The continuing backlog of incurred cost audits, and failure of DCAA to make any meaningful traction in closing the over $500 billion and growing backlog of incurred cost audits means that you will be continually supporting open year submissions dating back over 5 years. There is somewhat of a silver lining to this in the recent Raytheon decision (ASBCA Nos. 57576, 57679 (Dec. 17, 2012)), which we discussed in our February newsletter. The longer DCAA waits to audit, the closer contractors come to reaching the six-year Statute of Limitations; however the untested effect of DCAA deeming submissions inadequate has yet to be fully vetted. Does DCAA’s rejection of your submission as inadequate reset the clock? Prudent contractors are increasingly involving consultants with expertise in evaluation of open-year incurred cost submissions for not only adequacy, but also for mock audit procedures to expose potential risks for non-compliance. This exposure of risks gives the company time to consider alternatives and weigh the pros and cons of each situation versus having their hand forced by DCAA during audit when it is already too late. Being proactive in this area is critical to minimizing costs and future liabilities during eventual audit. Whether it’s unallowable cost, changes in cost accounting practices, questionable allocation methodologies or a plethora of other issues DCAA is continually challenging contractor submissions on, we can help you evaluate your options to minimize audit risk. Our staff includes former DCAA executives, Branch Managers and seasoned industry veterans that offer our clients the best possible chance to succeed during incurred cost audit.
Incurred Cost Submissionsadmin2020-08-28T14:12:58-05:00