DOD Contract Management
Overpayments Continue and Management and Accounting Issues Remain Gao ID: GAO-02-635 May 30, 2002Since GAO reported on Department of Defense (DOD) contractor overpayments in 1994, additional reports have been issued highlighting billions of dollars of overpayments to Defense contractors. In December 2001, Congress amended Title 31 of the United States Code to require a federal agency with contracts totaling over $500 million in a fiscal year to have a cost-effective program for identifying payment errors and for recovering amounts erroneously paid to contractors. DOD contractors' responses to GAO's survey indicate that they have millions of dollars of overpayments on their records and that they are continuing to refund overpayments-- about $488 million in fiscal year 2001. DOD has taken actions to address problems with contractor overpayments. In addition to its contract audit functions and as part of a broad based program to assist the Defense Contract Management Agency (DCMA) and the Defense Finance and Accounting Service (DFAS), the Defense Contract Audit Agency (DCAA) is auditing at least 190 large DOD contractors to identify overpayments and ensure that contractors have adequate internal controls for prompt identification and reporting of overpayments. Although DOD has several initiatives to reduce overpayments, it still does not yet have basic administrative control over contractor debt and underpayments because its procedures and practices do not fully meet federal accounting standards and federal financial system requirements for the recording of accounts receivable and liabilities. As a result, DOD managers do not have important information for effective financial management, such as ensuring that contractor debt is promptly collected.
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United States General Accounting Office:
GAO:
Report to the Chairman, Committee on Government Reform, House of
Representatives:
May 2002:
DOD Contract Management:
Overpayments Continue and Management and Accounting Issues Remain:
GAO-02-635:
Contents:
Letter:
Results in Brief:
Background:
Overpayments and Underpayments Continue:
DOD Initiatives to Manage and Reduce Overpayments:
Management and Accounting Control Issues Remain:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: List of Contractors We Surveyed and Results:
Appendix III: Contractor Survey:
Appendix IV: Summary of Results from DCAA Visits to 28 Contractor
Locations:
Appendix V: Comments from the Department of Defense:
Tables:
Table 1: Summary of Survey Results by Large and Small Business
Contractors:
Table 2: Refunds to the Government from Fiscal Years 1994 through 2001:
Table 3: DFAS Columbus Contracts Waiting for Reconciliation at Fiscal
Year-End from 1995 to 2001:
Table 4: Aging of DFAS Columbus Contracts Awaiting Reconciliation as of
September 30, 2001:
Table 5: DFAS Columbus Fiscal Year 2001 Monthly Accounts Receivable and
Amounts in Dispute:
Abbreviations:
CCR: Central Contract Registry:
DCAA: Defense Contract Audit Agency:
DCMA: Defense Contract Management Agency:
DFAS: Defense Finance and Accounting Service:
DMO: Debt Management Office:
DOD: Department of Defense:
DPPS: Defense Procurement Payment System:
FAR: Federal Acquisition Regulation:
FDPS: Federal Procurement Data System:
IG: inspector general:
MOCAS: Mechanization of Contract Administration Services:
SFFAS: Statement of Federal Financial Accounting Standards:
SPS: Standard Procurement System:
[End of section]
United States General Accounting Office:
Washington, D.C. 20548:
May 30, 2002:
The Honorable Dan Burton:
Chairman:
Committee on Government Reform:
House of Representatives:
Dear Mr. Chairman:
Since we reported on Department of Defense (DOD) contractor
overpayments in 1994,[Footnote 1] we have issued additional reports
highlighting billions of dollars of overpayments to Defense
contractors. As a result of these and other reports, there has been
increasing congressional interest in recovering overpayments made to
contractors. In December 2001, this interest led to the Congress
amending Title 31 of the United States Code[Footnote 2] to require a
federal agency with contracts totaling over $500 million in a fiscal
year to have a cost-effective program for identifying payment errors
and for recovering amounts erroneously paid to contractors.
You requested that we update our previous reviews to determine whether
DOD‘s problems with overpayments continue. Specifically, we determined
(1) whether overpayments and underpayments to contractors have
continued, (2) what actions DOD has taken to address payment
discrepancies with contractors, and (3) whether the Defense Finance and
Accounting Service (DFAS) properly accounts for and collects amounts
due from contractors and accounts for amounts the government owes
contractors.
Amounts due the government from DOD contractors can arise from
(1) improper payments made because of progress payment liquidation
errors, contractor billing errors, and other processing errors and
(2) contract administration actions, such as item price adjustments,
changes in delivery schedules, and changes in the quantities ordered,
all of which can occur after valid payments have been made on a
contract. The Federal Acquisition Regulation (FAR) refers to any
amounts due the government resulting from these actions as contractor
debt or overpayments. However, not all of these overpayments could
appropriately be considered improper payments. Specifically, those
resulting from contract administration actions were correct when made,
but due to subsequent changes, the excessive portion of the payment is
to be immediately pursued and promptly collected.
To accomplish our objectives, we (1) surveyed 183 DOD contractors, as
agreed to with your staff, similar to the approach we took in our 1995
report on contractor payment problems,[Footnote 3] (2) assessed DFAS
data on contractor refunds, (3) obtained the status of DOD corrective
actions on our previous recommendations, and (4) reviewed the
management of and accounting for overpayments and underpayments. We
focused our work at DFAS Columbus, which was also the area of emphasis
in prior audit reports on DOD contractor payment problems, because it
is the largest, centralized DFAS disbursing activity”disbursing $78
billion of contract payments to DOD contractors in fiscal year 2001. To
effectively use audit resources, the Defense Contract Audit Agency
(DCAA), as part of its contract audits at high-risk contractors, tested
the validity of selected contractor survey responses for us.
Our scope and methodology are described in more detail in appendix I. We
did not fully assess the reliability of the underlying data in the
contractors‘ responses or the data we obtained from DFAS Columbus. We
reviewed and discussed DCAA‘s work at selected contractor locations
where it performed follow-up work for us. We requested comments on a
draft of this report from the Secretary of Defense or his designee. We
received written comments from the Under Secretary of Defense
Comptroller and have reprinted the comments in this report. We
performed our work from August 2001 through April 2002 in accordance
with generally accepted government auditing standards.
Results in Brief:
DOD contractors‘ responses to our survey indicate that they have
millions of dollars in overpayments and underpayments on their records,
and based on DFAS Columbus records, they are continuing to refund
overpayments”about $488 million in fiscal year 2001. Contractors cited
progress payment liquidation errors as a primary reason for the
overpayments and underpayments. They usually did not include debt due
to contract administration actions”the reason for the majority of
contractor refunds according to DFAS Columbus records”in their reported
overpayments. Additional overpayments and underpayments could be
identified when audits of the over 3,200 contracts requiring some level
of reconciliation, as of September 30, 2001, are completed by DFAS
Columbus. Contractor debt, regardless of cause, is likely to continue
due to DOD‘s complex contract management and payments processes. Even
when payment discrepancies are identified, they are not always promptly
resolved.
DOD has taken actions to address problems with contractor overpayments.
In addition to its contract audit functions and as part of a broad-based
program to assist DCMA and DFAS, DCAA is auditing at least 190 large
DOD contractors to identify overpayments and ensure that contractors
have adequate internal controls for prompt identification and reporting
of overpayments. This type of activity can be considered part of a
recovery audit program. DFAS Columbus has implemented procedures to
better identify potential duplicate payments before the invoices are
paid and to determine and monitor the causes of the duplicate payments.
As part of its long-term solution to contract payment problems, DOD
also is implementing the Standard Procurement System and the Defense
Procurement Payment System to replace current contract administration
and payment systems. However, the full implementation of these systems
has been delayed and their success is uncertain.
While DOD has several initiatives to reduce overpayments, it still does
not yet have basic accounting control over contractor debt and
underpayments because its procedures and practices do not fully meet
federal accounting standards and federal financial system requirements
for the recording of accounts receivable and liabilities. As a result,
DOD managers do not have important information for effective financial
management, such as ensuring that contractor debt is promptly
collected. Further, DOD‘s reported accounts receivable, accounts
payable, and other liabilities could be understated or overstated at
the end of an accounting period. Without complete accounting for
overpayments and underpayments, DOD has not established adequate
performance measures to monitor and manage the timely resolution of
overpayments and underpayments.
This report contains recommendations to the Under Secretary of Defense
Comptroller and the Under Secretary of Defense for Acquisition,
Technology, and Logistics concerning actions to require internal
controls on the recovery of overpayments, establish procedures for the
recording of receivables and liabilities, and to develop and maintain
more complete records on contractor refunds and underpayments. In
written comments on a draft of this report, DOD concurred with our
report recommendations and discussed actions it intends to take to
implement each of our recommendations. These actions appear to respond
to our recommendations.
Background:
DOD‘s contract administration and payment processes involve numerous
organizations, including 23 DFAS offices; the contractors that perform
work and bill the government; the Defense Contract Management Agency
(DCMA), which administers most of DOD‘s largest procurement contracts;
military components‘ project and contracting offices; and DCAA, which
reviews contractors‘ records, internal controls, and billing systems.
The contract administration and payment processes have been described
in our prior reports. If DCMA administers a contract, DFAS Columbus
makes payments using the Mechanization of Contract Administration
Services (MOCAS) system, and DOD refers to the disbursements as
’contract pay.“ In fiscal year 2001, DFAS Columbus disbursed about $78
billion for over 300,000 contracts managed in MOCAS. Contracts that
DCMA does not administer are paid using other systems at the DFAS
offices. DOD refers to these contract disbursements as ’vendor pay.“
The Navy‘s shipbuilding and repair contracts are viewed as vendor pay
because they are not managed by DCMA or paid by DFAS Columbus using
MOCAS. In fiscal year 2001, DFAS processed over 10 million vendor pay
invoices, valued at over $59 billion. Large contractors with numerous
DOD contracts and locations can receive both contract pay and vendor
pay. Effective April 1, 2001, DFAS contract pay and vendor pay
management were consolidated at DFAS Columbus.
Contract payments involve payments for the delivery of goods and
services and financing payments. Financing payments include (1) progress
payments to cover a contractor‘s costs as they are incurred during the
construction of facilities or the production of major weapons systems
and (2) performance-based payments that are based on the accomplishment
of particular events or milestones”typically used on production
contracts. When contractors deliver items and submit invoices for the
delivered items, DFAS Columbus deducts financing payments from the
prices of the delivered items, or ’liquidates“ the financing payments,
based on a predetermined liquidation rate. Liquidation rates may be
adjusted when costs are higher or lower than projected. Contract
modifications can often occur due to changes in liquidation rates,
quantities ordered, and production schedules. These modifications and
other contract administration actions are managed by DCMA through
coordination with the contractors.
Our prior reports on contractor overpayment problems have highlighted
that (1) Defense contractors were refunding hundreds of millions of
dollars to DFAS Columbus each year, (2) DFAS Columbus had made
overpayments due to duplicate invoices and paid invoices without
properly and accurately recovering progress payments, (3) contract
administration actions had resulted in significant contractor debt or
overpayments, (4) DOD and contractors were not aggressively pursuing
the timely resolution of overpayments or underpayments when they were
identified, (5) DFAS Columbus did not have statistical information on
the results of contract reconciliation, and (6) DOD has ongoing actions
to address contractor payment problems.
DFAS Columbus can identify overpayments during contract reconciliation
or can be notified of an overpayment by a contractor or DCMA. When
DFAS Columbus becomes aware of an overpayment, its Accounts Receivable
Branch is to issue an initial demand letter to the contractor and
works with the entitlement divisions, which process and pay invoices, to
collect amounts due the government by initiating an ’offset“ that
reduces the amount paid on invoices in process. The Accounts Receivable
Branch also maintains the detailed records on the accounts receivable.
The contract reconciliation function deals with contracts being closed
out as well as active contracts needing partial audits to resolve prior
and current payment problems, such as overpayments, underpayments, and
invoice deficiencies. Since the mid-1990s, DFAS Columbus has contracted
with a major accounting firm to help reconcile and close out thousands
of contracts. When an amount exceeding $600 is due to the government and
is not collected within 90 days, the debt is supposed to be transferred
to DFAS‘s central Debt Management Office (DMO) for further collection
actions that can include referring debts to the Defense Criminal
Investigative Service or the U.S. Treasury‘s centralized debt collection
programs.
Within the last 6 months, three key actions have been taken to address
governmentwide issues on improper payments. As previously stated, in
December 2001, the Congress amended Title 31 of the United States Code
to require an agency with contracts totaling over $500 million to have a
cost-effective program for identifying payment errors and for recovering
amounts erroneously paid to contractors. The resources for implementing
the recovery program can include the agency, other federal departments
or agencies, and the private sector. As of March 2002, the Office of
Management and Budget had not issued implementing guidance on this
law.[Footnote 4] Another key action was our issuance of an executive
guide,[Footnote 5] in October 2001, that discusses strategies and
control activities, such as recovery auditing, contract audits, and
data mining, to identify and correct improper payments. The third
action, in response to our recommendation,[Footnote 6] was a change in
the FAR, effective February 19, 2002, which added a paragraph to the
’prompt payment“ clause of contracts that requires a contractor to
notify the contracting officer if the contractor becomes aware of an
overpayment and to request instructions for disposition of the
overpayment.
Overpayments and Underpayments Continue:
Defense contractors‘ responses to our survey indicated that they have
millions of dollars in overpayments and underpayments on their records,
and based on DFAS Columbus records, they are continuing to refund
overpayments. According to the contractors, a primary reason for these
payment discrepancies was progress payment liquidation errors.
Contractors usually did not include contractor debt arising from
contract administration actions in the overpayments amounts they
reported. However, according to DFAS Columbus records, contract
administration actions were the primary reason for the $488 million
that contractors refunded in fiscal year 2001. Contractor refunds are
likely to continue because of DOD‘s complex contract management and
payment processes. Also, even when payment discrepancies are
identified, they are not always promptly resolved.
Contractors Reported Overpayments and Underpayments but Extent of Them
Is Uncertain:
Based on information from our surveys, business units of 67 contractors
reported that they had about $62 million of overpayments and about
$176 million of underpayments in their records as of September or
October 2001.[Footnote 7] We sent surveys to 497 business units of 183
contractors, and at least 249 of the business units of 120 contractors
responded. The business units of the remaining 53 contractors that
responded did not report any overpayments or underpayments in their
records. Appendix II provides the details of our survey results and
appendix III contains the survey.
As shown in table 1, which summarizes the results of the survey, 34 of
the largest contractors did not respond to the survey. The 10 largest
contractors”according to their reported annual billings”that responded
to our survey reported about 86 percent of the total overpayments and 78
percent of the total underpayments reported by all of the contractors.
One Boeing contract alone accounted for $27 million of underpayments
due to contract funding issues. Contractors cited DFAS progress payment
liquidation errors as a primary reason for the overpayments and
underpayments. Contractors usually did not include contractor debt
arising from contract administration actions in the overpayment amounts
they reported. However, as discussed later in this report, contract
administration actions are the primary source of contractor refunds.
Most of the contractors reported that demand letters had not been
issued for the overpayments in their records but that they planned to
return about 29 percent of the overpayments by check or offset. For the
remaining 71 percent of the overpayments, contractors did not indicate
any planned actions. According to DCAA, it plans to ensure that all of
the overpayments are properly handled.
Table 1: Summary of Survey Results by Large and Small Business
Contractors:
Number of contractors surveyed:
Large contractors surveyed[A]: 92;
Small business contractors surveyed[A]: 91;
Total: 183.
Number of contractors with at least one response:
Large contractors surveyed[A]: 58;
Small business contractors surveyed[A]: 62;
Total: 120.
Number of contractors that did not respond:
Large contractors surveyed[A]: 34;
Small business contractors surveyed[A]: 29;
Total: 63.
Number of contractors reporting overpayments:
Large contractors surveyed[A]: 31;
Small business contractors surveyed[A]: 11;
Total: 42.
Number of contractors reporting underpayments:
Large contractors surveyed[A]: 31;
Small business contractors surveyed[A]: 26;
Total: 57.
Number of contractors reporting zero payment discrepancies:
Large contractors surveyed[A]: 21;
Small business contractors surveyed[A]: 32;
Total: 53.
Total overpayments reported:
Large contractors surveyed[A]: $61.0 million;
Small business contractors surveyed[A]: $1.0 million;
Total: $62.0 million.
Total underpayments reported:
Large contractors surveyed[A]: $165.3 million;
Small business contractors surveyed[A]: $10.8 million;
Total: $176.1 million.
Total gross billings reported:
Large contractors surveyed[A]: $28,656.0 million;
Small business contractors surveyed[A]: $2,718.0 million;
Total: $31,374.0 million.
[A] Large contractors have the highest dollars of contract actions in
the Federal Procurement Data System, and small business contractors are
designated as such in the system.
Source: GAO survey results.
[End of table]
These survey results cannot be used to determine the extent of
overpayments and underpayments in contractor records at a point in time.
Specifically, the results cannot be projected to a universe of DOD
contractors even if all contractors had reported because the surveyed
contractors were not randomly selected. Further, our analysis of
contractors‘ responses showed inaccuracies in their reporting. For
example, at least 3 contractors included information on contract
payments to federal agencies other than DOD and even to nonfederal
entities. At least 1 contractor reported overpayments that had been
refunded the government and, therefore, should not have been reported
because they were not outstanding overpayments. We also observed that
contractors were not consistent in reporting actions taken on
overpayments. Out of at least 588 reported overpayments, contractors
indicated in their responses that they had notified DOD of 251
overpayments. At the same time, contractors reported that they had not
notified DOD of 236 overpayments. For the remaining 101 overpayments,
contractors did not provide any indication one way or the other.
Based on factors such as contractor size, geographic location, and
amount of reported payment discrepancies, we selected, in coordination
with DCAA, 27 contractor locations involving 24 companies to test the
validity of contractors‘ responses. The selected business units reported
$58 million, or 94 percent, of the total reported overpayments and $126
million, or 71 percent, of the total reported underpayments. We
provided our survey results to DCAA for these business units, and its
auditors found that 10 of the contractor locations underreported
overpayments by $57.2 million and underreported underpayments by $58.0
million. DCAA stated that the remaining 17 locations had reported
accurately. According to DCAA, 5 contractors are primarily responsible
for these large differences and most of the differences are due to
contractors‘ billing weaknesses and erroneous reporting of unpaid
invoices. Appendix IV summarizes the DCAA results. At these same 10
contractor locations, DCAA also found that (1) differences in
application of liquidation rates and weaknesses in contractor billing
systems were primary reasons for both overpayments and underpayments
and (2) unpaid invoices over 30 days old were another primary reason
for underpayments. Such results demonstrate the need for recovery audit
programs, such as DCAA‘s contractor overpayment and underpayment audits
to identify payment errors, recover erroneous payments, and identify
payments due to the contractor.
During its follow-up to our surveys, DCAA also found that contractors
are reluctant to return overpayments on a contract when underpayments on
the same contract result in a net underpaid status. For example, 1 of
the largest DOD contractor‘s records showed a contract with millions of
dollars of overpayments and underpayments that resulted in a $1.8
million net underpaid status. According to the contractor‘s records,
some of these overpayments had occurred in 1997 and had not been
resolved. As of September 30, 2001, the contract was in reconciliation,
and, as of February 2002, these payment discrepancies had not been
resolved. According to DCAA officials, they decided, after consulting
with DFAS, that settlement of any overpayments and underpayments would
be deferred until contract reconciliation is complete and the final
contract amount is settled. DCAA officials stated that the contractor
had basic internal controls for overpayments, and DCAA is assisting the
reconciliation through its project on audits of contractor-prepared
reconciliations.
In responses to our survey, contractors also included overpayments and
underpayments associated with contracts paid through vendor pay. For
example, at least 28 contractors, including 3 major shipbuilding and
ship repair contractors, reported overpayments and underpayments
associated with vendor pay. These 3 major shipbuilding contractors,
alone, reported overpayments of almost $9.4 million and underpayments
of about $0.5 million. According to a response from 1 shipbuilding
contractor, overpayments and underpayments that occur on a contract are
not resolved until contract closeout, which could be several years
later. Another vendor pay contractor reported about $12 million of
underpayments primarily due to underpaid invoices. For contractors
indicating receipt of vendor pay, we could not accurately eliminate the
vendor pay discrepancies from the total amounts reported by the
contractors because (1) not all contractors provided sufficient and
consistent detailed information and (2) we did not validate all of the
responses. Nevertheless, we asked DFAS Columbus to compare its records
to the contractor responses for 106 contracts, and DFAS Columbus told us
it did not make the payments on 42 of the contracts because they were
vendor payments.
Although our prior reports placed more emphasis on contract pay than
vendor pay, recent DOD Office of Inspector General (IG) audits also have
identified weak internal controls in vendor pay systems and overpayments
to contractors. For example, in October 2001 and March 2002, the DOD IG
reported that the Computerized Accounts Payable System, a vendor pay
system used by DFAS Kansas City and DFAS Indianapolis, did not have
proper internal controls to detect and prevent improper payments, and
that DFAS had made at least $13 million of duplicate payments.[Footnote
8] As a result, recovery audits and recovery activities that are now
required by 31 U.S.C. 3561 could be used to improve the management of
contract payments associated with both ’contract pay“ and ’vendor pay.“
Contractor Refunds Primarily due to Contract Administration Actions but
Improper Payments Also Occurred:
From fiscal years 1994 through 2001, DOD contractors have refunded over
$6.7 billion to DFAS Columbus. However, as shown in table 2, DFAS
Columbus records showed that contractor refunds dropped to about $488
million in fiscal year 2001 from $901 million in fiscal year 2000. Of
the $488 million in refunds, DFAS Columbus collected $449 million by
contractors submitting checks and the remaining $39 million through
offsets. However, the level of refunds could be greater because
contracting officers often collect funds from the contractors by
offsets that are agreed to during contract negotiations, and DFAS might
not be notified. Since DFAS keeps track of only those offsets it
processes, its records would not have the number of refunds due to
these other offsets handled directly by DCMA and the contractors.
Table 2: Refunds to the Government from Fiscal Years 1994 through 2001:
Fiscal year: 1994
Amount of refunds: $940 million;
Fiscal year: 1995
Amount of refunds: $1,000 million;
Fiscal year: 1996
Amount of refunds: $1,020 million;
Fiscal year: 1997
Amount of refunds: $950 million;
Fiscal year: 1998
Amount of refunds: $746 million;
Fiscal year: 1999
Amount of refunds: $670 million;
Fiscal year: 2000
Amount of refunds: $901 million;
Fiscal year: 2001
Amount of refunds: $488 million;
Fiscal year: Total
Amount of refunds: $6,715 million;
Source: GAO reports and DFAS Columbus.
[End of table]
DFAS Columbus records showed that about $360 million, or 80 percent of
the $449 million in checks sent to the government in fiscal year 2001,
was due to DCMA contract administration actions and the remaining
$89 million, or 20 percent, was due to payment problems. This is
consistent with what we have previously reported. For example, in
February 2001,[Footnote 9] we reported that 77 percent of $351 million
in excess payments was primarily related to contract administration
actions, and, in July 1999, we reported[Footnote 10] that about 78
percent of the contractor refunds was due to contract administration
and other actions outside of DFAS‘s control.
In tracking contractor refunds due to payment problems, DFAS Columbus
distinguishes between refunds with issued demand letters and refunds
without demand letters”or unsolicited refunds. According to DFAS
Columbus records, refunds due to payment problems were caused primarily
by DFAS processing errors, including improper progress payment
liquidations. We reviewed 12 unsolicited contractor refunds valued at
about $24.2 million, or 83 percent of the total $29.2 million in
unsolicited contractor refunds during the months of October 2000, March
2001, and August 2001. Our review revealed that 6 of the overpayments
were due to progress payment liquidation errors and 6 were duplicate
payments caused by contractor billing errors along with DFAS weaknesses
in detecting and avoiding overpaying in these situations. Some examples
follow.
* In September 2000, Textron Systems refunded $8,194,856 because of a
DFAS error in liquidating progress payments. In August 2000, Textron
billed a net amount of $2,739,301, based on contract delivery price of
$10, 957,205, of which $8,217,904 should have been liquidated. However,
DFAS paid $10,934,158 in August 2000.
* In July 2001, Boeing refunded $5,527,922 due to the incorrect
liquidation of progress payments on two invoices. DFAS overpaid one
invoice by $2,077,922 and another invoice by $3,450,000 because it used
an incorrect liquidation rate.
* In March 2001, Northrup Grumman refunded $1,855,788 for a duplicate
payment. DFAS first paid this amount in September 1999 for an invoice
submitted in August 1999, and it paid the same amount again in January
2000. DFAS documentation did not indicate what allowed the invoice to
be processed twice. The unsolicited refund was about 15 months after
the overpayment.
* In August 2001, the Eagle Support Services Corporation refunded
$958,339 because it had received two payments for the same invoice.
The contractor submitted an electronic invoice on June 28, 2001, which
DFAS paid on July 10, 2001. However, the contractor had earlier
submitted a hard copy invoice on June 11, 2001, which DFAS paid on
July 18, 2001. DFAS processed each invoice because the invoices had
different shipment numbers.
DOD contract management, payment, and accounting processes are complex
and remain at risk of contractor debt arising from contract
administration actions and overpayments caused by payment and billing
errors. We reported in January 1998[Footnote 11] that DOD‘s contract
management and payment process involves numerous organizations that
share data using both manual and automated means that are not
integrated. Since then, DOD has implemented more electronic sharing of
contract information and invoicing to reduce manual processes. However,
in December 2000 and April 2001, the DOD IG reported that additional
controls were needed in electronic document sharing and interchange to
ensure security of the data.[Footnote 12] In addition, DFAS personnel
told us that contract and invoicing information still must be manually
entered into MOCAS. For example, contracts with special payment
instructions need to be processed manually because they are an
exception to the MOCAS automatic payment process.
One effect of the overall complex process is that DFAS Columbus can
sometimes issue demand letters that it later cancels due to subsequent
contractor, contracting officer, or DFAS actions to correct or otherwise
resolve the basis for the debt. In fiscal year 2001, DFAS Columbus
canceled $37.5 million of demand letters. A few examples follow.
* Lucent Technologies almost received a duplicate payment of $1,397,200
when the contractor submitted invoices to DFAS Omaha in October 2000
and DFAS Columbus in December 2000 for the same amount. DFAS Omaha, the
originally designated contract payment office, paid the first invoice.
Subsequently, DFAS Columbus became the payment office, and the
contractor resubmitted the invoice to DFAS Columbus, which initiated
payment. However, DFAS Columbus identified the duplicate payment,
issued a demand letter, and then canceled the demand letter when it
stopped the electronic funds transfer payment before it was processed
by the contractor‘s bank.
* In April 2001, DFAS issued a demand to Lockheed Martin for a
$2,755,244 debt that occurred in September 1997 when a contracting
officer issued a contract modification reducing the contract amount. An
April 1998 audit of the contract identified that the wrong accounting
line was cited in this modification, which created a debt. Even though
the contracting officer was notified of the mistake at that time, no
action was taken until DFAS issued the demand letter. In May 2001, a
contracting officer prepared another contract modification to cite the
correct accounting line, which eliminated the debt. DFAS then canceled
the demand.
* A demand to Litton Systems Advanced, Inc. for a $2,124,022
overpayment was canceled when the contractor sent an invoice with the
amount reduced for the overpayment.
The entire contract management and payment process, which has been
described in our prior reports, is further complicated by how progress
payments are accounted for in contract records, a method that can
ultimately create (1) differences in contractor and DFAS Columbus
records and (2) future payment and contract reconciliation problems. In
April 1997, we reported [Footnote 13] that contract payment problems
can occur when DFAS Columbus liquidates progress payments because of
payment allocations to an accounting classification reference number on
a contract that have little relationship to the work performed. If
payment allocations must be made using a different process than the
MOCAS automated process, especially when contracts have special payment
instructions, the risk of error increases. As mentioned earlier in this
report, contractors responded that progress pay liquidation errors were
a major reason for overpayments. This is consistent with our October
1995 report [Footnote 14] indicating that according to DFAS Columbus
analysis the most frequent cause of an overpayment was the incorrect
recovery of progress payments. DFAS Columbus data on fiscal year 2001
overpayments showed that progress payment liquidation problems were one
cause of the overpayments, but that the primary reasons were contract
modification and invoice processing errors.
Overpayments Likely to Be Identified by Contract Reconciliation:
Even though contractors or contracting officers identify many
overpayments, the DFAS Columbus contract reconciliation function is also
likely to identify many overpayments. Of the 2,512 demand letters issued
by DFAS Columbus in fiscal year 2001, its records showed that contract
reconciliation had identified overpayments associated with 1,115 demand
letters, valued at about $83.4 million. Its records also showed that the
contractor or a contracting officer had initiated the remaining 1,397
demand letters, valued at about $43.8 million. The contract
reconciliation process is intended to identify and correct imbalances
between (1) the contractor‘s invoiced amounts and recorded amounts paid
in MOCAS, (2) contract obligation and disbursement balances in DFAS
accounting records and MOCAS, and (3) the contract obligation amount
and MOCAS obligation and disbursement amounts. The contract
reconciliation function at DFAS Columbus deals not only with contracts
that are candidates for closure but also those contracts needing
partial audits to resolve prior payment problems and correct
deficiencies so that DFAS Columbus can pay current invoices.
As shown in table 3, at fiscal year-end, the number of contracts
waiting for reconciliation had averaged about 2,300 for the past 7
years. However, during the year, the number of contracts going through
reconciliation can be much greater. For example, in fiscal year 2001,
DFAS Columbus processed over 8,100 contracts through reconciliation. As
of September 30, 2001, DFAS Columbus had 3,249 contracts waiting for
some level of reconciliation, a higher level than in the prior 6 years.
Based on prior year results, contract reconciliation will likely
identify millions of dollar of overpayments needing resolution.
Table 3: DFAS Columbus Contracts Waiting for Reconciliation at Fiscal
Year-End from 1995 to 2001:
Fiscal year-end: 1995;
Number of contracts awaiting reconciliation: 2,372.
Fiscal year-end: 1996;
Number of contracts awaiting reconciliation: 2,553.
Fiscal year-end: 1997;
Number of contracts awaiting reconciliation: 2,167.
Fiscal year-end: 1998;
Number of contracts awaiting reconciliation: 2,494.
Fiscal year-end: 1999;
Number of contracts awaiting reconciliation: 1,881.
Fiscal year-end: 2000;
Number of contracts awaiting reconciliation: 1,507.
Fiscal year-end: 2001;
Number of contracts awaiting reconciliation: 3,249.
Average for fiscal years:
Number of contracts awaiting reconciliation: 2,318.
Source: DFAS Columbus.
[End of table]
As shown in table 4, of the 3,249 contracts awaiting reconciliation, as
of September 30, 2001, 575 had been in this status for over 360 days,
while 1,523 of the contracts had been awaiting reconciliation for 90
days or less. This is fewer than what we reported [Footnote 15] in July
1999 when over 900 of 2,453 contracts had been in reconciliation for
over a year. Included in the contracts awaiting reconciliation are
contracts for some of the largest contractors included in our survey.
For example, 3 of the largest DOD contractors that responded to our
survey”Lockheed Martin, Raytheon, and Boeing”had 205, 191, and 119
contracts, respectively, waiting for reconciliation as of August 31,
2001. In addition, 1 of the large contractors that did not respond to
our survey had 56 contracts in reconciliation at DFAS Columbus. As
noted later in this report, DCAA is auditing contractor-prepared
reconciliations at these large contractors, and DFAS uses the audit
results in completing the contract closeout process.
Table 4: Aging of DFAS Columbus Contracts Awaiting Reconciliation as of
September 30, 2001:
Days in reconciliation: 90 days or less;
Number of contracts awaiting reconciliation: 1,523.
Days in reconciliation: 91 to 180;
Number of contracts awaiting reconciliation: 666.
Days in reconciliation: 181 to 360;
Number of contracts awaiting reconciliation: 485.
Days in reconciliation: 361 to 720;
Number of contracts awaiting reconciliation: 219.
Days in reconciliation: Over 720;
Number of contracts awaiting reconciliation: 356.
Days in reconciliation: Total;
Number of contracts awaiting reconciliation: 3,249.
Source: DFAS Columbus.
[End of table]
The error-prone nature of the contract management and payment process
is illustrated by over 15,000 contracts in fiscal years 2000 and 2001
combined that have gone through some level of reconciliation at DFAS
Columbus. Contract provisions often change, affecting deliveries,
progress payment liquidation rates, and indirect cost rates, which
creates excess payments after invoices have been paid. As we reported
[Footnote 16] in January 1998, MOCAS records may differ from the
accounting office records because contract information, such as
modifications, may not have been properly and consistently processed by
all locations. DFAS and contractors can process invoices in different
sequences resulting in discrepancies in how progress payments are
liquidated. As a result, many contracts can require some type of
reconciliation more than once during their life. DFAS Columbus contract
reconciliation results for fiscal year 2001 indicated that the majority
of payment problems identified during research were due to payment
system errors and erroneous processing of contract modifications.
Overpayments Are Not Always Recovered Promptly:
We also have previously reported that overpayments are not always
recovered promptly. [Footnote 17] As mentioned in prior reports, such
delays can cost the government in lost interest charges and use of the
funds.
According to DFAS Columbus records, even though it had collected almost
$85.7 million in fiscal year 2001, problems remain with the timely
recovery of overpayments. For example, of the 546 overpayments,
including voluntary contractor refunds, for which DFAS Columbus had
recorded in its records both the check receipt date and the date the
overpayment was identified, only 75 were refunded within 30 days, with
294 being refunded after 90 days. Moreover, 360 additional refunds did
not have the dates necessary to determine the timeliness. Further, as
of August 2001, DFAS Columbus accounts receivable records showed that
about $26 million out of $54.8 million total receivables, or 47
percent, had been outstanding for over 90 days. Of those outstanding
for over 90 days, about $18.8 million had not been resolved for over a
year because contractors had disputed these receivables”also discussed
later in this report. We reviewed 11 files for these old accounts
receivable and some examples follow.
* In November 1997, DFAS Columbus issued a demand letter to McDonnell
Douglas for $2,294,454. The contractor disputed the demand and, in
March 1998, the contract was submitted to audit. As a result of the
audit, the demand was reduced to $27,904. However, DFAS did not issue a
demand for the reduced amount. In May 2000, DFAS decided to update the
audit on the contract. As of December 2001, over a year after the
second audit, the recorded receivable was still $2,294,454 because the
DFAS Columbus Accounts Receivable Branch had not been informed of the
audit results.
* In August 1996, DFAS Columbus issued a demand letter to Hughes
Aircraft for $2,032,113. DFAS subsequently issued a second demand
letter in September 1996. The contractor disputed the demand but did
not provide sufficient detail to support the dispute so that an audit
could resolve the dispute. In January 1997, DFAS Columbus asked the
contractor for additional information, and the contractor responded that
the problem might be with several different progress payment and
liquidation rates on the contract. As of December 2001, the account
receivable file showed that no action had been taken.
* In September 1999, DFAS Columbus issued a demand letter for
$3,886,567 to Raytheon because of a duplicate payment that had occurred
in 1995. The contractor disputed the demand and provided evidence that
it had sent a check for $3,137,200 for the debt in August 1995.
However, according to DFAS Columbus, this left a balance due of
$749,369. In November 1999, DFAS issued a demand letter for this new
balance due, and Raytheon disputed the remaining amount of the debt.
As of December 2001, the $749,369 demand had not been resolved.
After we shared our concerns about aged disputes with DCAA, it attempted
to resolve these receivables as part of its recovery audit effort. As
of this report‘s date, DCAA is still in the process of examining
contractor data to determine the validity of the debt. DFAS inattention
to resolving these disputed receivables and determining their validity
could result in potentially overstated accounts receivable balances.
Further, contract closeout problems, which we reported on in July 2001,
[Footnote 18] can be exacerbated when payment discrepancies are not
promptly resolved. We reported that DFAS had made $615 million of
illegal and improper adjustments to closed appropriation accounts, and
these adjustments included $9.9 million of overpayments that had been
improperly redistributed to open appropriation accounts after the
original accounts were closed.
DOD Initiatives to Manage and Reduce Overpayments:
In response to our prior recommendations, DOD has taken both short-term
actions and established long-term initiatives to address long-standing
contract payment problems that result in overpayments and
underpayments. Some of the short-term actions appear to be having some
positive results. However, the success of the longer-term initiatives,
which are more critical to resolving underlying problems in the
contract payment systems and processes, is uncertain.
In the short term, DFAS, DCMA, and DCAA, in coordination with the DOD
Comptroller, have initiatives to (1) audit major DOD contractors to
identify overpayments and evaluate their internal controls for
identifying and reporting overpayments and (2) reconcile and close out
old contracts. Specifically, in August 2001, DCAA agreed to assist DFAS
in addressing excess payments to contractors, debt collection, invoice
payment instructions, contract reconciliation, and professional
development. Subsequently, in November 2001, DCAA began audits on
overpayments and related contractor internal controls for identifying
and promptly reporting overpayments. Its plan is to complete audits at
190 contractors in fiscal year 2002. As of March 2002, the number of
contractors to be audited had increased to 195. As part of this effort,
DCAA is also examining some of the aged (over 90 days old) accounts
receivable in dispute according to DFAS Columbus records.
As of January 2002, DCAA had completed audits of overpayments at 46
contractors and identified over $22.7 million of overpayments. From
additional special audits of progress payments, DCAA identified about
another $27.3 million of overpayments, most of which were promptly
resolved. These results illustrate what can be accomplished from
programs to identify payment errors and recover erroneous payments.
DCAA officials stated that they would continue overpayment audits until
contractors‘ controls ensure prompt identification and reporting of
overpayments to DOD. While DCAA efforts could be viewed as a type of
recovery activity, DOD does not have an overall recovery audit program
that includes all types of contract payments. DCAA also has been
involved with the contract reconciliation of old contracts at large
contractors to facilitate contract closeout and the transition to the
new systems intended to replace MOCAS.
DCMA, in response to DOD overpayment issues, has issued additional
guidance to its contracting officers. For example, in April 2000 and
November 2001, it issued memorandums on the identification and recovery
of overpayments and excess progress payments, respectively. These
memorandums emphasized the need for contracting officers to be alert to
situations in which contractor debt is incurred and to immediately issue
demand letters. Further, in a response to our February 2001
recommendation, DCMA stated that it is using DFAS Columbus information
on refunds to identify and evaluate possible systemic contract
administration problem areas.
DFAS Columbus, in response to prior reported deficiencies, has
implemented practices to provide better oversight of the reasons for
overpayments and the results from contract reconciliation. For example,
it established a central-tracking database to categorize reasons for
contractor refunds. This database identifies different types of
possible DFAS Columbus errors and the types of contract administration
actions creating the contractor debt. In addition, DFAS Columbus has
been tracking contract reconciliation results to identify reasons for
the payment problems identified during reconciliation. Although DFAS
Columbus personnel easily provided us summary and detailed information
from these databases, the information had not been summarized and
incorporated into performance management indicators.
An additional DFAS Columbus effort, initiated in May 2000, is to
identify and monitor the potential for duplicate payments. Monthly
reports, including one on causes of duplicate payments, are prepared
for each of the three entitlement sections at DFAS Columbus and
summarized for management review. According to the duplicate payment
report for the first quarter of fiscal year 2002, DFAS Columbus had
avoided making about $181.7 million of duplicate payments that had been
identified as a result of the new procedures. DFAS Columbus has also
issued several operating procedures to improve payment processing.
The success of DOD‘s implementation of new systems to address the root
causes of contract administration and payment problems is uncertain.
DOD is planning on full implementation of the Standard Procurement
System (SPS) and the Defense Procurement Payment System (DPPS) to
improve contract management and payment processes by replacing MOCAS,
which has been used since 1968. SPS is intended to be DOD‘s single,
standard system to support contracting functions and interfacing with
financial management functions, such as payment processing. However, in
July 2001, we reported [Footnote 19] that (1) full implementation of
SPS has been delayed 3-1/2 years, (2) DOD had not justified the
continued investment in SPS, (3) SPS modules to manage the large
weapons systems procurements had not yet been implemented, and (4) the
DOD IG had found that the system lacked critical functionality and
users were generally dissatisfied with the system.
DPPS is intended to be DOD‘s standard contract payment system. However,
DPPS implementation at DFAS Columbus has been delayed over 2 years”from
August 2001 to October 2003. According to DPPS program officials, the
implementation of DPPS is not dependent on the full implementation of
SPS. Nevertheless, the DOD IG concluded in its September 2001 report
that DPPS would not fully eliminate disbursement and contract
accounting problems because DFAS, in order to comply with special
payment instructions, will need to continue making manual payments for
which there is a greater risk of errors being made.
Management and Accounting Control Issues Remain:
Despite DOD‘s initiatives and accomplishments in addressing overpayment
problems, DOD does not yet have fundamental control over contractor
debt and underpayments because its procedures and practices do not fully
meet federal accounting standards, federal financial system
requirements, and its own accounting policy. Further, DOD managers do
not have the performance measures needed to assess compliance with
policies and procedures and the extent of overpayment and underpayment
problems at a point in time. Specific examples follow.
* Federal accounting standards, federal financial system requirements,
and DOD‘s accounting policy call for the prompt and accurate recording
of accounts receivable upon completion of the event that entitles
collection of the amount. [Footnote 20] These standards and
requirements specify that an amount be estimated if the exact amount is
unknown at the time the claim is established. However, contractor debt
arising from contract administration actions usually is not recorded as
an accounts receivable when the debt is established in the contract or
its modification”the event that entitles DOD to collect an amount from
the contractor. Instead, the DFAS Columbus Accounts Receivable Branch
records an account receivable after it has been notified of the debt
and it or DCMA has issued a demand letter. Contractors often refund
amounts from contract administration actions, as well as from payment
and billing errors, without DCMA or DFAS Columbus issuing demand
letters. Together, these factors would tend to mask the extent of
overpayment problems and result in overpayments not being known or
promptly addressed.
* Federal financial system requirements and DOD accounting policy also
stipulate that accounts receivable are to be aged for monitoring and
controlling collection. DOD accounting policy specifies that accounts
receivable are to be aged into 10 groups, ranging from 1 to 30 days
delinquent to over 3 years delinquent. Even though DFAS Columbus tracks
the number of accounts receivable in dispute, its Accounts Receivable
Branch, which collects overpayments and maintains the detailed
accounting records to support collection activities, does not routinely
age accounts receivable according to DOD accounting policy to help
manage and monitor the timely resolution of the accounts.
* DOD policies require that a receivable be recorded within the same
month discovered in order to be recorded timely and that contractor
debts be promptly collected. However, DOD does not have adequate
performance measures on the timeliness of collection efforts for
contractor debt once it has been identified.
* Federal accounting standards also specify that accounts payable and
other liabilities will be recorded when the potential for the liability
is first recognized. Such liabilities include estimates of work
completed for facilities and equipment or requests for progress
payments for items constructed or manufactured to contract
specifications. DFAS Columbus does not maintain detailed records on
underpayment liabilities or accounts payable after the contractors
notify it of the underpayments, even though the underpayments could be
for millions of dollars and take months to resolve.
As a result, DOD managers do not have appropriate management control of
accounts receivable and accounts payable and other liabilities stemming
from its contract administration and payment processes. Aside from the
high risk that these accounting records could be misstated at the end
of an accounting period, failure to instill these disciplines magnifies
the level of effort required to later identify and collect these
amounts.
Contract Administration Events That Create an Account Receivable Are Not
Recorded When They Occur:
DFAS Columbus does not usually record an accounts receivable when the
debt is first created by a contract administration action. Instead, it
only tracks the checks from contractors when they are received and the
offsets of contractor invoices after they have been completed. DOD
policies and procedures require the contracting officer to issue a
demand letter to a contractor when an overpayment is identified and to
send a copy of the demand letter to DFAS Columbus where it is recorded
as an accounts receivable. When contract administration actions are
implemented through contract modifications or other signed agreements,
these documents recognize that a repayment will result from the action
and the amount owed is identified or can be readily calculated.
However, DCMA and DFAS do not always issue demand letters for
contractor debt based on contract administration actions because the
debt could be resolved promptly and issuing a demand letter would
involve additional effort.
While federal accounting standards require that such events be
recognized as accounts receivable, DFAS cannot recognize the receivable
unless it is promptly notified of contractor debt.
In fiscal year 2001, DFAS Columbus records showed that contractors
refunded about $360 million due to contract administration actions, but
the Accounts Receivable Branch only recorded about $127 million of
accounts receivable based on issued demand letters that included
duplicate payments and other payment errors. This comparison shows that
established procedures are not always followed. Additionally, we
reported [Footnote 21] in February 2001 that contracting officers do
not consistently issue demands for payment when contract changes are
negotiated even though the amount usually is known or can be
calculated. As a result, significant amounts of contactor debt arising
from contract administration actions are not being recorded when they
first occur as accounts receivable for financial management control and
reporting. A further result, discussed later, is that DOD cannot fully
measure the timeliness of contractor debt collection so that problems
can be identified and effective solutions implemented prior to final
contract reconciliation.
Effective February 19, 2002, the FAR was amended to add a paragraph to
the recommended ’prompt payment“ clauses of contracts requiring the
contractor to notify the contracting officer if it becomes aware of a
duplicate payment or an overpayment on an invoice. By its terms,
however, this requirement does not apply to overpayments due to errors
in financing payments or contract administration actions. With few
exceptions, the contracting officer should include this clause in
contracts. A similar revision to the FAR contract financing clauses
would ensure that all contractor debt would be promptly identified,
reported, and collected. The Office of Federal Procurement Policy is
currently reviewing for approval and publication revisions to the FAR
financing clauses that will require contractors to notify the
government if they become aware of overpayments arising from financing
payments. Adequate implementation of these procedures along with prompt
contracting officer action could facilitate the proper and complete
recording of accounts receivable by DFAS.
Accounts Receivable Were Not Aged:
DFAS Columbus is a primary DFAS activity involved in collecting
contractor debt and maintaining the detailed accounting records to
support collection activities. However, its Accounts Receivable Branch
did not routinely age its accounts receivable records, stemming from
DOD‘s contract management and payment process, as required by DOD‘s
accounting policy. The DFAS ’Concept of Operations for Recording and
Reporting Receivables Due From the Public“ effectively exempts DFAS
Columbus from this requirement because all receivables that are not
collected in 90 days are supposed to be sent to DMO. DFAS Columbus
procedures also specify that any debt in excess of $600 that has not
been resolved after two demand letters be transferred to DMO. However,
DFAS Columbus personnel told us that when a contractor disputes the
first or second demand letter the debt would not normally be
transferred to DMO because the validity of the debt has not been
established. Even though DFAS Columbus maintained information on the
number of accounts receivable in dispute each month, the disputed
amounts were not routinely aged. As we discussed earlier, about 47
percent of the receivables were over 90 days old. As of August 2001,
over $23.5 million of the $35.1 million of demand letters in dispute
had been outstanding for months, even years, and, therefore, had not
been transferred to DMO.
As a result of the policy exemption and DFAS Columbus not aging its
accounts receivable, DFAS did not have proper control over receivables
due from contractors. In fiscal year 2001, DFAS Columbus issued demand
letters for about $127 million. However, as shown in table 5, the
amounts in dispute averaged about $33.8 million, or almost 60 percent
of the total monthly receivables, during the year.
Table 5: DFAS Columbus Fiscal Year 2001 Monthly Accounts Receivable and
Amounts in Dispute:
Month: October;
Accounts receivable balance: Number of transactions: 613;
Accounts receivable balance: Dollars in millions: $60.0;
Accounts receivable in dispute: Number of transactions: 109;
Accounts receivable in dispute: Dollars in millions: $35.9;
Percentage dollar value of accounts receivable in dispute: 60%.
Month: November;
Accounts receivable balance: Number of transactions: 597;
Accounts receivable balance: Dollars in millions: $62.8;
Accounts receivable in dispute: Number of transactions: 110;
Accounts receivable in dispute: Dollars in millions: $36.2;
Percentage dollar value of accounts receivable in dispute: 58%.
Month: December;
Accounts receivable balance: Number of transactions: 642;
Accounts receivable balance: Dollars in millions: $57.1;
Accounts receivable in dispute: Number of transactions: 114;
Accounts receivable in dispute: Dollars in millions: $32.5;
Percentage dollar value of accounts receivable in dispute: 57%.
Month: January;
Accounts receivable balance: Number of transactions: 579;
Accounts receivable balance: Dollars in millions: $57.8;
Accounts receivable in dispute: Number of transactions: 115;
Accounts receivable in dispute: Dollars in millions: $32.6;
Percentage dollar value of accounts receivable in dispute: 56%.
Month: February;
Accounts receivable balance: Number of transactions: 582;
Accounts receivable balance: Dollars in millions: $51.9;
Accounts receivable in dispute: Number of transactions: 114;
Accounts receivable in dispute: Dollars in millions: $32.7;
Percentage dollar value of accounts receivable in dispute: 63%.
Month: March;
Accounts receivable balance: Number of transactions: 561;
Accounts receivable balance: Dollars in millions: $51.9;
Accounts receivable in dispute: Number of transactions: 115;
Accounts receivable in dispute: Dollars in millions: $33.8;
Percentage dollar value of accounts receivable in dispute: 65%.
Month: April;
Accounts receivable balance: Number of transactions: 554;
Accounts receivable balance: Dollars in millions: $61.8;
Accounts receivable in dispute: Number of transactions: 113;
Accounts receivable in dispute: Dollars in millions: $33.6;
Percentage dollar value of accounts receivable in dispute: 54%.
Month: May;
Accounts receivable balance: Number of transactions: 666;
Accounts receivable balance: Dollars in millions: $50.1;
Accounts receivable in dispute: Number of transactions: 116;
Accounts receivable in dispute: Dollars in millions: $34.8;
Percentage dollar value of accounts receivable in dispute: 70%.
Month: June;
Accounts receivable balance: Number of transactions: 699;
Accounts receivable balance: Dollars in millions: $61.5;
Accounts receivable in dispute: Number of transactions: 119;
Accounts receivable in dispute: Dollars in millions: $35.7;
Percentage dollar value of accounts receivable in dispute: 58%.
Month: July;
Accounts receivable balance: Number of transactions: 731;
Accounts receivable balance: Dollars in millions: $56.7;
Accounts receivable in dispute: Number of transactions: 116;
Accounts receivable in dispute: Dollars in millions: $34.8;
Percentage dollar value of accounts receivable in dispute: 61%.
Month: August;
Accounts receivable balance: Number of transactions: 782;
Accounts receivable balance: Dollars in millions: $54.8;
Accounts receivable in dispute: Number of transactions: 118;
Accounts receivable in dispute: Dollars in millions: $35.1;
Percentage dollar value of accounts receivable in dispute: 64%.
Month: September;
Accounts receivable balance: Number of transactions: 667;
Accounts receivable balance: Dollars in millions: $55.0;
Accounts receivable in dispute: Number of transactions: 91;
Accounts receivable in dispute: Dollars in millions: $27.6;
Percentage dollar value of accounts receivable in dispute: 50%.
Average per month:
Accounts receivable balance: Number of transactions: 639;
Accounts receivable balance: Dollars in millions: $56.8;
Accounts receivable in dispute: Number of transactions: 113;
Accounts receivable in dispute: Dollars in millions: $33.8;
Percentage dollar value of accounts receivable in dispute: 60%.
Source: DFAS Columbus and GAO calculations.
[End of table]
In May 2001 and June 2001, the DOD IG and we reported [Footnote 22]
that even when debts were transferred to DMO, collection of the debts
was not being effectively and proactively pursued. In its comments to
our report, DOD indicated that it took immediate actions to monitor and
improve debt collection in DMO. However, we did not assess the status
and effectiveness of these actions for this report”we limited our
review to those accounts receivable that had not been transferred to
DMO as of August 2001.
Lack of Performance Measures on Timeliness of Collection Efforts:
DOD also does not have adequate performance measures to monitor how
timely contractor debt is collected once it is identified. For example,
DCMA does not include the timeliness of contracting officers‘ actions
on overpayments as a key performance measure, and DCMA officials stated
that statistics on demand letters issued by contracting officers are
not kept. FAR and DCMA‘s procedures require the contracting officer to
take prompt action on contractor debt. However, the contracting officer
might not always take immediate action to collect the overpayment due a
large workload or oversight. For example, during its follow-up at 1
major contractor, DCAA found that the contractor had reported to its
contracting officer a $59,346 overpayment in June 1998 and a $144,504
overpayment in March 2001. The contractor assumed that these amounts
would be collected by an offset, but DOD did not take actions to
collect these amounts until after our survey. In January 2002, the
$144,504 was collected through offsets and a refund check. In December
2001, the $59,346 had only been partially collect through offset and
$21,913 was still outstanding at the time of DCAA‘s review in February
2002. In addition, the DFAS Columbus refund records lack key data, such
as dates of contract modifications or credit memorandums, needed to
measure the timeliness of collection for most refunds of contractor
debt arising from contract administration actions. Our review of the
documentation for 15 contract administration refunds, valued at $62.3
million, found that (1) 5 of them did not have enough information to
determine whether the funds were collected timely, (2) 2 were collected
within 30 days from the time an amount due the government was
identified, and (3) 8 were collected in over 30 days”1 in over 90 days
and another in over a year.
Even for the offsets that DFAS Columbus processes, it tracks them
separately from the other refunds, does not measure the timeliness of
collection, or does not always identify the reason for the overpayment.
Our review of 15 offsets from January, February, and June 2001 found
that 12 of them took over 30 days to fully collect the debt and reasons
for the debt were not always identified. Two examples follow.
* On February 21, 2001, United Technologies agreed to DFAS Columbus
taking offsets to collect $8,607,568 of overpayments. Three offsets were
taken to collect the full amount”the initial offset occurred on February
24, 2001, and the third offset occurred on March 23, 2001. The recording
of these offsets in the contract accounting records was completed on
April 6, 2001, or 44 days later. DFAS Columbus records also did not
indicate a reason for the overpayment.
* In November 1999, Viasat, Inc. first contacted DCMA about $2,605,889
it owed the government due to a change in contract terms. The contractor
contacted DCMA again in October 2000 to discuss an offset. DCMA
provided DFAS Columbus a credit voucher on November 13, 2000, and DFAS
processed the voucher on December 18, 2000. However, DFAS Columbus did
not complete the offset until January 29, 2001”97 days after the
contractor expressed interest in an offset. DFAS Columbus records did
not indicate a reason for the time involved to complete the offset.
In its contractor overpayment audits, DCAA also is examining contractor
records on refunds and offsets. According to DCAA, preliminary results
from its contractor audits indicate that (1) not all amounts due the
government are promptly returned and (2) contractor controls over
offsets are weak because the contractors lack supporting documentation
and DFAS is not always notified of offsets that occur. As a result,
contractor and DFAS accounting records may not agree for certain
contracts, and DOD lacks complete information on the amount of refunds
being collected.
Inadequate Monitoring of Underpayments:
DOD also is unable to fully measure and monitor underpayments and the
timeliness of their resolution. Even though DFAS Columbus maintains data
on unpaid contractor invoices, it could not provide us any other
information on contractor underpayments. According to DFAS Columbus
officials, they do not maintain detailed records on underpayments
because contractors usually notify them promptly about underpayments,
which is not always the case with overpayments. Yet, the contractors
that responded to our survey indicated that they had over $176 million
of underpayments in their records at the end of fiscal year 2001.
According to federal accounting standards and financial system
requirements, such information on underpayments should be routinely
recorded and maintained in accounts payable or other liability records.
In February 2001, we reported [Footnote 23] that for the 39 contractors
we reviewed, all of the fiscal year 1999 unresolved underpayments had
been unresolved for over 180 days. Without complete detailed accounting
records on payables, DFAS Columbus is unable to adequately monitor the
resolution of underpayments, and the amount of payables reported by
DFAS Columbus could be understated at the end of an accounting period.
Further, any problems with unresolved underpayments could hinder prompt
resolution of overpayments.
Conclusions:
Survey results, DCAA audits, and DFAS Columbus data indicated that
contractor debts resulting from contract administration actions as well
as payment problems exist for all DOD contract payments”contract pay as
well as vendor pay. Further, resolution of contractor debt has not
always been timely. DOD has taken short-term actions, including
increased contract audits focusing on overpayments that are achieving
immediate results. However, its longer-term initiatives rely on new
automated systems that have not been implemented to address many of the
existing problems in DOD‘s contract management and payment processes.
The success of these systems is uncertain because of the problems in
functionality, costs, and significant delays that the DOD IG and we
have reported on. Until these contract management and payment processes
are improved, DOD‘s risk of contractor overpayments, regardless of
cause, and underpayments will continue. Accordingly, development and
implementation of an internal control to identify and recover
contractor debt, which is now required by 31 U.S.C. 3561, will be
important.
DOD could have better management control of all types of contractor
debt, regardless of cause, and underpayments by establishing procedures
calling for (1) accounts receivable and liabilities to be recorded in
accounting records according to federal accounting standards and
federal financial system requirements and (2) mechanisms to hold staff
and management accountable for doing so. The accounting records could
then provide more comprehensive performance measures for DOD managers
to monitor the timely collection of all amounts due the government and
resolution of underpayments. Such measures could, in turn, result in
more effective financial management and help reduce contract
reconciliation and closeout problems in the future.
Recommendations for Executive Action:
We recommend that the Under Secretary of Defense Comptroller in
coordination with the under Secretary of Defense for Acquisition,
Technology, and Logistics:
* implement an internal control, as now required by 31 U.S.C. 3561, to
identify and collect overpayments to contractors, regardless of contract
payment type;
* reevaluate DCMA, DOD Comptroller, and DFAS established procedures and
controls and revise them as needed to ensure prompt recognition and
recording of receivables and potential liabilities stemming from DOD‘s
contract management and payment processes, according to federal
accounting standards and financial management system requirements; and;
* develop and maintain more comprehensive and complete records on
contactor refunds and underpayments to better measure and monitor (1)
the timeliness of all collections, including checks and offsets, (2) the
resolution of demand letter disputes, (3) the causes of overpayments
and underpayments, (4) the resolution of overpayments and underpayments
and the need for corrective actions, and (5) compliance with policies
and procedures.
Agency Comments and Our Evaluation:
DOD provided written comments on a draft of this report, which are
reprinted in appendix V. DOD concurred with the report‘s
recommendations.
In its comments, DOD emphasized that it supports the requirement for an
audit recovery program, was taking actions consistent with such a
program before the enactment of 31 U.S.C. 3561, and will comply with
future Office of Management and Budget guidance. In addition, DOD
stated that (1) DFAS has implemented several additional internal
controls in its contractor entitlement and payment process to identify
erroneous payments for recovery and minimize future erroneous payments,
(2) new MOCAS procedures are being developed and implemented to reduce
progress payment liquidation differences, and (3) its contract audit
resources are being better used to detect overpayments. DOD also stated
that its financial management guidance on recording accounts receivable
and payable and account aging is consistent with the federal accounting
standards, but to improve compliance requires consideration of the
existing processes, factors establishing claims or obligations, and
ways to manage efficiently and cost effectively. Further, DOD stated
that to improve compliance, (1) DOD is developing new performance
indicators on accounts receivable, overpayments, and aging, (2) DFAS is
reviewing and revising its procedures in this area, and (3) DFAS
Columbus plans to modify its accounts receivable processes to measure
the timeliness of collections for amounts due and is working with
contractors and DCAA to reduce the number and age of disputes.
DOD also provided detailed technical comments that we incorporated into
the report as appropriate.
As you requested, unless you publicly announce its contents earlier, we
plan no further distribution of this report until 30 days from the
issue date. At that time, we will send copies of this report to
interested congressional committees. We also will send copies of this
report to the Secretary of Defense; the Under Secretary of Defense for
Acquisition, Technology, and Logistics; the Under Secretary of Defense
Comptroller; the Director of the Defense Finance and Accounting
Service; and the Director of the Office of Management and Budget. We
will make copies available to others upon request, and the report will
also be available on GAO‘s home page at [hyperlink,
http://www.gao.gov].
If you have any questions regarding this report, please contact me at
(202) 512-9505 or David Childress at (202) 512-4639. Key contributors
to this report are Jean Lee, Harold Reich, Alan Steiner, and Gary
Wiggins.
Sincerely yours,
Signed by:
Gregory D. Kutz:
Director, Financial Management and Assurance:
[End of section]
Appendix I: Scope and Methodology:
To determine the number and value of overpayments and underpayments in
selected DOD contractors‘ records at end of fiscal year 2001, we
surveyed 183 DOD contractors. Appendix II has a complete list of these
contractors. We identified the top 100 DOD contractors and the top 100
small business DOD contractors based on total dollar value of fiscal
year 2000 contract actions recorded in the Federal Procurement Data
System (FPDS). After identifying the contractors, we used DOD‘s Central
Contract Registry (CCR) to identify contractor business units, their
addresses, and points of contact. Contractors must be in CCR to receive
payments, and contractors are responsible for maintaining the data in
the registry. About 54 percent of the large DOD contractors had
multiple business units. For example, Lockheed Martin, Raytheon, and
Boeing had 114, 100, and 61 business units, respectively. Accordingly,
we contacted officials at many of the contractors for help identifying
the appropriate addresses to which the questionnaires should be sent so
that the appropriate finance units would receive them. The appropriate
finance units for our survey were those that handle the billings and
maintain accounts receivables; some business units for which we had
addresses do not maintain these records. We did not send surveys to all
of the 200 contractors as listed in FPDS because 1 of them was
classified, 7 of the small businesses were also included in the top 100
contractors, 3 contractors‘ names could not be matched to those in CCR,
and 5 contractors listed in FPDS had merged with other contractors”for
example, Boeing had merged with McDonnell Douglas”or were business
units of major contractors already listed.
We subsequently mailed 497 surveys to business units of 183 DOD
contractors requesting the total overpayments and underpayments in their
records as of September 30, 2001, [Footnote 24] and specific detail on
individual overpayments and underpayments equal to or over $1,000. The
survey is similar to the one we used in our 1995 report. [Footnote 25]
A copy of our final survey is in appendix III. We either telephoned or
sent follow-up reminders to business units. In response to our mailings
and follow-up, we received 249 survey responses from business units of
58 large contractors and 62 small business contractors. However, some
of the responses we received did not include all of the business units
from the contractor, and others indicated that another business unit
would have the information. Twenty-two mailings were returned as
undeliverable. The 249 business units that responded to our survey
reported on overpayments and underpayments associated with over 600
contracts. The findings from our survey apply only to the contractor
business units that responded and cannot be projected to any others.
We coordinated with DCAA, as part of its ongoing recovery audits, for
its auditors to test the validity of the contractors‘ responses on 27
business units in our survey. These units reported about $58 million,
or 94 percent, of the total reported overpayments, and about $126
million, or 71 percent, of the total reported underpayments. We and
DCAA selected the business units to visit based on a combination of
factors, including geographic location, size of the contractor, the
amount of reported payment discrepancies, and the nonreporting of
payment discrepancies with significant annual billings. We also visited
DCAA offices to discuss the agency‘s audit results in verifying
overpayments and underpayments reported for 9 of the 27 contractor
locations.
To determine the status of DOD corrective actions, we obtained and
reviewed fiscal year 2000 and 2001 data collected by DFAS Columbus on
contractor refunds, offsets, and reasons for the refunds. In addition,
we obtained data on the number of contracts in reconciliation at the
end of fiscal year 2001, the number of contracts that had been
partially or completely reconciled in fiscal years 2000 and 2001, and
the reasons for payment problems that DFAS Columbus had identified
during reconciliation. We did not verify the data provided.
We also obtained and evaluated fiscal year 2001 accounts receivable
balances, which represented demand letters issued by DFAS Columbus. To
identify some of the conditions and reasons for overpayments, we
selected 58 of the highest dollar transactions from the 3 months in
fiscal year 2001 with the highest balances for accounts receivable
cancellations, transfers, collections made through offsets, and
unsolicited refunds. The transactions selected represented about 80
percent of the total dollar value of the group for that month. In
addition, we obtained a detailed list of all accounts receivable over
90 days old as of August 2001 and reviewed the highest dollar value
transaction in each year from 1996 through 2001. To further assess the
timeliness of collections, we analyzed data in DFAS Columbus records on
refunds due to payments errors and attempted to determine the
collection time for 15 contract administration action refunds in fiscal
year 2001.
Further, we obtained information on performance measures, certain DFAS
Columbus procedural changes, and the planned implementation of DPPS. We
also discussed payment problems and corrective actions with DFAS
Columbus and DCMA officials. We reviewed prior GAO and DOD IG reports
on contract payment problems, applicable laws and FAR sections, federal
accounting standards and financial system requirements, the DOD
Financial Management Regulation, DCMA policies and procedures contained
in its ’One Book,“ and DFAS Columbus procedures regarding accounts
receivable, contractor refunds, and contract reconciliation.
We requested comments on a draft of this report from the Secretary of
Defense or his designee. We received comments from the Under Secretary
of Defense Comptroller and have reprinted these comments in appendix V.
We conducted our review from August 2001 through April 2002 in
accordance with U.S. generally accepted government auditing standards.
[End of section]
Appendix II: List of Contractors We Surveyed and Results:
Contractor names and fiscal year 2000 contract actions are from the
Federal Procurement Data System. Dollars of overpayments and
underpayments are from survey responses received before February 2002.
Contractor name: Lockheed Martin Corp.
Dollars of overpayments: $9,424,034;
Dollars of underpayments: $24,070,485;
Fiscal year 2000 contract actions (dollars in thousands): $15,592,665.
Contractor name: Boeing - McDonnell Douglas;
Dollars of overpayments: $32,738,149;
Dollars of underpayments: $65,981,813;
Fiscal year 2000 contract actions (dollars in thousands): $12,261,227.
Contractor name: Raytheon Company;
Dollars of overpayments: $2,304,572;
Dollars of underpayments: $3,767,230;
Fiscal year 2000 contract actions (dollars in thousands): $6,120,469.
Contractor name: Bath Iron Works Corp.
Dollars of overpayments: $1,214,695;
Dollars of underpayments: $330,520;
Fiscal year 2000 contract actions (dollars in thousands): $4,164,569.
Contractor name: Northrop Grumman Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $2,944,473.
Contractor name: Ingalls Shipbuilding, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $2,745,694.
Contractor name: Pratt & Whitney;
Dollars of overpayments: $74,357;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $2,022,865.
Contractor name: TRW, Inc.
Dollars of overpayments: $70,794;
Dollars of underpayments: $23,514,753;
Fiscal year 2000 contract actions (dollars in thousands): $2,010,996.
Contractor name: General Electric Company;
Dollars of overpayments: $5,356;
Dollars of underpayments: $77,578;
Fiscal year 2000 contract actions (dollars in thousands): $1,599,304.
Contractor name: SAIC Information Services;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $1,540,529.
Contractor name: United Defense, L.P.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $1,203,056.
Contractor name: Computer Sciences Corp.
Dollars of overpayments: $84,728;
Dollars of underpayments: $1,841,404;
Fiscal year 2000 contract actions (dollars in thousands): $1,173,953.
Contractor name: Bell Helicopter Textron, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $1,156,910.
Contractor name: BAE Systems Technical Services
Dollars of overpayments: $55,142;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $967,891.
Contractor name: Honeywell International, Inc.
Dollars of overpayments: $1,522,194;
Dollars of underpayments: $8,394,462;
Fiscal year 2000 contract actions (dollars in thousands): $908,509.
Contractor name: Dyncorp;
Dollars of overpayments: $427,612;
Dollars of underpayments: $200,801;
Fiscal year 2000 contract actions (dollars in thousands): $762,608.
Contractor name: Newport News Shipbuilding & Drydock;
Dollars of overpayments: $6,924,277;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $741,523.
Contractor name: Bechtel National, Inc.
Dollars of overpayments: $179,558;
Dollars of underpayments: $158,218;
Fiscal year 2000 contract actions (dollars in thousands): $735,434.
Contractor name: Canadian Commercial Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $659,145.
Contractor name: Westinghouse Electric Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $619,694.
Contractor name: Raytheon Engineers & Construction;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $598,725.
Contractor name: Rockwell Collins, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $593,550.
Contractor name: Brown & Root Services;
Dollars of overpayments: $53,553;
Dollars of underpayments: $6,649;
Fiscal year 2000 contract actions (dollars in thousands): $590,689.
Contractor name: Atlantic Richfield Company, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $558,129.
Contractor name: ITT Federal Services Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $556,422.
Contractor name: Foundation Health Federal Services;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $550,668.
Contractor name: Beneco Enterprises, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $499,464.
Contractor name: Alliant Techsystems;
Dollars of overpayments: $2,620,865;
Dollars of underpayments: $528,680;
Fiscal year 2000 contract actions (dollars in thousands): $462,132.
Contractor name: Federal Express Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $452,513.
Contractor name: Expresser Transport Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $332,423;
Fiscal year 2000 contract actions (dollars in thousands): $426,798.
Contractor name: Stewart & Stevenson Services;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $424,053.
Contractor name: Booz Allen & Hamilton, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $421,237.
Contractor name: Federal Ministry
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $410,555.
Contractor name: The Mitre Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $409,221.
Contractor name: Sverdrup Technology, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $395,160.
Contractor name: Motorola, Inc.[A];
Dollars of overpayments: $451,374;
Dollars of underpayments: $2,222,106;
Fiscal year 2000 contract actions (dollars in thousands): $392,952.
Contractor name: Interstate Electronics Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $373,024.
Contractor name: Oshkosh Truck Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $1,184,999;
Fiscal year 2000 contract actions (dollars in thousands): $372,916.
Contractor name: Alascom, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $358,116.
Contractor name: Massachusetts Institute of Technology;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $347,248.
Contractor name: Triwest Healthcare Alliance Co.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $334,342.
Contractor name: The Aerospace Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $334,194.
Contractor name: AM General Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $142,216;
Fiscal year 2000 contract actions (dollars in thousands): $332,383.
Contractor name: J.A. Jones Construction Co.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $331,725.
Contractor name: Electronic Data Systems Corp.
Dollars of overpayments: $1,280;
Dollars of underpayments: $9,969,770;
Fiscal year 2000 contract actions (dollars in thousands): $329,391.
Contractor name: Mobil Oil Corp.[B];
Dollars of overpayments: $0;
Dollars of underpayments: $0 ;
Fiscal year 2000 contract actions (dollars in thousands): $324,772.
Contractor name: Sencom Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $321,788.
Contractor name: Johns Hopkins University;
Dollars of overpayments: $11,252;
Dollars of underpayments: $5,389,410;
Fiscal year 2000 contract actions (dollars in thousands): $321,317.
Contractor name: Hughes Arabia Limited;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $308,876.
Contractor name: Dell Marketing, L.P.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $299,981.
Contractor name: GTSI
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $299,249.
Contractor name: Vector Data Systems, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $286,019.
Contractor name: Norfolk Shipbuilding & Drydock;
Dollars of overpayments: $1,216,004;
Dollars of underpayments: $202,782;
Fiscal year 2000 contract actions (dollars in thousands): $277,618.
Contractor name: Arinc, Incorporated;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $272,468.
Contractor name: Harris Corp.
Dollars of overpayments: $123,614;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $267,232.
Contractor name: Equilon Enterprises, LLC;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $265,600.
Contractor name: Texas Instruments, Inc.
Dollars of overpayments: $2,843;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $244,741.
Contractor name: WTAK-3, Inc.[C];
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $241,912.
Contractor name: Systems & Electronics, Inc.
Dollars of overpayments: $746,438;
Dollars of underpayments: $1,135,482;
Fiscal year 2000 contract actions (dollars in thousands): $237,113.
Contractor name: Coastal Aruba Refining Company[C];
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $231,784.
Contractor name: The Procter Gamble Distributing Co.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $228,437.
Contractor name: CACI, Inc.- Federal;
Dollars of overpayments: $264,145;
Dollars of underpayments: $583,686;
Fiscal year 2000 contract actions (dollars in thousands): $220,547.
Contractor name: Bergen Brunswig Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $217,183.
Contractor name: Anthem Alliance Health Insurance[B];
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $215,299.
Contractor name: Johnson Controls World Service;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $214,447.
Contractor name: Mantech International Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $211,471.
Contractor name: B.F. Goodrich Aerospace;
Dollars of overpayments: $0;
Dollars of underpayments: $282,274;
Fiscal year 2000 contract actions (dollars in thousands): $204,447.
Contractor name: Parsons Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $204,262.
Contractor name: Bindley Western Industries;
Dollars of overpayments: $49,411;
Dollars of underpayments: $11,710,683;
Fiscal year 2000 contract actions (dollars in thousands): $204,040.
Contractor name: Rolls-Royce, PLC;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $196,478.
Contractor name: Foster Wheeler Environmental;
Dollars of overpayments: $203,750;
Dollars of underpayments: $1,874,331;
Fiscal year 2000 contract actions (dollars in thousands): $185,755.
Contractor name: Cubic Defense Systems, Inc.
Dollars of overpayments: $22,421;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $184,474.
Contractor name: Resource Consultants, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $182,720.
Contractor name: Emery Air Freight Corp.
Dollars of overpayments: $17,855;
Dollars of underpayments: $292,236;
Fiscal year 2000 contract actions (dollars in thousands): $165,119.
Contractor name: Unisys Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $163,238.
Contractor name: Battelle Memorial Institute;
Dollars of overpayments: $83,894;
Dollars of underpayments: $46,296;
Fiscal year 2000 contract actions (dollars in thousands): $162,749.
Contractor name: Chugach Management Services;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $162,692.
Contractor name: Great Lakes Dredge & Dock;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $150,300.
Contractor name: Kraft Foods, Inc.
Dollars of overpayments: $20,914;
Dollars of underpayments: $134,441;
Fiscal year 2000 contract actions (dollars in thousands): $149,545.
Contractor name: AAI/ACL Technologies, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $149,537.
Contractor name: Motor Oil (Hellas) Corinth;
Dollars of overpayments: $0;
Dollars of underpayments: $636,200;
Fiscal year 2000 contract actions (dollars in thousands): $148,432.
Contractor name: Metro Machine Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $147,301.
Contractor name: Lucent Technologies, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $143,019.
Contractor name: Hunt Building Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $1,023,459;
Fiscal year 2000 contract actions (dollars in thousands): $140,314.
Contractor name: General Atomics Aeronautical;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $134,234.
Contractor name: Sierra Health Services, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $134,022.
Contractor name: EG&G Technical Services, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $130,811.
Contractor name: Conoco, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $130,735.
Contractor name: Humana Military Healthcare;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $129,163.
Contractor name: CH2M Hill Companies, Ltd.
Dollars of overpayments: $24,368;
Dollars of underpayments: $1,500,973;
Fiscal year 2000 contract actions (dollars in thousands): $127,505.
Contractor name: Rand Corp.
Dollars of overpayments: $516,231;
Dollars of underpayments: $3,763;
Fiscal year 2000 contract actions (dollars in thousands): $127,079.
Contractor name: Bell Atlantic Network Services;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $126,906.
Contractor name: Navajo Refining Company;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $121,075.
Contractor name: Spectrum Astro, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $111,579.
Contractor name: Oracle Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $91,294.
Contractor name: M.S. Aerospace;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $90,220.
Contractor name: Ameriqual Group, LLC;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $89,682.
Contractor name: Digital System Resources, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $163,000;
Fiscal year 2000 contract actions (dollars in thousands): $87,939.
Contractor name: Paramount Petroleum Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $82,708.
Contractor name: Bay Ship Management Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $77,957.
Contractor name: Mantech International Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $77,744.
Contractor name: Ocean Triumph Shipping, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $58,156;
Fiscal year 2000 contract actions (dollars in thousands): $76,347.
Contractor name: EER Systems, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $73,770.
Contractor name: Todd Pacific Shipyards Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $72,599.
Contractor name: Mevatec Corp.
Dollars of overpayments: $13,712;
Dollars of underpayments: $212,212;
Fiscal year 2000 contract actions (dollars in thousands): $72,147.
Contractor name: Petro Star Valdez, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $6,403;
Fiscal year 2000 contract actions (dollars in thousands): $64,050.
Contractor name: Sparta, Inc.
Dollars of overpayments: $3,671;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $63,027.
Contractor name: Earl Industries, LLC;
Dollars of overpayments: $18,115;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $62,942.
Contractor name: RQ Construction, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $252,161;
Fiscal year 2000 contract actions (dollars in thousands): $61,114.
Contractor name: Dynetics, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $6,828;
Fiscal year 2000 contract actions (dollars in thousands): $58,620.
Contractor name: Sealift Holdings, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $56,972.
Contractor name: Gary-Williams Energy Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $56,528.
Contractor name: Colsa Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $56,295.
Contractor name: Environmental Chemical Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $1,434,416;
Fiscal year 2000 contract actions (dollars in thousands): $54,578.
Contractor name: Viasat, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $54,002.
Contractor name: Premier Technology Group, Inc.
Dollars of overpayments: $69,731;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $53,987.
Contractor name: American Renovation & Construction
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $53,710.
Contractor name: Scientific Research Corp.
Dollars of overpayments: $29,356;
Dollars of underpayments: $354,671;
Fiscal year 2000 contract actions (dollars in thousands): $53,248.
Contractor name: Storage Area Networks, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $52,439.
Contractor name: Nan, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $1,342,934;
Fiscal year 2000 contract actions (dollars in thousands): $52,342.
Contractor name: Bender Shipbuilding & Repair;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $52,296.
Contractor name: Bioport Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $51,550.
Contractor name: Signal Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $51,266.
Contractor name: Federal Data Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $50,839.
Contractor name: NLX Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $409,241;
Fiscal year 2000 contract actions (dollars in thousands): $50,416.
Contractor name: Spectral Systems, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $49,761.
Contractor name: The Wornick Company;
Dollars of overpayments: $0;
Dollars of underpayments: $53,760;
Fiscal year 2000 contract actions (dollars in thousands): $49,648.
Contractor name: Applied Research Associates;
Dollars of overpayments: $0;
Dollars of underpayments: $325,673;
Fiscal year 2000 contract actions (dollars in thousands): $48,428.
Contractor name: CAS, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $248,645;
Fiscal year 2000 contract actions (dollars in thousands): $48,398.
Contractor name: Placid Refining Company, LLC;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $47,004.
Contractor name: Sytex, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $45,745.
Contractor name: Sabreliner Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $45,125.
Contractor name: N.E.T. Federal, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $44,838.
Contractor name: Point Blank Body Armor, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $43,982.
Contractor name: Sharp, George G, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $43,464.
Contractor name: DJ Manufacturing Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $41,873.
Contractor name: Jaycor, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $41,002.
Contractor name: Ages Group, LTD Partnership;
Dollars of overpayments: $200,459;
Dollars of underpayments: $733,264;
Fiscal year 2000 contract actions (dollars in thousands): $40,785.
Contractor name: Sundt/Ninteman, Joint Venture;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $40,721.
Contractor name: KDI Precision Products, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $40,594.
Contractor name: Landmark Construction Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $39,070.
Contractor name: Fibertek, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $38,928.
Contractor name: World Wide Technology;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $38,423.
Contractor name: Evans & Sutherland Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $38,237.
Contractor name: Mission Research Corp.
Dollars of overpayments: $7,878;
Dollars of underpayments: $150,957;
Fiscal year 2000 contract actions (dollars in thousands): $37,891.
Contractor name: U.S. Oil & Refining Co.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $37,729.
Contractor name: Assurance Technology Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $37,411.
Contractor name: Tybrin Corp.
Dollars of overpayments: $0
Dollars of underpayments: $9,011
Fiscal year 2000 contract actions (dollars in thousands): $36,823.
Contractor name: Griffin Services, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $36,370.
Contractor name: Sierratech, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $35,565.
Contractor name: Sevenson Environmental Service;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $35,538.
Contractor name: O.K. James Construction, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $34,276.
Contractor name: Baltimore Marine Industries;
Dollars of overpayments: $0;
Dollars of underpayments: $270,008;
Fiscal year 2000 contract actions (dollars in thousands): $33,910.
Contractor name: McBride and Associates, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $33,901.
Contractor name: Logistic Services International;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $33,798.
Contractor name: American Mechanical, Inc.[C]
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $33,791.
Contractor name: Pride Companies, LP;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $33,355.
Contractor name: Cormorant Shipholding Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $11,544;
Fiscal year 2000 contract actions (dollars in thousands): $33,156.
Contractor name: Dataline, Inc.
Dollars of overpayments: $22,375;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $31,548.
Contractor name: Golden Manufacturing, Inc.
Dollars of overpayments: $12,293;
Dollars of underpayments: $11,880;
Fiscal year 2000 contract actions (dollars in thousands): $31,391.
Contractor name: Specialty Plastic Products;
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $31,385.
Contractor name: Science & Engineering Associates;
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $31,275.
Contractor name: S.W. Day Construction Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $31,012.
Contractor name: Premco Holdings, Inc.[C]
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $30,905.
Contractor name: Space Mark, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $89,000;
Fiscal year 2000 contract actions (dollars in thousands): $29,874.
Contractor name: Condor Systems, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $2,250;
Fiscal year 2000 contract actions (dollars in thousands): $29,830.
Contractor name: Nichols Research Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $29,750.
Contractor name: Petroleum Traders Corp.
Dollars of overpayments: $2,333;
Dollars of underpayments: $1,880;
Fiscal year 2000 contract actions (dollars in thousands): $29,391.
Contractor name: Sy Technology, Inc.
Dollars of overpayments: $155,756;
Dollars of underpayments: $641,422;
Fiscal year 2000 contract actions (dollars in thousands): $29,247.
Contractor name: J.F. Taylor, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $28,728.
Contractor name: Soza & Company, Ltd.
Dollars of overpayments: $0;
Dollars of underpayments: $1,650,253;
Fiscal year 2000 contract actions (dollars in thousands): $28,224.
Contractor name: DME Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $28,066.
Contractor name: Bulova Technologies, LLC;
Dollars of overpayments: $0;
Dollars of underpayments: $106,941;
Fiscal year 2000 contract actions (dollars in thousands): $27,913.
Contractor name: Engineering Research & Consulting
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $27,511.
Contractor name: E-OIR Measurements, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $27,418.
Contractor name: Butt Construction Company, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $27,166.
Contractor name: Akima Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $26,904.
Contractor name: Martin Electronics, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $2,306;
Fiscal year 2000 contract actions (dollars in thousands): $26,711.
Contractor name: Bradley Broadcast Sales, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $26,469.
Contractor name: Manufacturing Technology, Inc.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $26,312.
Contractor name: Sechan Electronics, Inc.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $26,305.
Contractor name: SMF Systems Corp.
Dollars of overpayments: $0;
Dollars of underpayments: $0;
Fiscal year 2000 contract actions (dollars in thousands): $26,280.
Contractor name: Camber Corp.
Dollars of overpayments: No response;
Dollars of underpayments: [Empty];
Fiscal year 2000 contract actions (dollars in thousands): $26,243.
Total:
Dollars of overpayments: $61,991,268;
Dollars of underpayments: $176,088,939.
[A] Units that reported these amounts are now General Dynamics Decision
Systems, Inc.
[B] Responses indicated that these companies no longer have DOD
contracts.
[C] Surveys were returned due to invalid addresses.
[End of table]
[End of section]
Appendix III: Contractor Survey:
Reporting Format For Information Requested By The U.S. General
Accounting Office:
The Chairman of the House Committee on Government Reform has asked the
U.S. General Accounting Office (GAO) to obtain data from contractors on
the extent of overpayments (any dollars owed) and underpayments
(dollars owed to you) outstanding on contracts with the Department of
Defense (DOD). This data will be used as part of an ongoing assignment
(GAO code 192036) to update the status of DOD‘s contract overpayments
and underpayments and to determine what progress has been made from
prior reports. Please follow the attached instructions when accumulating
the requested information and return it in the enclosed envelope by
October 26, 2001. If you do not have any overpayments or underpayments,
we would still appreciate you returning this survey indicating that you
have not identified any such payments. Please return your completed
survey and schedules by mail, fax or obtain a survey by email:
Mr. Harold D. Reich:
U.S. General Accounting Office:
Los Angeles World Trade Center:
350 South Figueroa Street, Suite 1010:
Los Angeles, CA 90071:
Or Fax to:
Harold D. Reich:
(213) 830-1180:
Or Get Email format from: (reichh@gao.gov):
Any questions should be directed to Harold Reich at (213) 830-1078
(reichh@gao.gov) or Eric Johns at (213) 830-1154 (johnse@gao.gov) in
our Los Angeles Field Office or Al Steiner in our Washington, D.C.
office at (202) 512-9332 (steinera@gao.gov).
I. General Information:
1. We are requesting information on the single business unit at the
address listed below, unless you find an Attachment 3 in your survey.
If you have an Attachment 3 your response should be an aggregate
response for all listed and confirmed business units, or any units you
might add, for which you handle accounts receivable and payable.
(Please make any corrections to address in this space)
2. Please provide the name and telephone number of a contact in the
accounting and financial unit for us to contact if additional
information is needed:
Name Of Contact:
Email Address:
Phone Number:
3. If your business unit is a subsidiary of a parent company, please
list the name, DUNS number, and address of the parent business.
Parent Company:
DUNS:
Business Address:
4. Does your business unit prepare contract billings and maintain
accounts receivable for contracts with the DOD?
[Note: If we have called you to make other arrangements, please proceed
directly to question 5 as we already have the information for this
question.]
Yes: (Go To Question 5)
No: (Read Instruction In Box Below.)
[Stop – If you answered ’No“ to question 4 above, please do not
continue but return this request in the enclosed envelope after
supplying the information requested in this box. Please do not forward
to the business unit that does your billings and maintains your
accounts receivable. Instead, please provide the name and address for
the business unit that maintains your accounts receivables so we can
verify that the unit has been included in the initial mailing of this
data request.
List below the name and address of the business unit that maintains
your accounts receivable:
Name:
Address:
Contact Person:
Phone:]
II. Contract Information:
5. From your accounts receivable and payable ledgers, or other
appropriate accounting record, provide total gross dollar amounts of
existing overpayments and underpayments (billed amounts versus payments
received) for all DOD contracts as of September 30, 2001 (or if
September 30 is impracticable, please specify the "as of" date you have
used). Overpayments should exclude advance payments. The total
underpayments extracted should exclude 1) billings less than 30-days
old on the "as of" date for the information provided (this excludes
billings for which payments are not delinquent), and 2) claims,
accounts under dispute, and unbilled receivables on long-term
contracts. However, we expect overpayments or underpayments caused by
incorrect liquidation of progress payments to be included in the
summary totals provided in response to this question.
Gross Overpayment Dollar Amount:
Gross Underpayment Dollar Amount:
As of date used:
6. For each overpayment exceeding $1,000, please provide the following
information on the Schedule for Contract Overpayments (Attachment I):
contract number, the amount of the overpayment, the date the
overpayment was identified: action you have taken (i.e., notified DCMA
and/or DFAS, adjustments by check, offset, or no action); indicate
whether you received a demand letter for the overpayment, and the
potential cause for each payment. If you are unable to provide this
detail contract information, please briefly explain why it is not
available:
7. For each underpayment exceeding $1,000, please provide the following
information on the Schedule For Contract Underpayments (Attachment II):
contract number, the amount of underpayment, the date the underpayment
was identified; notification and the action you have taken; and the
potential cause for the underpayment. If you are unable to provide this
detail contract information, please briefly explain why it is not
available:
8. List the most recent annual dollar amount of gross contract billings
to DOD by this business unit.
Year Ending:
Gross Dollar Amount Of Billings To DOD:
9. Please include any additional information or specific comments and
issues concerning your DOD contract payment experiences that you
believe we should consider.
Please retain any work sheets or records used to prepare this response.
Thank you for your prompt response.
Enclosure 2:
Instruction Sheet For Completing Information Request:
I. General Information:
The information requested regarding the business unit reporting is
intended to identify the unit providing the information. Please make
any appropriate changes to the name and address of your business unit
(Question 1). Please provide the name, telephone number, and email
address of a contact person (Q2) who could best respond to our
technical questions about the information you provide. Also identify
the parent company of this business unit (Q3) providing the name, DUNS
number, and mailing address.
II. Contract Information:
Q4. The accounting and finance unit that maintains the accounts
receivable and related billing accounts for contracts with DOD should
respond to this data request. We intended to send this data request to
the business units that are listed in the CCR and could maintain
accounts receivable and billing records. If your unit does not maintain
these records, please provide the name, address of the business unit
and a contact with phone number who maintains your accounts receivable
for DOD contracts, but do not forward this request to that unit.
Q5. From your accounts payable and receivable ledgers or other
appropriate accounts that include information by individual billing
numbers (invoices and vouchers), please provide the total gross dollar
amounts of overpayments and underpayments (including unpaid bills) for
all DOD contracts billed directly to the government as of September 30,
2001. If the information is not available as of this date, provide the
information for a date as close as practicable and specify the date
used. The total underpayments extracted should exclude billings less
than 30-days old on the "as of" date for the information provided (this
excludes billings for which payments are not delinquent). Please ensure
that you do not consider (1) advance payments as overpayments and (2)
claims, amounts under dispute, and unbilled receivables on long-term
contracts as underpayments.
The amounts listed in response to question 5 should provide a point-in-
time measurement of total underpayments and overpayments as shown by
contractor records and include the effects of incorrectly liquidated
progress payments. We recognize that the payment status for DOD
contracts will change after the "as of" date.
Q6. Following the instructions below, please complete the Schedule for
Contract Overpayments (Attachment I).
Column: a, b, c;
Instructions: Enter the contract number, amount of the overpayment, and
date on which the overpayment was identified. Provide this information
for individual contract overpayments exceeding $1,000. Do not include
advance payments. Round dollar amounts to the nearest dollar.
Column: d, e;
Instructions: If you have notified DOD of the overpayment, specify
which DCMA and/or DFAS office you contacted and the date you notified
them.
Column: f, g, h;
Instructions: Check if you have made payment by check, made plans to
offset against another payment, or if no action has been taken.
Column: i, j;
Instructions: If a demand letter was received from DOD for the
overpayment, please indicate the date of the letter and which DCMA or
DFAS office sent it.
Column: k;
Instructions: For the potential cause, please provide a brief
description”i.e., contract modification-scope change, contract
modification-price adjustment, contract modification-other, duplicate
payment, recording error, etc.
Q7.Following the instructions below, please complete the Schedule for
Contract Underpayments (Attachment II).
Column: a, b, c;
Instructions: Enter the information indicated for individual contract
underpayments exceeding $1,000. Round dollar amounts to the nearest
dollar.
Column: d, e, f;
Instructions: If you have notified DOD of the underpayments, specify
which DCMA and/or DFAS office you contacted and the date you notified
them. Or if no action taken, check column f.
Column: g;
Instructions: For the potential cause, please provide a brief
description”i.e., progress payment calculation error, prices not
updated, recording error, lost inventories, contract modification not
processed, etc.
Q8. State the volume of business your business unit has with DOD as
measured by total gross billings to DOD for your most recent year
ending date. Please include the ending date (month and year) for the
total billings listed.
Attachment 3:
Business Units Handle By Your Accounts Receivable and Payable Office:
Instructions: Through review of the Central Contract Registry (CCR), or
by prior contact with your company, we have indications that your
business unit maintains the accounts receivable and payable for each of
the units listed below. Please confirm that you do maintain accounts
for each of these business units by 1) crossing out any units not
maintained, and 2) adding the name and address of any additional units
for which you maintain these accounts. Your survey response should be
an aggregate response for all the confirmed business units.
Additional Sites:
Attachment 1:
Schedule for Contract Overpayments (Exceeding $1,000):
(See Enclosure 2 for detail instructions on completing this schedule.)
Important: Please ensure that you do not consider advance payments as
overpayments.
Overpayment (Insert information): a. Contract Number:
Overpayment (Insert information): b. Amount of Overpayment (Round to
the nearest dollar):
Overpayment (Insert information): c. Date Overpayment Identified & By
Whom (Contractor or DOD):
Action Taken Or Planned: Notifying DOD (Insert information): d. DFAS or
DCMA Office Notified:
Action Taken Or Planned: Notifying DOD (Insert information): e. Date
Office Notified:
Action Taken Or Planned: Adjustments (Check one column): f. Return
Overpayment by Check: Done; Planned;
Action Taken Or Planned: Adjustments (Check one column): g. Offset
Against Another Payment; Done; Planned;
Action Taken Or Planned: h. No Action Taken;
Demand Letter (Only If Letter Received): i. Date of Demand Letter;
Demand Letter (Only If Letter Received): j. DOD Office Sending Demand
Letter;
Cause For Overpayment: k. Potential Cause (Describe briefly):
[End of attachment]
Attachment 2:
Schedule For Contract Underpayments (Exceeding $1,000):
(See Enclosure 2 for detail instructions on completing this schedule):
Important: The total underpayments extracted should exclude billings
less than 30-days old on the "as of" date for the information provided
(this excludes billings for which payments are not delinquent). Also,
do not consider claims, amounts under dispute, and unbilled receivables
on long-term contracts as underpayments.
Underpayment (Insert Information): a. Contract Number:
Underpayment (Insert Information): b. Amount of Underpayment (Round to
the nearest dollar):
Underpayment (Insert Information): c. Date Underpayment Identified & By
Whom (Contractor or DOD):
Notification (Insert Information, Or Check No Action Taken): d. DFAS or
DCMA Office Notified:
Notification (Insert Information, Or Check No Action Taken): e. Date
Office Notified:
Notification (Insert Information, Or Check No Action Taken): f. No
Action Taken:
Cause For Underpayment: g. Potential Cause (Describe briefly):
[End of attachment]
[End of section]
Appendix IV: Summary of Results from DCAA Visits to 28 Contractor
Locations:
DCAA auditors found that 17 contractor locations did not have any
differences or the differences were immaterial based on their review of
contractors‘ records and comparison to their survey responses. Shown
below are 10 contractor locations with material differences identified
by DCAA and the primary reasons for the differences. In addition, DCAA
auditors visited 1 contractor”SAIC”that did not respond to the survey,
and they found $259,194 of overpayments and $2,002,243 of underpayments
in the contractor‘s records.
Contractors”material differences from survey: Ages Group[A];
Overpayment differences: ($319,025);
Primary reasons for differences: Overbilled costs were not reported;
Underpayment differences: 0;
Primary reasons for differences: Not applicable.
Contractors”material differences from survey: Boeing – St. Louis;
Overpayment differences: 1,895;
Primary reasons for differences: Not identified;
Underpayment differences: ($997,141);
Primary reasons for differences: Unpaid invoices not reported.
Contractors”material differences from survey: Honeywell Shared
Services;
Overpayment differences: (6,946,813);
Primary reasons for differences: Unanalyzed overpayments were not
reported;
Underpayment differences: (7,672,885);
Primary reasons for differences: Unanalyzed underpayments were not
reported; unpaid invoices not reported.
Contractors”material differences from survey: Lockheed Martin Shared
Service;
Overpayment differences: (30,432,643);
Primary reasons for differences: Unanalyzed overpayments were not
reported; outstanding payment variances and contract administration
adjustments not reported;
Underpayment differences: (16,554,214);
Primary reasons for differences: Unanalyzed underpayments were not
reported.
Contractors”material differences from survey: Lockheed Martin NE & SS;
Overpayment differences: (37,833);
Primary reasons for differences: Not identified;
Underpayment differences: (876,695);
Primary reasons for differences: Unpaid invoices not reported” only
reported invoices with partial payments.
Contractors”material differences from survey: Newport News
Shipbuilding;
Overpayment differences: (12,688,525);
Primary reasons for differences: Contractor failed to report
overpayments; inappropriate accounting for labor and material transfers
Underpayment differences: (83,694);
Primary reasons for differences: Not identified.
Contractors”material differences from survey: Raytheon – El Segundo;
Overpayment differences: (4,028,327);
Primary reasons for differences: Overpayments over 1 year old were not
reported;
Underpayment differences: (22,612,605);
Primary reasons for differences: Underpayments over 1 year old were not
reported; unpaid invoices not reported”only reported invoices with
partial payments.
Contractors”material differences from survey: TRW Space & Electronics;
Overpayment differences: (75,103);
Primary reasons for differences: Not identified;
Underpayment differences: (631,577);
Primary reasons for differences: Underpayments on certain contracts
were not reported.
Contractors”material differences from survey: TRW Systems East;
Overpayment differences: 0;
Primary reasons for differences: Not applicable;
Underpayment differences: 1,574,295;
Primary reasons for differences: Erroneously reported unpaid invoices
under 30 days.
Contractors”material differences from survey: TRW Systems West;
Overpayment differences: (2,666,281);
Primary reasons for differences: Overpayments on certain contracts were
not reported; overpayments and underpayments netted for reporting
Underpayment differences: (10,386,620);
Primary reasons for differences: Underpayments on certain contracts
were not reported.
Totals:
Overpayment differences: ($57,185,791).
Underpayment differences: ($58,040,558).
[End of section]
Appendix V: Comments from the Department of Defense:
Under Secretary Of Defense:
Comptroller:
1100 Defense Pentagon:
Washington, DC 20301-1100:
MAY 23, 2002:
Mr. Gregory Kutz:
Director Financial Management and Assurance:
U.S. General Accounting Office:
Washington, DC 20548:
Dear Mr. Kutz:
This is the Department of Defense (DoD) response to the General
Accounting Office (GAO) draft report GAO-02-635, "DoD Contract
Management: Overpayments Continue and Management and Accounting Issues
Remain," dated April 19, 2002.
As indicated in your draft report, the Department has taken positive
steps to address contract overpayments. The DFAS consolidated the
management of contract and vendor pay operations and we have improved
payment process controls and employed data mining to identify erroneous
payments for recovery. New payment system edits have reduced duplicate
payments from 94 in the first 6 months of fiscal year (FY) 2001 to 23
in the first 6 months of FY 2002 and we have improved system controls
over progress payment liquidation rates.
The accounts receivable module in the Mechanization of Contract
Administration System is being modified to improve timeliness in
collecting amounts due, and the DFAS revised its debt management
procedures, with over 2,000 cases transferred to the Department of the
Treasury for collection since May 2001. In addition, my office is
developing performance indicators for senior DoD management that target
accounts receivable, overpayments, and aging.
Defense Contract Audit Agency resources are in use to detect
overpayments and promote improved contractor policies and billing
system internal controls. As you noted, DCAA audits have identified
over $50 million in overpayments, most of which were promptly resolved.
Responses to the draft report recommendations and other technical
comments are in the enclosure. The Department appreciates the
opportunity to comment on this draft report. My staff point of contact
on this matter is Mr. Chuck Crichley. He may be reached by e-mail:
crichlec@osd.pentagon.mil or by telephone at (703) 602-0369.
Sincerely,
Signed by:
Dov S. Zakheim:
Enclosure:
Office Of The Under Secretary Of Defense (Comptroller):
Draft Audit Report, "Contract Management: Overpayments Continue and
Management and Accounting Issues Remain" (GAO Code 192036):
Comments On The Recommendations:
Recommendation: Implement an internal control, as required by 31 U.S.C.
3561, to identify and collect overpayments to contractors, regardless
of contract payment type.
DoD Response: Concur. The Department of Defense endorses the
requirement for a program to identify errors made in paying contractors
and recover any amounts paid to those contractors. In fact, the
Department was taking a number of actions to implement such a program
even before the enactment of 31 U.S.C. 3561. In addition to the conduct
of pilot recovery audit programs using private contractors, the
Department is using internal resources to detect overpayments,
determine systemic causes, and take appropriate corrective actions.
These actions are reducing the number of erroneous payments and
hastening collections.
The Defense Finance and Accounting Service (DFAS) has improved its
entitlement and payment process controls to isolate potential improper
payments and successfully is using data mining to identify erroneous
payments for recovery. This work has resulted in the implementation of
new payment system edits to minimize future erroneous payments.
Automated internal control processes to identify potential duplicate
payments recently were added to the Mechanization of Contract
Administration System (MOCAS). As a result, duplicate payments detected
were reduced from 94 in the first 6 months of fiscal year 2001 to 20 in
the first 6 months of fiscal year 2002. Two additional changes that
help eliminate duplicate payments now are in process. First, a new
system query has been developed to ensure that progress payment
liquidation rates in two MOCAS modules are consistent. The new
procedure will help reduce progress payment liquidation differences
that the General Accounting Office reported were the primary cause of
over and underpayments. A second system query is being used to identify
contracts that require special payment instructions. New contracts are
being screened as received. Deficiency notices are being sent to
contracting officers to ensure corrective action. In the vendor pay
network, new software is being used to detect and prevent duplicate
payments. In the area of debt collection, the DFAS instituted new debt
management procedures and transferred over 2,000 cases to the
Department of the Treasury for collection.
Further, the Department is making better use of its contract audit
resources to detect overpayments and promote improved contractor
policies and billing system internal controls. The Defense Contract
Audit Agency (DCAA) has modified its practices to test the
effectiveness of contractors' billing system internal controls in the
areas of overpayments and refunds to the government.
Upon issuance, the Department will comply with Office of Management and
Budget guidance on the conduct of a cost-effective program to identify
errors made in paying contractors.
Recommendation: Reevaluate DCMA, DoD Comptroller, and DFAS established
procedures and controls and revise them as needed to ensure prompt
recognition and recording of receivables and potential liabilities
stemming from DoD's contract management and payment processes,
according to federal accounting standards and financial management
system requirements.
DoD Response: Concur. The Department's financial management guidance on
recording accounts receivable, accounts payable, and account aging is
consistent with the federal accounting standards. The issue is
compliance with established policy. In deciding what steps may be
necessary to improve compliance, it is necessary to consider the
processes in place, factors that establish claims or obligations, and
the need to manage in efficient and cost-effective ways. For example,
contractor billing rate adjustments do not result in contract
modifications and normally are resolved within the normal billing
cycle; the Federal Acquisition Regulation "Allowable Cost and Payment"
clause allows contractors up to 120 days after the settlement of
indirect cost rates to submit a completion voucher; and refunds from
contractors include routine amounts of penalties and interest,
government property rental payments and sales proceeds. The recording
of receivables and payables becomes an issue when such transactions are
not resolved timely and aged, as indicated in the draft report.
The DFAS revised its debt management procedures and is transferring
more debts for collection. Over 2,000 cases have been transferred to
the Department of the Treasury for collection since May 2001. The DFAS
is further reviewing and revising its procedures in this area. A manual
payment procedure implemented in October 2000 is preventing future
duplicate payments like the January 2000 duplicate payment made to
Northrup Grumman. In April 2002, a new procedure was implemented to
expedite the transfer of overdue receivables to the Debt Management
Office for collection. Finally, in January 2002, new procedures were
issued that address recording, reporting and reconciling receivables
from the public.
This office is developing new performance indicators for accounts
receivable, overpayments, and aging. These measures will assure better
management visibility of performance and help identify any further
actions needed.
Recommendation: Develop and maintain more comprehensive and complete
records on contractor refunds and underpayments to better measure and
monitor: (1) the timeliness of all collections, including checks and
offsets, (2) the resolution of demand letter disputes, (3) the causes
of overpayments and underpayments, (4) the resolution of over and
underpayments and the need for corrective actions, and (5) compliance
with policies and procedures.
DoD Response: Concur. The MOCAS accounts receivable module currently
lacks the ability to capture the accrual date of a debt, but that
module will be modified to measure timeliness in the collection of
amounts due. Underpayments, when validated, are paid immediately. The
DFAS monitors the number of disputes and is working to reduce the
backlog and keep it small. Contractor cooperation and Defense Contract
Audit Agency assistance are contributing to the reductions. The DFAS
Contract Pay Operations, Customer Service, and Contract Reconciliation
functions detect over and underpayments. Root cause statistics are
collected and recorded for two of the three functions. The DFAS
Columbus site (DFAS-CO) will study the feasibility of using error codes
in Contract Pay Operations and make a decision by September 30, 2002.
Full compliance with all procedures is expected, and procedures are
reviewed and updated continuously.
Technical Comments:
Page 3, Middle Paragraph, et al. The second sentence comments that the
DCAA audits large contractors, to identify overpayments and ensure that
contractors have adequate internal controls for prompt identification
and reporting of overpayments. The report suggests that DCAA efforts
may be considered part of a recovery audit program. This is a
mischaracterization of the DCAA role as the Department's contract
auditing organization. The distinction between contract auditors and
those who perform recovery "audits" should not be confused. The purpose
of contract auditing is to assist in achieving prudent contracting by
providing procurement officials with financial information and advice
relating to the effectiveness, efficiency, and economy of contractors'
operations. In doing so, the DCAA reviews contractor records. Recovery
auditing is the practice of identifying and recovering overpayments. In
recovery auditing, the review is normally limited to an examination of
government financial and procurement records.
Page 7, Final Sentence. The sentence states that for the remaining 71
percent of the overpayments, contractors did not indicate any planned
action. The following should be added as the final sentence:
"The DCAA plans to follow up on the overpayments to ensure that all are
properly handled."
Page 9, Bottom Paragraph. The third sentence states that the DCAA did
not recover overpayments on a contract because the underpayments
exceeded them. The sentence is not technically correct, and is not
complete in its explanation. The wording should be changed to read as
follows:
"DCAA officials stated that the contract was in a net underpaid status
and the contractor has basic internal controls for overpayments. After
consulting with the DFAS, it was decided that settlement of the final
contract amount and any resulting overpayment or underpayment would be
deferred until the DFAS contract reconciliation is completed. The DCAA
is assisting the DFAS' reconciliation of the contract through the DCAA
project on audits of contractor prepared reconciliations."
Page 16, Final Sentence. The sentence states that the DCAA is working
with the DFAS-CO on reconciling contracts. The sentence should be
changed to indicate that the DCAA is performing audits of contractor
prepared reconciliations, and that the DFAS uses the results in
completing the contract closeout process.
Page 19, Middle Paragraph. The second and third sentences state that
the DCAA's preliminary conclusion is that demands for return of
contract overpayments that it reviewed, which had not been resolved for
over a year, may not be valid. The DCAA is still in the process of
examining contractor data and has not reached a conclusion on the
possible overstatement of accounts receivable. The sentences should be
revised to indicate that it is too soon to state whether the debts are
valid or DFAS-CO accounts receivable are overstated.
Page 24, Second Paragraph. The fifth sentence notes that the Defense
Contract Management Agency and the DFAS do not always issue demand
letters for contract debt based on contract administration because the
debt could be resolved promptly and issuing a demand letter would
involve additional effort. Some contract administration actions do not
result in modifications, such as auditor or contracting officer billing
rate adjustments made by mutual agreement (FAR 42.704). In this and
other instances, such as the settlement of final indirect cost rates or
noncompliance with Cost Accounting Standards, the appropriate and
expeditious method of resolution is routine offset, as provided for in
FAR 32.611. The DFAS believes that its current practice of using
offsets is in full compliance with the procurement regulation.
Page 25, Middle Paragraph:
1. The draft report correctly observes that there is no requirement for
notification of overpayment arising from contract administration
actions. This is because an amount owed by the contractor as a result
of a contract administration action does not arise from an invoice
payment by the government, and thus is not subject to the provisions
(including the overpayment notification provision) of the prompt
payment clause. If a contract administration action consists of a
change to contract requirements (e.g., delivery schedule or quantities)
the modification that revises contract requirements also will indicate
whether an equitable adjustment is due the contractor or the
government. If the government is due an equitable adjustment, a demand
letter should be issued in conjunction with the contract modification.
Because of the normal sequence of events, no purpose would be served by
requiring a contractor to provide notification of overpayment. Other
contract administration actions can result in either the contractor
owing the government money, or vice versa, and arise from the normal
and expected operation of the contract's provisions, e.g., adjustment
of the contract's provisional billing rates. Typically, any amount owed
either by the contractor or by the government as the result of a change
to billing rates, or similar contract administration action, is
resolved as part of the billing and payments process provided for under
the contract (i.e., when the contractor makes, and the government pays,
the contractor's next payment request). Consequently, the contractor's
submittal of timely, accurate payment requests in accordance with the
terms of the contract, in effect subsumes any amount due the government
which may have arisen as a result of contract administration. In these
instances, a separate requirement for notification of overpayment
arising from contract administration actions would be redundant and
potentially confusing.
2. The third sentence states that the overpayment notification
requirement (in the clauses for prompt payment) is binding only if the
contracting officer includes the clause in the contract. This sentence
gives the impression that contracting officers have the latitude to
leave the applicable prompt payment clause out of contracts. FAR 32.908
requires the inclusion of the appropriate prompt payment clause in
contracts, except when the clause at 52.212-4, "Contract Terms and
Conditions-Commercial Items," applies, or when other governmental
authority (e.g., tariffs) establishes payment terms and late payment
penalties. FAR Case 2001-005 will add the requirement for notification
of overpayments to FAR 52.212-4.
3. The fourth sentence states that the Department's efforts to reduce
progress payment liquidation problems have not been fully effective. It
goes on to say that contracting officers have not always provided
payment instructions in accordance with policy and the DFAS had not
always followed payment instructions when provided, thereby creating
the likelihood of future payment problems. This comment appears to be
misplaced since a lack of payment instructions leads to the question of
whether the correct appropriation is being charged when a payment is
made, not whether a contract will be over or under paid.
4. The seventh sentence states that the prompt payment clause should be
expanded to include financing payments so that all contractor debt will
be promptly identified, reported and collected. Because the Prompt
Payment Act does not apply to financing payments, other than interim
payments of services contracts, the Department has chosen not to revise
the prompt payment clauses to add a reference to notification of
overpayments that may occur on a financing payment. Rather, the
Department has proposed that the contract financing clauses (i.e.,
Federal Acquisition Regulation (FAR) 52-216-7; 52.216-13; 52.232-7;
52.232-16; 52.232-30; 52.232-32; and 52.232-39) be revised to add the
same notification of overpayment requirement as was recently added to
the prompt payment clauses. This revision to financing clauses is being
accomplished via FAR Case 2001-005; that case has been approved by the
Defense Acquisition Regulations Council and Civilian Agency Acquisition
Council, and currently is awaiting approval by the Office of Federal
Procurement Policy (OFPP), which must occur prior to publication as a
proposed rule. FAR Case 2001-005 also modifies FAR 12.210 and the
clause at FAR 52.212-4 to provide for notification of overpayments on
contract financing and invoice payments on commercial contracts.
5. The paragraph concludes that the OFPP is considering adding
financing payments to the prompt payment clauses. This comment is not
technically correct. The FAR case (i.e., 2001-005), currently
undergoing the normal OFPP review that precedes publication of a
proposed rule, does not revise the prompt payment clauses. Rather, it
revises the contract financing clauses to add a requirement for
contractors to notify the government if they become aware of an
overpayment arising from a financing payment.
Page 29, Middle Paragraph. The sentence states that DCAA preliminary
results indicate that amounts due the government are not promptly
returned and controls over "agreed to" offsets are weak. The DCAA
concluded that contractor controls over offsets are weak, and that
contractors used offsets. The wording should be changed to read:
"According to the DCAA, preliminary results of its contract audits
indicate that (1) not all amounts due the government are returned
promptly, and (2) contractor controls over offsets are weak because
they lack supporting documentation and the DFAS is not always notified
of offsets that occur."
Page 30, Middle Paragraph. The first sentence states that survey
results, DCAA audits and DFAS-CO data indicate that contractor debt
caused by contract administration actions as well as payment problems
have continued. The wording implies that contract administration debt
is a problem, but that view is not one that is shared. The first
sentence should be changed to read:
"Survey results, DCAA audits, and DFAS-CO data indicated that payment
problems have continued with DoD contract payments--contract pay as
well as vendor pay--and that resolution of payment discrepancies and
contract administration actions has not always been timely."
[End of section]
Footnotes:
[1] U.S. General Accounting Office, DOD Procurement: Millions in
Overpayments Returned by DOD Contractors, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-94-106] (Washington, D.C.: Mar.
14, 1994).
[2] 31 U.S.C. 3561-3567, National Defense Authorization Act for Fiscal
Year 2002, section 831, Public Law No. 107-107, 115 Stat. 1012, 1186
(2001).
[3] U.S. General Accounting Office, DOD Procurement: Millions in
Contract Payment Errors Not Detected and Resolved Promptly, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-96-8] (Washington, D.C.: Oct. 6,
1995).
[4] 31 U.S.C. 3561-3567.
[5] U.S. General Accounting Office, Strategies to Manage Improper
Payments: Learning From Public and Private Sector Organizations,
[hyperlink, http://www.gao.gov/products/GAO-02-69G] (Washington, D.C.:
Oct. 2001).
[6] U.S. General Accounting Office, DOD Contact Management: Greater
Attention Needed to Identify and Recover Overpayments, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-99-131] (Washington, D.C.: July
19, 1999).
[7] Even though we requested data as of September 30, 2001, some
contractors reported as of that date and others reported as of various
dates, most in October 2001.
[8] DOD Inspector General, Controls Over the Computerized Accounts
Payable System at Defense Finance and Accounting Service Kansas City,
Report No. D-2002-008 (Washington, D.C.: Oct. 19, 2001), and Financial
Management: Controls Over Vendor Payments Made for the Army and Defense
Agencies Using the Computerized Accounts Payable System, Report No. D-
2002-056 (Washington, D.C.: Mar. 6, 2002).
[9] U.S. General Accounting Office, Contract Management: Excess
Payments and Underpayments Continue to Be a Problem at DOD, [hyperlink,
http://www.gao.gov/products/GAO-01-309] (Washington, D.C.: Feb. 22,
2001).
[10] [hyperlink, http://www.gao.gov/products/GAO/NSIAD-99-131].
[11] U.S. General Accounting Office, Financial Management: Seven DOD
Initiatives That Affect the Contract Payment Process, [hyperlink,
http://www.gao.gov/products/GAO/AIMD-98-40] (Washington, D.C.: Jan. 30,
1998).
[12] DOD Inspector General, Controls Over Electronic Document
Management, Report No. D-2001-101 (Washington, D.C.: Apr. 16, 2001);
Controls for the Electronic Interchange at the Defense Finance and
Accounting Service Columbus, Report No. D-2001-095 (Washington, D.C.:
Apr. 6, 2001); and General Controls Over the Electronic Document Access
System, Report No. D-2001-029 (Washington, D.C.: Dec. 27, 2000)
[13] U.S. General Accounting Office, Contract Management: Fixing DOD‘s
Payment Problems Is Imperative, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-97-37] (Washington, D.C.: Apr.
10, 1997).
[14] [hyperlink, http://www.gao.gov/products/GAO/NSIAD-96-8].
[15] [hyperlink, http://www.gao.gov/products/GAO/NSIAD-99-131].
[16] [hyperlink, http://www.gao.gov/products/GAO/AIMD-98-40].
[17] [hyperlink, http://www.gao.gov/products/GAO-01-309] and
[hyperlink, http://www.gao.gov/products/GAO/NSIAD-99-131].
[18] U.S. General Accounting Office, Canceled DOD Appropriations: $615
Million of Illegal or Otherwise Improper Adjustments, [hyperlink,
http://www.gao.gov/products/GAO-01-697] (Washington, D.C.: July 26,
2001).
[19] U.S. General Accounting Office, DOD Systems Modernization:
Continued Investment in the Standard Procurement System Has Not Been
Justified, [hyperlink, http://www.gao.gov/products/GAO-01-682]
(Washington, D.C.: July 31, 2001).
[20] Statement of Federal Financial Accounting Standards (SFFAS) No. 1,
Accounting for Selected Assets and Liabilities, Mar. 30, 1993; SFFAS
No. 5, Accounting for Liabilities of the Federal Government, Dec. 20,
1995; Joint Financial Management Improvement Program, Federal Financial
Management System Requirements: Core Financial System Requirements
(Washington, D.C.: Sept. 1995); and DOD, Financial Management
Regulation, vol. 4, chap. 3, (Washington, D.C.: Jan. 2001).
[21] [hyperlink, http://www.gao.gov/products/GAO-01-309].
[22] U.S. General Accounting Office, Debt Collection: Defense Finance
and Accounting Service Needs to Improve Collection Efforts, [hyperlink,
http://www.gao.gov/products/GAO-01-686] (Washington, D.C.: June 29,
2001) and DOD Inspector General, DOD Contractor Debt Collection
Process, Report No. D-2001-114 (Washington, D.C.: May 7, 2001).
[23] [hyperlink, http://www.gao.gov/products/GAO-01-309].
[24] See footnote 7.
[25] [hyperlink, http://www.gao.gov/products/GAO/NSIAD-96-08].
[End of section]
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