MRD 08-PPD-020(R) - Audit Guidance on Audits of Contractor Cost Data Reports (CCDRs)
2 pages
English

MRD 08-PPD-020(R) - Audit Guidance on Audits of Contractor Cost Data Reports (CCDRs)

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2 pages
English
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DEFENSE CONTRACT AUDIT AGENCY DEPARTMENT OF DEFENSE8725 JOHN J. KINGMAN ROAD, SUITE 2135 FORT BELVOIR, VA 22060-6219 I N RE PLY REF E R T O PPD 730.5.15.1 June 19, 2008 08-PPD-020(R) MEMORANDUM FOR REGIONAL DIRECTORS, DCAA DIRECTOR, FIELD DETACHMENT, DCAA SUBJECT: Audit Guidance on Audits of Contractor Cost Data Reports (CCDRs) Summary This audit guidance is being issued to provide additional audit procedures and emphasize existing guidance (CAM 11-408) to address recent issues raised by the Director of the Defense Cost and Resource Center (DCARC) regarding CCDR audits. Auditors should be responsive to DCARC requests for audit which, in the future, will likely include specific areas for review, such as verifying certain actual costs to the contractor’s books and records. CAM 11-408 will be expanded to incorporate the guidance detailed below. Background The CCDR is relied upon by DoD to develop independent cost estimates that are the basis for Departmental budget requests and key milestone decisions on major defense acquisition programs. As a result, it is critical that any known deficiencies and inaccuracies or noncompliances in contractor-reported data are appropriately reported and considered in assessing the overall adequacy of the contractor report and related policies and procedures. Upon receipt of the CCDR from the contractor, DCARC performs a validation for numerical and clerical accuracy and consistency with the Cost Analysis ...

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 I NR E P L YR E F E RT O
DEFENSE CONTRACT AUDIT AGENCYDEPARTMENT OF DEFENSE8725 JOHN J. KINGMAN ROAD, SUITE 2135 FORT BELVOIR, VA 22060-6219
PPD 730.5.15.1June 19, 2008  08-PPD-020(R) MEMORANDUM FOR REGIONAL DIRECTORS, DCAA DIRECTOR, FIELD DETACHMENT, DCAA SUBJECT: AuditGuidance on Audits of Contractor Cost Data Reports (CCDRs) Summary This audit guidance is being issued to provide additional audit procedures and emphasize existing guidance (CAM 11-408) to address recent issues raised by the Director of the Defense Cost and Resource Center (DCARC) regarding CCDR audits. Auditors should be responsive to DCARC requests for audit which, in the future, will likely include specific areas for review, such as verifying certain actual costs to the contractor’s books and records.CAM 11-408 will be expanded to incorporate the guidance detailed below. Background The CCDR is relied upon by DoD to develop independent cost estimates that are the basis for Departmental budget requests and key milestone decisions on major defense acquisition programs. Asa result, it is critical that any known deficiencies and inaccuracies or noncompliances in contractor-reported data are appropriately reported and considered in assessing the overall adequacy of the contractor report and related policies and procedures. Upon receipt of the CCDR from the contractor, DCARC performs a validation for numerical and clerical accuracy and consistency with the Cost Analysis Improvement Group approved plan.Based on its review, the DCARC issues a validation memorandum to the contractor, Government program office, and the cognizant DCAA FAO.The validation memorandum states whether the CCDR passed validation.If the CCDR is not validated, the DCARC reports the reasons for the failure and the corrective action required of the contractor. Guidance FAOs should perform annual CCDR audits in accordance with CAM 11-408.Contracts where the DCARC has identified significant data inaccuracies or noncompliances should be considered when selecting the sample of contracts to test in the annual CCDR audit.For contracts selected for review, auditors should obtain an understanding of the CCDR requirements by reviewing the Cost and Software Data Reporting (CSDR) plan and the Contract Data Requirements List (CDRL) items incorporated in the contract.
June 19, 2008 PPD 730.5.15.108-PPD-020(R) SUBJECT: AuditGuidance on Audits of Contractor Cost Data Reports (CCDRs)
In addition to verifying the CCDR data to the contractor’s books and records, the auditor should determine the significance of deficiencies identified in the DCARC validation memos and, where applicable, quantify the impact of the deficiency on the accuracy of the report data, as well as on the adequacy of the contractor policies and procedures.As detailed in CAM 11-409, auditors should report significant noncompliances and data inaccuracies identified in the audit, even if the total cost reported is not over/understated (e.g., cost in one WBS element or functional area is overstated but offset by an understatement of costs in another WBS element or functional area).
As part of the CCDR audit, auditors should also:
review for contractor compliance as to the flow-down requirements for subcontractors. Where flow-down requirements are applicable, the prime contractor auditor coordinates with the cognizant subcontractor auditors to ensure subcontractor CCDRs are included in the subcontractor auditor’s universe for selection for its annual CCDR audit.
report as a deficiency the contractor’s failure to document, within its overall accounting and management policies and procedures, specific procedures for accumulating data and preparing CCDR reports.
Auditors are also reminded to consider obtaining technical evaluations, when necessary, to render an opinion on such unique areas as the appropriateness of contractor classification of costs as recurring versus nonrecurring (CAM 11-408e).
Field audit office personnel should refer questions regarding this memorandum to their regional offices.Questions from the regional offices should be directed to Policy Programs Division, at 703-767-2270 or e-mail atDCAA-PPD@dcaa.mil.
DISTRIBUTION: C
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/Signed/ Kenneth J. Saccoccia Assistant Director Policy and Plans
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