9. Coordinating Assist Audits

Management System: Budget and Financial Management

Subject Area: Evaluation and Review of Financial Management

Procedure 9. Coordinating Assist Audits

Subject Matter Expert: NATHANIEL BARKER
Management System Owner: JUDY PENRY
Secondary Management System Owner: MARY SUNDERLAND

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Issue Date:  10/07/2011
SCMS Revision:  4.0

1.0  Applicability

This procedure applies to the Office of Science (SC) Integrated Support Center (ISC) Staff who provide financial support to Contracting Officers (COs).

2.0  Required Procedure

The assist audit function is a cyclical event that begins at contract award and ends after expiration and closeout of the contract. Significant post‑award audit effort by the cognizant audit agency is required. For example, the Defense Contract Audit Agency (DCAA) maintains audit cognizance for cost‑reimbursement type contracts with commercial entities, and the U.S. Department of Health and Human Services (HHS) maintains audit cognizance for contracts and subcontracts with Colleges and Universities. These audits cover the contractor’s fiscal year (FY) and not the Government’s FY.

Step 1 Upon contract award, the procurement organization shall distribute copies of cost‑reimbursement type contracts to the SC ISC organization that is responsible for the assist audit function.
Step 2

For DCAA audits, the SC ISC or SC Site Office Staff Member determines which DCAA office has cognizance over the contractor, by using the “Audit Office Locator” function on DCAA’s Web site which matches the ZIP Code for the contractor’s home office to the cognizant DCAA office.

For Colleges and Universities, audit report information is available from a searchable database located at http://harvester.census.gov/sac/dissem/entity.html.

Step 3

The SC ISC Staff Member transmits a copy of the contract or subcontract to the cognizant audit office in accordance with local procedures.

NOTE: The SC ISC Staff Member is the point of contact (POC) listed on the request. Telephone calls between the cognizant audit agency’s auditor and the SC ISC Staff are typical when the cognizant audit agency initially receives the request.
Step 4 The SC ISC Staff Member analyzes Section H of the contract document and note any advance understandings in regards to costs. Any advance understandings are noted in the audit request discussed above.
Step 5

Upon receipt of the annual incurred cost audits, the SC ISC Staff Member:

  • Prepares a schedule of vouchers paid for the contractor’s FY under audit,

  • Notes any instances of disallowed costs made by the CO at the time the voucher was paid in accordance with Section H of the contract document or other deductions, and

  • Ensures schedule agrees with total paid to date as shown in the Standard Accounting and Reporting System (STARS).

Step 6

The SC ISC Staff Member reconciles the amount paid from the voucher schedule to the schedule of allowable costs for the year and reconciles any variances.

NOTE: Some variances may require negotiation between the CO and the contractor.

Step 7 The SC ISC Staff Member issues a memorandum to the CO summarizing the results of the audit and assists in negotiations of any questioned cost items in the audit report that the contractor does not concur with.
Step 8 The CO is responsible for negotiations and settlement of questioned costs.
Step 9

The SC ISC or SC Site Office Staff Members are also responsible for coordinating assist audit activities on behalf of Management and Operating (M&O) contractors for audits on subcontractors. The SC ISC or SC Site Office Staff Members shall ensure the M&O contractors submit their requests for assist audits in accordance with local procedures.

The resulting subcontract audit reports received on these subcontractors could be of several different kinds in nature such as floor check audits, estimating systems, materials existence, etc. However the primary reports for use by M&O contractor personnel are the annual incurred cost audits.

DCAA reports are qualified with the following release restrictions:

Information contained in this audit report may be proprietary. It is not practical to identify during the conduct of the audit those elements of the data which are proprietary. Make proprietary determinations in the event of an external request for access. Consider the restrictions of 18 U.S.C. 1905 before releasing this information to the public.

Express written permission from authorized representatives of the subcontractor for release of the report to M&O contractor personnel must be obtained and is mandatory. It should be noted that 18 U.S.C. 1905 is criminal statute and must be strictly adhered to by all SC ISC staff. However, some audit reports already contain such required release statements. The statement contained in the audit report should be reviewed to determine whether release pertains to the entire audit report or just sections thereof.

These same release restrictions apply to HHS reports on Colleges and Universities for subcontracts with M&O contractors and must be adhered to.

3.0  References


This is the online OFFICIAL SCMS COPY of this file. Before using a printed copy, verify that it is the most current version by checking the Last Major Revision and Last Minor Revision dates (at the bottom of each document) on the SCMS Web site.


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Last Major SCMS Revision: 10/07/2011