARS business system rule requires audits by CPA’s, with DCAA approving the risk assessment and the audit program and reviewing the working papers afterwards.      

The obvious reason for this proposal is that DCAA is unable to perform the audits themselves.  At least not on a timely basis.  When DCAA was performing the audits, it was taking over 2 years to perform 1 system audit.  This rule requires it to be done within 6 months after the close of the contractor’s fiscal year.  In contrast, DCAA was not completing the risk assessment in that length of time.

So now let’s take CPA firms that are used to performing financial statement reviews in a timely manner and handcuff them to DCAA, an Agency that is notorious for missing due dates.

And THEN let that same Agency, in essence, audit the audit.  And furthermore, there are no provisions to limit DCAA to a reasonable time frame for approval of the risk assessment and audit program. 

This is a planning nightmare for both the CPA firm and DCAA.   DCAA would not know when the risk assessments or audit programs would arrive.  Since the majority of companies are on a calendar year as their fiscal year, most of audits would be required to be completed by June 30.  This makes it likely that DCAA would be swamped with risk assessments and audit programs to review during January, leaving few, if any, resources to perform forward pricing audits.

The CPA firm would be waiting for DCAA to “approve” the risk assessments and audit programs, with no real indication of when this approval would come.  This would also be during the timeframe the CPA firms would be performing financial statement audits to meet their requirements for those.

Then comes the real problem: What if the CPA firm and DCAA disagree on the risk assessment and/or the audit program???  Then they continue down the road, stumbling from one side to the other, shackled together and each trying to pull the other to their side of the road.







Written by Cheryl Anderson

Cheryl Anderson Cheryl Anderson is a Director with Redstone Government Consulting, Inc. She provides Government Contract Consulting services to our government contractors primarily related to equitable adjustment claims, terminations, and DCAA audit expectations. Prior to joining Redstone Government Consulting, Cheryl served in a number of capacities with DCAA for over thirty-five years. Upon her retirement, Cheryl was a regional audit manager with DCAA. Cheryl began her DCAA career in 1977 as an auditor-trainee with the Ingalls Resident Office in Pascagoula, Mississippi. After instructing at the Defense Contract Audit Institute for four years, she returned to the Eastern Region in 1990, holding various audit positions before ultimately becoming a Regional Audit Manager in August 2005. She had overall management responsibility for audits performed by approximately 200 employees. During Cheryl’s tenure with DCAA, she was involved in conducting or managing a variety of compliance audits, to include cost proposals incurred cost submissions, systems, Cost Accounting Standards, claims, defective pricing, financial capability and agreed-upon procedures. She directly supported the government litigation team on a contract dispute and has prepared and presented various lectures and seminars to DCAA staff. In addition, she has served as an instructor for the Government Audit Training Institute for over 20 years. She currently specializes in preparing clients for more complex DCAA audits, providing advice on FAR cost principles and contracts regulatory provisions, and assisting clients in anticipating and addressing audit. Education Cheryl has a BS Degree in Accounting from Auburn University at Montgomery and a Masters of Business Administration from Wichita State University. Cheryl also completed courses at OPM’s management and executive development centers and at the Federal Executive Institute and is a Georgia Certified Public Accountant.

About Redstone GCI

Redstone Government Consultants are a team of the most senior industry veterans and the brightest new talent in the industry. Many have held senior government positions including leadership roles in the DCAA. Our new talents bring significant accounting and software experience along with fresh perspectives, inspiration and energy to our team. Through our leadership and combined experience, we provide a unique perspective, bringing both government and contractor proficiencies to bear and ensuring rock-solid government compliance for our clients.

Topics: Business Systems Review, Contracts Administration, DFARS Business Systems, DCAA Audit Support