Many of us who have retired from DCAA as well as contractors like to discuss the “good old days” before DCAA audits became marathons and helping contractors was not forbidden. As DCAA became more demanding and intrusive, the preferred alternative for a contractor was to be subjected to the less-intrusive review by DCMA. Now it appears that contractors may soon be longing for the “good old days” of DCMA as well.
A few recent DCMA actions brought up memories of the new DCAA. First, was the receipt by a client of a 3 page, 22 item letter requesting information for a financial capability evaluation – due in 15 days. Second was a report issued by the Contractor Purchasing System Review (CPSR) Team which cited as a “significant deficiency” the lack of a policy related to requirements that were not applicable to the company. Third, a contractor’s forward pricing (bid) rates were going to be reviewed by DCMA, but first the contractor had to complete an adequacy checklist (not required by any regulation, but borrowed from DCAA).
For at least the last 35 years, there have been rumors that DCAA would be merged into DCMA. Now it seems that that DCAA and DCMA are blending together, unofficially. DCMA, in some cases staffed by former DCAA auditors, now performs reviews of purchasing systems, earned value management system reviews, forward pricing proposals, disclosure statements, financial capability, and forward pricing rate proposals, all of which used to be performed by DCAA. The biggest difference in what DCAA used to do and what DCMA now does, is that DCMA does not call them audits and does not perform them in accordance with Generally Accepted Auditing Standards (GAGAS).
As DCMA takes over more and more of the work that DCAA used to perform, the similarities between the Agencies seem to increase. It now appears that DCMA is following DCAA’s lead in performing system reviews by following a checklist. If anything on the checklist is missing, there is a significant deficiency, which makes the system inadequate. This has been a problem for as long as there have been system reviews – but typically limited to reports coming from DCAA.
Bottom line – anyone longing for the “good old days” in terms of the experience of dealing with the new DCAA, just needs to go through the experience of dealing with the new DCMA. They will feel right at home.