BOP 540.1, Requests to Defense Contracting Audit Agency (DCAA) for Audit of M&O Contractor Subcontractors
In accordance with DEAR 970.5244-1, Contractor purchasing system, the contract clause entitled "Contractor Purchasing System (DEC 2000)," as prescribed in 48 CFR 970.4402-5, is incorporated in NNSA's Management & Operating (M&O) contracts. Subparagraph (3) of this clause contains the following language: Where audits of subcontractors at any tier are required,
arrangements may be made to have the cognizant Federal agency perform the audit of the subcontract. These arrangements shall be made administratively between DOE and the other agency involved and shall provide for the cognizant agency to audit in an appropriate manner in light of the magnitude and nature of the subcontract. In no case, however, shall these arrangements preclude determination by the DOE contracting officer of the allow ability or unavailability of subcontractor costs claimed for reimbursement by the contractor. Commensurate with this language and requirement, the purpose of this document is to provide the NNSA Service Center, Site Offices, and M&O contractors with guidance regarding requesting audit support from DCAA.
PAS recommends cancellation without replacement.
August annual audit call data not used as DCAA does audit planning in May. MOU/MOA is between DOE and DCAA. No major changes forecasted for MOU as it is only getting updated since it is old. Subcontract audit process has not changed since the change from a Cooperative Audit Strategy to an Independent Audit Strategy where DCAA can self-initiate incurred cost audits per the MOU. M&O subcontract audits typically part of larger incurred cost audits for these large contractors. Similar to other audits, DCAA coordinates with the Pricing Branch for its
participation in the incurred cost audits.
Previously BOP-003.0404. NNSA Directives Program has revised its numbering system to a three-digit system. See Crosswalk for more information.
Related To:
Version history and related documents
Related documents
- BOP 540.1, Requests to Defense Contracting Audit Agency (DCAA) for Audit of M&O Contractor Subcontractors (Redline)
- Cancellation of National Nuclear Security Administration (NNSA) Business Operating Procedures (BOPs) where the Office of Partnership and Acquisition Services (NA-PAS) is the Office of Primary Interest (OPI)
Document text
Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
NNSA Policy Letter: BOP 540.1
Date: July 28, 2004
TITLE: Requests to Defense Contracting Audit Agency (DCAA) for Audit of
M&O Contractor Subcontracts.
OBJECTIVE: I.
In accordance with DEAR 970.5244-1, Contractor purchasing system, the
contract clause entitled "Contractor Purchasing System (DEC 2000)," as
prescribed in 48 CFR 970.4402-5, is incorporated in NNSA’s Management &
Operating (M&O) contracts. Subparagraph (3) of this clause contains the
following language:
Where audits of subcontractors at any tier are required,
arrangements may be made to have the cognizant Federal
agency perform the audit of the subcontract. These
arrangements shall be made administratively between DOE
and the other agency involved and shall provide for the
cognizant agency to audit in an appropriate manner in
light of the magnitude and nature of the subcontract. In no
case, however, shall these arrangements preclude
determination by the DOE contracting officer of the
allowability or unallowability of subcontractor costs
claimed for reimbursement by the contractor.
Commensurate with this language and requirement, the purpose of this document
is to provide the NNSA Service Center, Site Offices, and M&O contractors with
guidance regarding requesting audit support from DCAA.
IL APPLICABILITY:
All NNSA elements except Naval Reactors.
REQUIREMENTS: III.
M&O contractors shall request audit support from DCAA (e.g., pre-award audit;
incurred costs audit; post performance audit; rate verification) through the Site
Office to the Service Center. The Site Office shall provide a courtesy copy of the
audit request and a copy of the audit report to the Service Center.
Requests for DCAA support will be considered only if DCAA is the cognizant
audit agency for a particular subcontractor.
Requests for DCAA support will be considered only if DCAA is the cognizant
audit agency for a particular subcontractor.
The following DCAA thresholds should be taken into consideration prior to any
requests to DCAA:
• Fixed Price proposals subject to cost/pricing data threshold per FAR
15.403-4
Cost-type proposals or subcontracts in excess of $10M.
Special audits (e.g., terminations, claims, etc.) on a case-by-case basis.
•
•
In requesting support from DCAA, M&O contractors must provide the
appropriate documentation needed for the audit. In the case of a pre-award audit,
a copy of the subcontractor's proposal is required. For an incurred cost audit or a
post performance audit, copies of the subcontract and vouchers are required.
In requesting support from DCAA be aware of the following:
• The Service Center will develop, in cooperation with DCAA, an estimate
of hours required for the requested services so that the extent of billing is
known.
The number of hours agreed to between the Service Center and DCAA
will not be exceeded by DCAA without additional coordination between
the Service Center and DCAA.
DCAA will not commence a pre-award audit until an adequate proposal
from the subcontractor is provided.
A billing reference number will be provided to DCAA by the Service
Center.
•
•
•
Consider the following risk factors when determining the type of DCAA
assistance needed:
•
•
•
•
•
Dollar value of the proposal;
Type of anticipated award;
Prior government experience with subcontractor;
Size of subcontractor; and
Complexity and adequacy of subcontractor's systems, policies,
procedures, and internal controls.
Section 2
The Service Center will issue an annual call on or about August 1st to the Site
Offices to assess the magnitude of DCCA support (e.g., pre-award audit; incurred
costs audit; post performance audit; rate verification) that will be required by their
site for a particular fiscal year. Responses from Site Offices are due to the
Service Center within 15 days. The annual call will be issued in the attached
format. Site Offices must advise the Service Center of changes or updates to their
response to the annual call as they become aware of them.
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IV. RESPONSIBILITY:
The Service Center and Site Offices are responsible for implementing and
adhering to this policy.
POINT OF CONTACT FOR ADMINISTRATION OF POLICY LETTER:
Deputy Director, Office of Acquisition and Supply Management (NA-63)
202-586-8559.
BY ORDER OF THE SENIOR PROCUREMENT EXECUTIVE:
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Attachment
Annual Call for DCAA Audit Support