DCAA Audit DFARS Business Systems Redstone Government Consulting

Prior to retiring from DCAA, I was involved in developing the 2012 DCAA Requirements Plan for the Huntsville Branch Office. Since one of my Huntsville contractors was a major, I was required to coordinate my plan with the DCAA Contract Audit Coordinator (CAC) in Chicago. The CAC was estimating the Business Systems staffing requirement for ONE major contractor. The estimate was prepared to consider auditing the Accounting and Billing business system requirements using the draft DCAA audit program for the respective systems. The CAC advised me that its estimate of the hours required to complete TWO business system audits across all segments of the ONE major contractor would be 235,000 over a two-year period. This estimate was communicated to DCAA management at the All Managers Meeting in the fall of 2011.

It does not surprise me that the DOD is now mandating these audits be completed by CPA firms as opposed to DCAA since DCAA’s staffing would need to quadruple to address the business system audit requirements. We all know that is not going to happen so the answer…”let’s get the CPA firms to do it”. Notwithstanding the change in responsibility for these audits, the long pole in the tent is still staffing! The CPA firms are clearly not adequately staffed to address the GAGAS audit requirements for the three business systems at large contractors throughout the country, even on a triennial basis. It is another instance of the Government recommending regulatory changes with no clue regarding the consequences. Even if the DCAA CAC’s estimate was ten times the actual requirements, one can only imagine the resource requirements and enormous costs associated with this proposed rule. Oh, and let’s not forget, DCAA still wants a piece of the pie, so they are going to review the CPA’s work.

Once again, the lights are on but nobody is home!!

PS – Prior to retiring, I did write a Memo to the DCAA director alerting him to the dire consequences of audit requirements related to the new business system rules.  I recommended the DCAA propose that the FAR be revised to only require business system audits at contractors whose ADV was a billion dollars or more. I was pleasantly surprised when he called to talk about this, and other issues in the memorandum. He listened but offered no commitment as to what would be done. I guess they finally figured it out…let the CPA firms do it!!

New! DFARS Business Systems Center

Written by Glenn Behrends

Glenn Behrends

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Compliant Accounting Infrastructure, Government Compliance Training, DFARS Business Systems, DCAA Audit Support