RGCI - How to Deal with a Difficult DCAA Auditor

You pride yourself on working well and getting along with everyone, at least professionally. However, there is an auditor that seems to get under your skin. What do you do? Well, although there may not be a “magic bullet” to all make it better. I propose the following to get you through the situation at hand:

Watch Your Emotions and Keep Them in Check

This may not be easy. In my career, I had “hardnosed” or “intense” auditors whom I worked with and who worked for me. It was even a desirable trait among some to “be tough to those you audited.” But letting your emotions take over may be something you later regret. For example, giving the auditor a piece of your mind and venting to the auditor all that is wrong with their audit or request for information may not go well with the contracting officer in either awarding your company a contract or during contract administration. The auditor and their audit generally are backed by the audit clause, FAR 52.215-2, Audit and Records-Negotiation, which provides for authorized representatives of the contracting officer… shall have the right to examine and audit all records and other evidence sufficient to reflect all costs properly claimed to have been incurred or anticipated to be incurred directly or indirectly in the performance of this contract….” When I was a new Defense Contract Audit Agency (DCAA) audit supervisor, I attended one meeting where the auditee’s CFO pounded a large conference table to get his way. Now I do not recommend responding in kind and providing a similar response, and I would recommend taking a break before giving in to emotions and words that cannot be taken back.

Be Professional

This goes hand-in-hand with keeping your emotions in check. Always be professional with those you are in business with, especially your government client and its representatives. That does not mean you acquiesce with the auditor’s findings but remain in an unemotional state where you can make clear decisions even if you “agree to disagree” with the auditor’s findings. In the e-book, Dealing with Difficult People (Harvard Business Review Emotional Intelligence Series), The Secret to Dealing with Difficult People: It’s About You, Tony Schwartz states that using a reverse lens of viewing the world through the lens of the person triggering you. In this case, the auditor may view the situation differently than you and reference, “Where is my responsibility in all this?” In a way, it is empathy. As you do this, you may get a different response. If the relationship is not professional at some point, perhaps acknowledge that and try clearing the air by asking, “I know we may not have seen eye-to-eye on this audit, but putting that aside, how can we move forward? That may provide you both an opportunity to reset the professional working relationship.

Be Prepared and Do Your Homework

DCAA contract auditors have a defined audit scope in what they are testing and providing an audit opinion to the contracting officer for use in awarding, administering, and closing contracts. The master audit programs can be found here on the DCAA public website. I recommend obtaining the DCAA master audit program to gain background on what the auditor will request for information and why. The master audit program is a good source for understanding the purpose of the audit. It will provide references such as the federal acquisition regulation (FAR) and its supplements and what the auditor will consider in providing their audit opinion. On the first page, the DCAA master audit programs will state the audit purpose and scope with applicable contractual and FAR references. From this, you can obtain an understanding of the audit, and if the auditor gets off track, you can ask why the auditor is departing from the master audit program.

Focus on the Objective

The objective of an audit, like an initial proposal audit, is for the auditor to review and opine on the proposed costs for compliance with FAR Part 15 (Contracting by Negotiation) and FAR Part 31 (Contract Cost Principles and Procedures) so the contracting officer can award your company a contract or more business. So, keep your mind on the objective that the audit leads to more business for your company. The contracting officer has the responsibility to award a government contract at a “fair and reasonable” price in accordance with FAR Part 15.402 (Pricing Policy). Still, the objective is a good thing for you, more business for you and your company.

Know that the DCAA Auditor May Feel They are Virtuous

The auditor that may be getting under your skin may think that by doing that, they are doing a good job by “hitting heads” with you and having a contentious working relationship. They may have management that emphasizes audit findings as a measure of “how good an auditor they are.” So, with this in mind, they may be making a contentious working relationship and thinking this is good or productive and will lead to audit findings. I recommend that you may try your best to try to turn this thought process and improve the working relationship since the same auditor may do another audit at your company, and you may be seeing them again.

Again, look forward to the result: more business for you and your company. Audits are necessary for the life cycle of a contract which goes from contract pricing through contract administration and eventual contract closing. So, with that business comes the work of getting the contract through the conclusion of the contract, but the result is beneficial to both the Government in getting the goods and services they need and for you and your company through increased sales and profit.

Keeping these suggestions in mind may make the audit less stressful, less emotional, and better for you and the auditor. Note that this does not have to be a test of how well you work with others. But by overcoming the challenges of working with difficult situations, you will be better the next time, even when presented with what initially may look like an impossible situation, such as a difficult auditor.

Redstone GCI assists contractors throughout the U.S. and internationally with understanding the Government’s expectations and supporting contractors with establishing and revising provisional billing rates and preparing adjustment vouchers. We would be happy to be part of your team.

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Written by David G. Fix, CPA, CFE

David G. Fix, CPA, CFE David (Dave) Fix is a Director with Redstone Government Consulting, Inc. He provides Government Contract Consulting services to our Government contractors primarily related to compliance with Federal Acquisition Regulations and Cost Accounting Standards, equitable adjustment claims, and business systems. Prior to joining Redstone Government Consulting, Dave served in a number of capacities with DCAA for over 35 years. Upon his retirement, Dave was a Regional Audit Manager with DCAA. Dave began his DCAA career in 1986 as an auditor-trainee with the General Electric Suboffice in Pittsfield, Massachusetts. He progressed from auditor to DCAA management ranks serving in DCAA offices in Upstate New York, Columbus, Ohio and Greensboro, North Carolina in audits of major and non-major contractors. Dave served DCAA in three overseas tours, all as Branch Manager, in Kuwait/Iraq (2007), Afghanistan (2010-2012) and Kuwait (2014). Dave was promoted to Regional Special Programs Manager (RSPM) in 2015 before ultimately becoming a Regional Audit Manager (RAM) in October 2019. While a RSPM, Dave worked with DCAA’s other three RSPMs with updating the Agency-wide audit planning process including assigning priorities and determining funded/unfunded audits that is currently being used by DCAA. While a RAM, Dave had overall management responsibility for audits performed by approximately 140 employees including one of DCAA’s largest shipyards. During his career, he served as guest instructor at DCAA’s Defense Contract Audit Institute (DCAI) bringing field perspective to “Advance Auditing Issues” and “Supervisors’ Course” as well as served as a DCAI adjunct instructor over DCAA auditors’ initial two-week training course prior to his retirement. Dave served 36 years in the Air Force Reserve/Air National Guard in both enlisted and officer positions retiring at the rank of Lieutenant Colonel. His last duty station was Air Force Reserve Command (AFRC) Headquarters, Robins Air Force Base, Inspector General Office serving as the Chief, Contracting Inspections leading inspections of AFRC’s 10 contracting offices as well as assisting in inspections of AFRC finance offices. Dave currently specializes in preparing clients for more complex DCAA audits, providing advice on FAR cost principles and contracts regulatory provisions and in assisting clients in anticipating and addressing audit.

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: Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)