Government Contract Oversight – Audits, Reviews and Investigations

Course Overview

This comprehensive seminar will provide new and existing government contractors with a fundamental understanding of contract oversight, including audits and other reviews that test a contractor’s compliance with solicitation or contract clauses. This course will link compliance with timing, pre-award versus post-award, and connect compliance with the various government agencies and, in some cases, private (non-government) firms with oversight/audit roles and responsibilities.

Course Objectives

At the completion of this one-day comprehensive course, participants will be able to:

• Understand the significance of contract types linked to audit/compliance exposure
• Distinguish audits from investigations and other compliance reviews
• Understand the oversight role of prime contractors vis-à-vis subcontracts
• Understand how DCAA (Defense Contract Audit Agency) evaluates contractor accounting system
• Understand and differentiate the Government approach to pre-award compliance from post-award compliance
• Focus on the most common compliance challenges and risks
• Have a basic understanding of the processes and alternatives for resolving audit and other oversight issues
• Anticipate audit requests for data and information and develop contractor response strategies

Program Content

This course will cover the following topics:

• Government Contracting and the Agencies Responsible for Compliance Oversight
  • OFCCP (Office of Federal Contract Compliance and Programs
  • GAO (General Accountability Office)
  • OIG (Office of Inspector General)
  • DCAA (Defense Contract Audit Agency)
  • DCMA (Defense Contract Management Agency)
  • Civilian Agency Contract Pricing and Contract Administration
  • IPAs (Independent Public Accountants)
  • Prime contractors (with respect to subcontract administration)
• Government Solicitations and Prospective Contractor Compliance
  • Contractor proposals: adequacy determinations
  • Contract Type and Government Cost or Price Analysis
  • Audits versus Cost or Price Analysis
  • Certified or other-than-certified cost or pricing data
  • Updating cost or pricing data and TINA (Truth in Negotiations Act)
  • Government access to contractor or subcontractor records
  • Estimating Systems and mapping contractor data to solicitation specific requirement
  • Access to Government cost analysis or audit results
• Government Contracts and Government Oversight “Real-time”
  • Contract-type and Government access to records
  • Provisional billing rates
  • Public vouchers and pre-payment or post-payment audits
  • Floor-checks or employee interviews
  • Direct materials verification
  • Accounting Systems (major or non-major contractor)
• Government Contracts and Government Oversight “After-the-Fact”
  • Indirect Cost Proposals
    • Timing and Format
    • High-risk or Low-risk classification
    • Audits’ risk assessment and planning
    • Audit execution and interim communications
    • Direct versus Indirect Costs
    • FAR Part 31 Cost Principles, DCAA Interpretations, and penalties for expressly unallowable costs
    • Audit results and issue resolution (Including examples of direct or indirect cost issues)
    • Final indirect rate agreement letters
    • Contract Disputes Act or when all else fails
  • Contract Close-Out
    • Linking the ICP Schedule I to Contract Close-out
    • Prime Contractor Responsibility for subcontracts
    • Final vouchers, contractor releases, and Government property
    • Final payment and records retention
  • Government Contract Oversight:  Other than Audits
    • Business Systems (DCMA)
    • Investigations: Contractor “Voluntary” Disclosures
    • Investigations Government Initiated or Qui Tams
  • Government Oversight or Audit Situations
    • Post-award audits for TINA Compliance
    • Requests for Equitable Adjustment
    • Terminations
    • CAS (Cost Accounting Administration), including Disclosure Statements and Cost-impacts
    • Business Systems (DCMA & DCAA)
    • Investigations: Contractor “Voluntary” Disclosures
    • Investigations: Government Initiated or Qui Tams
  • Department of Labor Audits and Investigations
    • Office of Federal Contract Compliance Programs
      • Pre-Award & other Audits
      • Investigations
      • OFCCP Portal requirements
    • Wage and Hour Investigations
      • Service Contract Act & Davis Bacon Act
      • Fair Labor Standards Act & Independent Contractor Issues
      • Joint Employer Issues

Course Run Time

• 8 hours

Customization Options: This course can be customized into a half-day, 1-day, or 2-day training based on your company’s needs.

CPE Credit

• CPE credit is available using the following training methods: Custom Training, In Person Training (Group), In Person Training (Individual), and Live Webinar Training.