DCAA Disclosure Statement Adequacy Review Program

govtacct02, I have an Excel template I used to test disclosure statement interrelationships several years ago in a DCAA D/S adequacy audit. If you are a DCAA employee and would like me to send you the template, please reply with your name as listed in the Global address book and I will send it to you.

Regards,

srterral

morning, www.dcma.mil has a policy page on Cost Accounting Instructions, resources I think policy 120 scroll down to conformity I think that might be what you're looking for.

I am not a DCAA auditor. So srterral, I won't be able to take you up on your offer. Thank you anyhow.

Joan - I do not see the term "conformity" in DCMA Instructions on CAS Compliance...or in Policy 120. Can you provide a more specific link?

Thanks.

As a follow up - my local DCMA office provided the adequacy review program, that includes conformity.  If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had.

Thanks for following-up, govtacct02.

govtacct02 said:

As a follow up - my local DCMA office provided the adequacy review program, that includes conformity.  If you need it, you can ask your DCMA, who now has disclosure statement adequacy determination responsibility that DCAA once had.

Can you qualify this? I understand it to be that, while DCMA has determination responsibility, they rely on DCAA to perform the review and compliance. At least in my recent experience.

JMG, not so much.

DCAA has formally abdicated responsibility for determining whether a contractor's D/S is adequate. It was always the ACO's responsibility to make a formal determination (similar to how Business Systems work) but now that determination is based on DCMA's work and not DCAA's work. DCAA does perform a review, and does assess adequacy as part of that review, but the auditors no longer express an opinion on the D/S adequacy. Quite honestly, I have no idea what value the DCAA review adds to the process anymore.

The new process is confusing to all parties.

H2H

Thanks Help. Interesting. So DCAA will still review but just provide objective results? I tend to think DCMA lacks the local knowledge to perform such reviews; they would have to reach out to a cost/pricing center or other team (similar to CPSR).

JMG in my experience the DCAA auditors read each section of the D/S and confirm that the contractor has provided an answer. Then they stop. For example, suppose the contractor has to identify whether the security function is direct, indirect or both. If both, the contractor must describe the circumstances for its differing treatment and identify the affected indirect pools. The auditor checks to see whether the contractor checked "direct" or "indirect" or "both" and, if "both" was checked, then the auditor makes sure that the contractor identified the affected cost pools.

The contractor shrugs and answers the questions asked. The auditors shrug and do what they are told. The DCMA folks shrug and approve the D/S. At least, that's how it seems to me.

I should add, though, that I've seen a few Cost Monitors and Price Analysts really dig into what the contractor is disclosing, and really try to understand what they should expect to see in proposals and invoices. That's a separate process from the D/S review, but it seems to be happening with some regularity. It makes me more comfortable with the D/S review "process".