DCAA Audits
Widespread Problems with Audit Quality Require Significant Reform Gao ID: GAO-09-468 September 23, 2009The Defense Contract Audit Agency (DCAA) under the Department of Defense (DOD) Comptroller plays a critical role in contractor oversight by providing auditing, accounting, and financial advisory services in connection with DOD and other federal agency contracts and subcontracts. Last year, GAO found numerous problems with DCAA audit quality at three locations in California, including the failure to meet professional auditing standards. This report addresses audit quality issues at DCAA offices nationwide. GAO was asked to (1) conduct a broad assessment of DCAA's management environment and audit quality assurance structure, (2) evaluate DCAA actions to date to correct previously identified problems, and (3) identify potential legislative and other actions for improving DCAA effectiveness and independence. To achieve these objectives, GAO analyzed DCAA's mission, strategic plan, audit policies, and quality assurance program; conducted interviews; reviewed selected audits at DCAA offices; and analyzed legislative and other actions.
GAO found audit quality problems at DCAA offices nationwide, including compromise of auditor independence, insufficient audit testing, and inadequate planning and supervision. GAO's conclusions stem from a review of 69 audit assignments supporting contract award and administrative decisions; an assessment of DCAA's audit quality assurance structure, which found similar audit quality problems but gave satisfactory ratings to deficient audits; and DCAA's rescission of 80 problem audit reports. The rescinded audits supported decisions on pricing and contract awards and impacted the planning and reliability of hundreds of other DCAA audits, representing billions of dollars in DOD expenditures. GAO found DCAA's management environment and quality assurance structure were based on a production-oriented mission that put DCAA in the role of facilitating DOD contracting without also protecting the public interest. DCAA has taken several positive steps. However, DOD and DCAA have not yet addressed fundamental weaknesses in DCAA's mission, strategic plan, metrics, audit approach, and human capital practices that had a detrimental effect on audit quality. To improve DCAA oversight, the DOD Comptroller requested Defense Business Board and "tiger team" reviews and established a DCAA Oversight Committee. In addition, in the short-term, Congress could provide DCAA with certain legislative protections and authorities similar to those available to IGs. In the longer term, Congress may wish to consider organizational changes to elevate DCAA to a component agency reporting to the Deputy Secretary or to establish an independent governmentwide contract audit agency.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-09-468, DCAA Audits: Widespread Problems with Audit Quality Require Significant Reform
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Report to the Committee on Homeland Security and Governmental Affairs,
U.S. Senate:
United States Government Accountability Office:
GAO:
September 2009:
DCAA Audits:
Widespread Problems with Audit Quality Require Significant Reform:
GAO-09-468:
GAO Highlights:
Highlights of GAO-09-468, a report to the Committee on Homeland
Security and Governmental Affairs, U.S. Senate.
Why GAO Did This Study:
The Defense Contract Audit Agency (DCAA) under the Department of
Defense (DOD) Comptroller plays a critical role in contractor oversight
by providing auditing, accounting, and financial advisory services in
connection with DOD and other federal agency contracts and
subcontracts. Last year, GAO found numerous problems with DCAA audit
quality at three locations in California, including the failure to meet
professional auditing standards. This report addresses audit quality
issues at DCAA offices nationwide. GAO was asked to (1) conduct a broad
assessment of DCAA‘s management environment and audit quality assurance
structure, (2) evaluate DCAA actions to date to correct previously
identified problems, and (3) identify potential legislative and other
actions for improving DCAA effectiveness and independence. To achieve
these objectives, GAO analyzed DCAA‘s mission, strategic plan, audit
policies, and quality assurance program; conducted interviews; reviewed
selected audits at DCAA offices; and analyzed legislative and other
actions.
What GAO Found:
GAO found audit quality problems at DCAA offices nationwide, including
compromise of auditor independence, insufficient audit testing, and
inadequate planning and supervision. GAO‘s conclusions stem from a
review of 69 audit assignments supporting contract award and
administrative decisions; an assessment of DCAA‘s audit quality
assurance structure, which found similar audit quality problems but
gave satisfactory ratings to deficient audits; and DCAA‘s rescission of
80 problem audit reports. The rescinded audits supported decisions on
pricing and contract awards and impacted the planning and reliability
of hundreds of other DCAA audits, representing billions of dollars in
DOD expenditures. GAO findings include the following.
Table: Selected Details of Audits GAO Reviewed:
Contractor: Research and development grantee; Audit: Billing system;
Significant case study issues:
* DCAA auditors spent 530 hours to support an audit of a nonexistent
billing system and reported adequate system controls.
* Instead, DCAA should have relied on the Single Audit Act report on
the grantee‘s cash management system. DCAA agrees.
Contractor: Combat systems;
Audit: Billing system;
Significant case study issues:
* This was a new system and therefore high risk, but auditors deleted
key audit steps related to contractor policies and internal controls
over progress payments without explanation.
* One auditor told GAO he did not perform detailed tests because ’the
contractor would not appreciate it.“
* DCAA allowed the contractor 7 months to address 6 significant
deficiencies, dropping 2 and downgrading the other 4.
* DCAA rescinded this audit report following GAO‘s review.
Contractor: Iraq reconstruction;
Audit: Accounting system;
Significant case study issues:
* Contractor objected to draft report, which included 8 significant
deficiencies in the accounting system.
* Auditors dropped 5 significant deficiencies and downgraded 3 others
to suggestions to improve without performing new work.
* Supervisory auditors directed audit staff to delete some audit
documents, generate others, and in one case, copy the signature of a
prior supervisor onto new documents making it appear that the prior
supervisor had approved a revised risk assessment.
* Supervisory auditor who approved altered documents was later promoted
to western region quality assurance manager, where he served as quality
control check over thousands of audits.
Source: GAO.
[End of table]
GAO found DCAA‘s management environment and quality assurance structure
were based on a production-oriented mission that put DCAA in the role
of facilitating DOD contracting without also protecting the public
interest. DCAA has taken several positive steps. However, DOD and DCAA
have not yet addressed fundamental weaknesses in DCAA‘s mission,
strategic plan, metrics, audit approach, and human capital practices
that had a detrimental effect on audit quality.
To improve DCAA oversight, the DOD Comptroller requested Defense
Business Board and ’tiger team“ reviews and established a DCAA
Oversight Committee. In addition, in the short-term, Congress could
provide DCAA with certain legislative protections and authorities
similar to those available to IGs. In the longer term, Congress may
wish to consider organizational changes to elevate DCAA to a component
agency reporting to the Deputy Secretary or to establish an independent
governmentwide contract audit agency.
What GAO Recommends:
GAO makes 17 recommendations to DOD and the DOD Inspector General (IG)
to improve DCAA‘s management environment, audit quality, and oversight.
GAO also discusses matters that Congress should consider to enhance the
effectiveness and independence of DCAA contract audits. DOD and DOD IG
generally agreed with GAO‘s recommendations, concurring with all but
two.
View [hyperlink, http://www.gao.gov/products/GAO-09-468] or key
components. For more information, contact Gregory Kutz at (202) 512-
6722 or kutzg@gao.gov.
[End of section]
Contents:
Letter:
Background:
Nationwide Audit Quality Problems Are Rooted in DCAA's Poor Management
Environment:
DCAA Has Made Progress, but Correcting Fundamental Problems in Agency
Culture That Have Impacted Audit Quality Will Require Sustained
Leadership:
Legislative and Other Actions To Improve DCAA's Effectiveness and
Independence:
Conclusions:
Recommendations for Executive Action:
Matters for Congressional Consideration:
Agency Comments and Our Evaluation:
Appendix I: Internal Control System Audits Did Not Meet Professional
Standards:
Appendix II: DCAA Does Not Perform Sufficient Work to Identify and
Collect Contractor Overpayments:
Appendix III: Objectives, Scope, and Methodology:
Appendix IV: Comments from the Department of Defense:
Appendix V: Comments from the Department of Defense Inspector General:
Tables:
Table 1: Examples of DCAA Audit and Nonaudit Services:
Table 2: Summary of Five Selected Internal Control Audits:
Table 3: Summary of Five Selected Cost-Related Assignments:
Table 4: Summary of Selected DCAA Audit Quality Review Results:
Table 5: GAGAS Noncompliance on 37 Selected Audits of Contractor
Controls:
Table 6: Case Studies of Problem DCAA Cost-Related Assignments:
Table 7: Summary of DCAA Audits Reviewed for GAGAS Compliance:
Table 8: Summary of DCAA Cost-Related Assignments Reviewed:
Figures:
Figure 1: DCAA Opinions on Contractor Internal Control Systems Audits:
Figure 2: Comparison of DOD Contract Obligations and DCAA Workforce for
Fiscal Years 2002 through 2008:
Figure 3: DCAA Questioned Costs and Amounts Sustained by Contracting
Officers:
Abbreviations:
AICPA: American Institute of Certified Public Accountants:
AT: AICPA Statements on Attestation Standards:
AT&L: Acquisition, Technology, and Logistics:
APO: Audit Policy and Oversight (a Defense Inspector General
organization):
AU: AICPA Statements on Auditing Standards:
CAS: Cost Accounting Standards:
CAM: Contract Audit Manual, also referred to as the DCAA Contract Audit
Manual, or DCAM:
CFO: Chief Financial Officer:
COSO: Committee on Sponsoring Organizations:
DBB: Defense Business Board:
DCAA: Defense Contract Audit Agency:
DCAM: DCAA Contract Audit Manual:
DCMA: Defense Contract Management Agency:
DFARS: Defense Federal Acquisition Regulation Supplement:
DFAS: Defense Finance and Accounting Service:
DFMR: Defense Financial Management Regulation:
DOD: Department of Defense:
DPAP: Director of Defense Procurement Policy:
FAO: field audit office:
FAR: Federal Acquisition Regulation:
FLA: Financial Liaison Advisor:
FMR: Financial Management Regulation, also referred to as the Defense
Financial Management Regulation, or DFMR:
GAGAS: generally accepted government auditing standards:
GAS: Government Auditing Standards:
GPRA: Government Performance and Results Act:
GS: General Schedule:
IG: Inspector General:
IGDH: Inspector General, Defense Handbook:
OIG: Office of Inspector General:
PCIE: President's Council on Integrity and Efficiency, renamed the
Council of the Inspectors General on Integrity and Efficiency:
SAS: AICPA Statements on Auditing Standards:
SES: Senior Executive Service:
SIGIR: Special Inspector General for Iraq Reconstruction:
SSAE: AICPA Statements on Standards for Attestation Engagements:
USC: United States Code:
USD: Under Secretary of Defense:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 23, 2009:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Claire C. McCaskill:
Chairman:
Subcommittee on Contracting Oversight:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
This report addresses audit quality problems and independence issues at
the Defense Contract Audit Agency (DCAA). In a September 2008 hearing
before the Committee, we testified[Footnote 1] that DCAA failed to meet
professional audit standards at three locations in California.
Specifically, we found that the audit documentation for 14 selected
audits at two locations did not support reported opinions, that DCAA
supervisors dropped findings and changed audit opinions without
adequate audit evidence for their changes, and that sufficient audit
work was not performed to support audit opinions and conclusions.
Further, we found that contractor officials and the Department of
Defense (DOD) contracting community improperly influenced the audit
scope, conclusions, and opinions of several audits, including forward
pricing audits at a third location--a serious independence issue.
During our investigation, DCAA managers took actions against their
staff at two locations that served to intimidate auditors and create an
abusive work environment. For example, we learned of verbal
admonishments, reassignments, and threats of disciplinary action
against auditors who spoke with or contacted our investigators, DOD
investigators, or DOD contracting officials.
At the time of the September 2008 hearing, we were conducting a broad
assessment of DCAA's management environment and audit quality assurance
structure at DCAA offices nationwide. Given the evidence presented at
this hearing, you requested that we expand our ongoing assessment. This
report therefore presents (1) an assessment of DCAA's management
environment and quality assurance structure; (2) an analysis of DCAA's
corrective actions in response to our July 2008 report,[Footnote 2] the
Under Secretary of Defense (Comptroller/Chief Financial Officer)
[Footnote 3] "tiger team" review,[Footnote 4] and the Defense Business
Board study;[Footnote 5] and (3) potential legislative and other
actions that could improve DCAA's effectiveness and independence.
To assess DCAA's overall management environment and quality assurance
structure, we analyzed DCAA's mission statement and strategic plan,
performance metrics, policies and audit guidance, and system of quality
control. We also reviewed audit documentation for selected audits at
certain field audit offices (FAO) in each of DCAA's five regions for
compliance with generally accepted government auditing standards
(GAGAS)[Footnote 6] and other applicable standards. We selected 37
audits of contractor internal control systems performed by seven
geographically disperse DCAA field offices within the five DCAA regions
during fiscal years 2004 through 2006.[Footnote 7] These were the most
recently completed fiscal years at the time we initiated our audit. Our
approach focused on DCAA offices that reported predominately adequate,
or "clean," opinions on audits of contractor internal controls over
cost accounting, billing, and cost estimating systems issued in fiscal
years 2005 and 2006.[Footnote 8] We selected DCAA offices that report
predominately adequate opinions on contractor systems and related
internal controls because contracting officers rely on these opinions
for three or more years to make decisions on pricing and contract
awards, and payment. For example, audits of estimating system controls
support negotiation of fair and reasonable prices.[Footnote 9] Also,
the FAR requires contractors to have an adequate accounting system
prior to award of a cost-reimbursable or other flexibly priced
contract.[Footnote 10] Billing system internal control audit results
support decisions to authorize contractors to submit invoices directly
to DOD and other federal agency disbursing offices for payment without
government review.[Footnote 11] In addition, DCAA uses the results of
internal control audits to assess risk and plan the nature, extent, and
timing of tests for other contractor audits and other assignments. When
a contractor has received an adequate opinion on its systems and
related controls, DCAA would assess the risk for subsequent internal
control and cost-related audits as low and would perform less testing
on these audits. Although our selection of the seven offices and 37
internal control audits was not statistical, it represented about 9
percent of the total 76 DCAA offices that issued audit reports on
contractor internal controls and nearly 18 percent of the 40 offices
that issued 8 or more reports on contractor internal controls during
fiscal year 2006. Of the 37 internal control audits we reviewed, 32
reports were issued with adequate opinions and 5 reports were issued
with inadequate-in-part opinions.
At the same seven DCAA field offices, we selected an additional 32 paid
voucher, overpayment, request for equitable adjustment, and incurred
cost assignments that were completed during fiscal years 2004 through
2006 for review of supporting documentation to determine whether DCAA
auditors were identifying and reporting contractor overpayments and
billing errors.[Footnote 12] In total, we reviewed 69 DCAA audits and
cost-related assignments.[Footnote 13] To address our second objective,
we assessed the status and analyzed several key actions that DCAA
initiated as a result of our earlier investigation, including changes
in performance metrics and policy and procedural guidance, as well as
DCAA efforts in response to DOD Comptroller/CFO and Defense Business
Board[Footnote 14] recommendations. To achieve our third objective to
identify potential legislative and other actions that could improve
DCAA's effectiveness and independence, we considered DCAA's current
role and responsibilities; the framework of statutory authority for
auditor independence in the Inspector General Act of 1978, as
amended;[Footnote 15] best practices of leading organizations that have
made cultural and organizational transformations; our past work on DCAA
organizational alternatives; GAGAS criteria for auditor integrity,
objectivity, and independence; and GAO's Standards for Internal Control
In the Federal Government[Footnote 16] on managerial leadership and
oversight.
Throughout our audit, we met with the DCAA Director and DCAA
headquarters policy, quality assurance, and operations officials and
DCAA region and FAO managers, supervisors, and auditors. We also met
with DOD Office of Inspector General (OIG) auditors responsible for
DCAA audit oversight and DOD OIG hotline office staff. We conducted
this performance audit from August 2006 through December 2007, at which
time we suspended this work to complete our investigation of hotline
complaints regarding audits performed at three DCAA field offices. We
resumed our work on this audit in October 2008 and performed additional
work through mid-September 2009 to evaluate DCAA's quality assurance
program during fiscal years 2007 and 2008, assess DCAA corrective
actions on identified audit quality weaknesses, and consider
legislative and organizational placement options. During our assessment
of DCAA corrective actions and analysis of legislative and
organizational placement options for DCAA, we met with the former DOD
Comptroller/CFO to discuss plans for Office of Comptroller/CFO and
Defense Business Board reviews, and we continued to meet with and
obtain information from the new DOD Comptroller/CFO and his staff. We
also met with Comptroller's new DCAA Oversight Committee, which
includes the Auditors General of the Army, the Navy, and the Air Force;
the DOD Director of Defense Procurement and Acquisition Policy; and the
DOD Deputy General Counsel for Acquisition. We obtained DOD and DOD OIG
comments on a draft of this report. DOD and DOD IG comments are
summarized in the Agency Comments and Our Evaluation section of this
report. DOD comments are reprinted in appendix IV and DOD OIG comments
are reprinted in appendix V. We conducted our audit in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for findings and conclusions based
on our audit objectives. We performed our investigative procedures in
accordance with quality standards set forth by the Council of the
Inspectors General on Integrity and Efficiency (formerly the
President's Council on Integrity and Efficiency). A detailed discussion
of our objectives, scope, and methodology is included in appendix III.
Background:
DOD contract management continues to be a high-risk area for the
government.[Footnote 17] With hundreds of billions of taxpayer dollars
at stake, strong controls are needed to provide reasonable assurance
that contract funds are not lost to fraud, waste, abuse, and
mismanagement. Downsizing of contract administration personnel during
the 1990s coupled with increased contract spending since 2000 have
exacerbated the risks associated with DOD contract management. Our work
continues to identify significant problems with federal agency contract
payments[Footnote 18] and contract management.[Footnote 19]
DCAA is charged with a critical role in DOD contractor oversight by
providing auditing, accounting, and financial advisory services in
connection with the negotiation, administration, and settlement of
contracts and subcontracts. DCAA also performs contract audit services
and payment reviews for other federal agencies, as requested, on a fee-
for-service basis. DCAA contract audit services are intended to be a
key control to help assure that prices paid by the government for
needed goods and services are fair and reasonable and that contractors
are charging the government in accordance with applicable laws,
regulations (e.g., Federal Acquisition Regulation (FAR) and Defense
Federal Acquisition Supplement (DFARS), standards (e.g., Cost
Accounting Standards (CAS)), and contract terms.
DCAA is headed by a director who reports to the Under Secretary of
Defense (Comptroller/CFO). DCAA's placement provides the DOD
Comptroller/CFO with access to financial information on defense
contracts and allows the Comptroller/CFO to make this information
available to the Secretary and Deputy Secretary of Defense. In
addition, it permits the Comptroller/CFO to elevate policy issues
concerning the scope of DCAA's authority and level of resources. The
DCAA Director is responsible for day-to-day management of DCAA,
development of strategic plans, audit guidance and procedures, and the
quality of DCAA's audit services. DCAA's Contract Audit Manual
(CAM)[Footnote 20] prescribes the standards, policies, and techniques
to be followed by DCAA personnel in conducting contract audits. DCAA
emphasizes and supplements CAM guidance through policy memorandums and
other written notices, as well as through training and oral
communications.
The IG Act gives the DOD IG broad responsibilities to provide policy
direction for and to conduct, supervise, and coordinate audits and
investigations in DOD and in contractor operations, if warranted. DOD
IG duties pertaining to DCAA include (1) providing policy direction for
all DOD audits; (2) investigating fraud, waste, and abuse uncovered as
a result of audits; (3) monitoring and evaluating adherence by all DOD
auditors to audit policies, procedures, and standards; and (4)
requesting assistance as needed from other auditors in DOD. As part of
its audit policy and oversight responsibilities, the DOD IG reviews
DCAA's system of audit quality control on a 3-year basis that is
intended to meet the requirements under GAGAS for a peer review.
DCAA History and Organizational Structure:
Audits of military contracts can be traced back to at least the World
War I era. Initially, the various branches of the military had their
own contract audit function and associated instructions and accounting
rulings. Contractors and government personnel recognized the need for
consistency in both contract administration and audit. The Navy and the
Army Air Corps made the first attempt to perform joint audits in 1939.
By December 1942, the Navy, the Army Air Corps, and the Ordnance
Department had established audit coordination committees for selected
areas where plants were producing different items under contracts for
more than one service. On June 18, 1952, the three military services
jointly issued a contract audit manual that later became the DCAA CAM.
In May 1962, Secretary of Defense Robert S. McNamara instituted
"Project 60" to examine the feasibility of centrally managing the field
activities concerned with contract administration and audit.[Footnote
21] An outcome of this study was the decision to establish a single
contract audit capability within DOD and DCAA was established on June
8, 1965.[Footnote 22] At that time, DCAA's mission to perform all
necessary contract audits for DOD and provide accounting and financial
advisory services regarding contracts and subcontracts to all DOD
components responsible for procurement and contract administration was
established. The former Deputy Comptroller of the Air Force was
selected as the DCAA Director and the former Director of Contract Audit
for the Navy, was selected as the Deputy Director. DCAA was placed
under management control of the Under Secretary of Defense
(Comptroller), where it remains today.
DCAA consists of a headquarters office at Fort Belvoir, Virginia, and
six major organizational components--a field detachment office, which
handles audits of classified contracting activity, and five regional
offices within the United States. The regional offices manage field
audit offices (FAO), which are identified as branch offices, resident
offices, or suboffices. Resident offices are located at larger
contractor facilities in order to facilitate DCAA audit work. In
addition, regional office directors can establish suboffices as
extensions of FAOs to provide contract audit services more
economically. A suboffice depends on its parent FAO for release of
audit reports and other administrative support. In total, there are
more than 300 FAOs and suboffices throughout the United States and
overseas. During fiscal year 2008, DCAA employed about 3,600 auditors
at more than 300 FAOs throughout the United States, Europe, the Middle
East, and in the Pacific to perform audits and provide nonaudit
services in support of contract negotiations related to approximately
10,000 contractors.
DCAA Audit and Nonaudit Services:
DCAA's mission encompasses both audit and nonaudit services in support
of DOD contracting and contract payment functions. FAR subpart 42.1,
"Contract Audit Services," and DOD Directive 5105.36, Defense Contract
Audit Agency (DCAA), establish DCAA as the department's contract audit
agency[Footnote 23] and set forth DCAA's responsibilities.
FAR 42.101 prescribes contract audit responsibilities as submitting
information and advice to the requesting activity, based on the
analysis of contractor financial and accounting records or other
related data as to the acceptability of the contractors' incurred and
estimated costs; reviewing the financial and accounting aspects of
contractor cost control systems; and, performing other analyses and
reviews that require access to contractor financial and accounting
records supporting proposed and incurred costs. DOD Directive 5150.36
lists several responsibilities and functions that shall be performed by
the DCAA Director,[Footnote 24] including:
* "Assist in achieving the objective of prudent contracting by
providing DOD officials responsible for procurement and contract
administration[Footnote 25] with financial information and advice on
proposed or existing contracts and contractors, as appropriate."
* "Audit, examine, and/or review contractors' and subcontractors'
accounts, records, documents, and other evidence; systems of internal
control; [and] accounting, costing, and general business practices and
procedures; to the extent and in whatever manner is considered
necessary to permit proper performance of other functions —." These
other functions cover contract audit and nonaudit services. In
addition, the Directive states that the DCAA Director shall perform
such other functions as may be assigned by the Secretary and Deputy
Secretary of Defense or the Under Secretary of Defense (Comptroller/
CFO).
* "Approve, suspend, or disapprove costs on reimbursement vouchers
received directly from contractors, under cost-type contracts,
transmitting the vouchers to the cognizant Disbursing Officer."
DCAA uses the term audit to refer to a variety of evaluations of
various types of data.[Footnote 26] In fiscal year 2008, DCAA reported
that over 97 percent of its service work hours were spent on audits,
meaning that DCAA has opted to provide nearly all of its services to
the contracting and finance communities under applicable auditing
standards, as discussed below. Table 1 lists several audit and nonaudit
services provided by DCAA during the three phases of the contracting
process--pre-award, contract administration, and close-out--and cites
the statutory and regulatory provisions that authorize or establish the
need to have DCAA perform the service. DCAA audits also support the
contract payment process both directly and indirectly. For example,
audits of contractor incurred cost claims and voucher reviews directly
support the contract payment process by providing the information
necessary to certify payment of claimed costs. [Footnote 27] Other
audits of contractor systems, including audits of contractor internal
controls, CAS compliance, and defective pricing, indirectly support the
payment process by providing assurance about contractor controls over
cost accounting, cost estimating, purchases, and billings that the
agency may rely upon when making contract decisions, such as
determinations of reasonable and fair prices on negotiated contracts.
For example, an accounting system deemed to be adequate by a DCAA audit
permits progress payments based on costs to be made without further
audit.[Footnote 28]
Table 1: Examples of DCAA Audit and Nonaudit Services:
Pre-award phase:
Contract phase and assignment: Accounting system[A];
Audit and Nonaudit services: Audit: DCAA determines adequacy of the
contractor's accounting system prior to award of a cost-reimbursable or
other flexibly priced contract. FAR § 16.301-3(a)(1);
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Contractor accounting disclosure
statements;
Audit and Nonaudit services: Audit: DCAA reviews the contractor's
Disclosure Statement for adequacy and CAS compliance and determines
whether the contractor's Disclosure Statement is current, accurate, and
complete. DCAA also reviews Disclosure Statements during the post award
phase if contractors revise them. FAR §§ 30.202-6(c), 30.202-7 and
30.601(c);
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Estimating system [A];
Audit and Nonaudit services: Audit: DCAA determines adequacy of
contractor estimating systems. FAR § 15.407-5 and DFARS § 252.215-
7002(d),(e);
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Contract price proposals and forward
pricing proposals[B];
Audit and Nonaudit services: Audit: DCAA examines contractor records to
ensure that cost or pricing data is accurate, current, and complete and
supports the determination of fair and reasonable prices. 10 U.S.C. §§
2306a and 2313 (DOD) and 41 U.S.C. § 254d (other agencies); FAR Subpart
15.4 (esp. FAR § 15.404-2(c)) and § 52.215-2(c); and DFARS § 215.404-1;
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Financial liaison advisory services[B];
Audit and Nonaudit services: Nonaudit: DCAA Director establishes and
maintains liaison auditors and financial advisors, as appropriate, at
major procuring and contract administration offices. These services are
also provided during the post-award phase, as needed. DODD 5105.36,
paras. 7.1.1 and 5.9;
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Post award/administration phase:
Contract phase and assignment: Internal control system audits
(generally);
Audit and Nonaudit services: Audit: DCAA reviews the financial and
accounting aspects of the contractor's cost control systems, including
the contractor's internal control systems. FAR § 42.101(a)(3) and DFARS
§ 242.7501;
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Billing system audits[A];
DCAA reviews the financial and Audit: DCAA determines adequacy of
contractors' billing system controls and reviews accuracy of paid
vouchers. DCAA uses audit results to support approval of contractors to
participate in the direct-bill program. FAR § 42.101 and DFARS § 42.803
(b)(i)(C);
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Purchasing system review[B];
Audit and Nonaudit services: Audit: DCAA determines adequacy of a
contractor's or subcontractor's purchasing system. FAR Subpart 44.3;
Contracting support: [Check];
Payment support: Direct: [Empty];
Payment support: Indirect: [Check].
Contract phase and assignment: Progress payments[B];
Audit and Nonaudit services: Audit: DCAA verifies amount claimed,
determines allowability of contractor requests for cost-based progress
payments, and determines if the payment will result in undue financial
risk to the government. FAR §§ 32.503-3, 32.503-4, and 52.232-16;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Incurred cost claims[A];
Audit and Nonaudit services: Audit: DCAA determines acceptability of
the contractors' claimed costs incurred and submitted by contractors
for reimbursement under cost-reimbursable, fixed-price incentive, and
other types of flexibly priced contracts and compliance with contract
terms, FAR, and CAS, if applicable. FAR §§ 42.101, 42.803(b), and DFARS
§ 242.803;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Billing rates and final indirect cost
rates[A];
Audit and Nonaudit services: Audit: DCAA establishes billing rates for
interim indirect costs and final indirect cost rates. FAR §§ 42.704,
42.705 and 42.705-2 and DFARS § 42.705-2;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Defective pricing[B];
Audit and Nonaudit services: Audit: DCAA determines the amount of cost
adjustments related to defective pricing. See above authorities to
audit contractor cost and pricing data and FAR § 15.407-1;
Contracting support: [Check];
Payment support: [Empty];
Payment support: [Check].
Contract phase and assignment: CAS compliance[B];
Audit and Nonaudit services: Audit: DCAA determines contractor and
subcontractor compliance with CAS set forth in 48 CFR § 9903.201 and
determines cost impacts of noncompliance. FAR §§ 1.602-2, 30.202-7, and
30.601(C);
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Other specially requested services;
Audit and Nonaudit services: Audit: Audit and nonaudit services: DCAA
conducts performance audits and other audits based on requests from DOD
components and requests from other federal agencies. DOD Directive
5105.36, Sec. 5;
Contracting support: [Check];
Payment support: [Empty];
Payment support: [Check].
Contract phase and assignment: Paid voucher reviews[A];
Audit and Nonaudit services: Audit: Nonaudit services: DCAA reviews
vouchers after payment to support continued contractor participation in
the direct bill program. CAM 6-1007.6; FAR § 42.803; DFARS § 242.803;
DODD 5105.36, paras. 5.4 and 5.5; and DOD Financial Management
Regulation (FMR), vol. 10, ch. 10, para. 100202;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Approval of vouchers prior to
payment[A];
Audit and Nonaudit services: Audit: Nonaudit: DCAA reviews and approves
contractor interim vouchers for payment and suspends payment of
questionable costs. FAR § 42.803; DFARS § 242.803(b)(i)(B); DOD
Directive 5105.36, paras. 5.4 and 5.5; and DOD FMR vol. 10, ch. 10,
para. 100202;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Contract phase and assignment: Overpayment reviews[A];
Audit and Nonaudit services: Audit: Non audit services: At the request
of the contracting officer, DCAA reviews contractor data to identify
potential contract overpayments. FAR §§ 2.605, 52.216-7(g),(h)2;
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Close-out/termination phase:
Contract phase and assignment: Contract close-out procedures and
audits[A];
Audit and Nonaudit services: Audit: DCAA reviews final completion
vouchers and the cumulative allowable cost worksheet and may review
contract closing statements. DFARS § 242.803(b)(i)(D);
Contracting support: [Check];
Payment support: [Check];
Payment support: [Empty].
Source: GAO analysis.
[A] Indicates DCAA audit and nonaudit services covered in this audit.
[B] Indicates types of audits covered in our prior investigation (GAO-
08-857). We reviewed progress payment and contract close-out audits
that related to audits in our earlier investigation or this audit where
the auditors considered the evidence in those audits.
[End of table]
Importance of Audits in Accordance with GAGAS:
DCAA policy states[Footnote 29] that it follows GAGAS[Footnote 30] when
conducting audits. These standards provide a framework for conducting
high quality government audits and attestation engagements. These
standards also provide guidelines to help government auditors maintain
competence, integrity, objectivity, and independence in their work and
require that they obtain sufficient evidence to support audit
conclusions and opinions. When auditors are required to follow GAGAS or
are representing to others that they followed GAGAS, they should follow
all applicable GAGAS requirements and should refer to compliance with
GAGAS in the auditor's report.[Footnote 31] Most DCAA audits are
performed as attestation audits under GAGAS. For attestation audits,
GAGAS incorporates the American Institute of Certified Public
Accountants (AICPA) general standard on criteria, and the field work
and reporting standards and the related Statements on Standards for
Attestation Engagements (SSAE), unless specifically excluded or
modified by GAGAS.[Footnote 32] DCAA also conducts performance audits
upon request. This report addresses DCAA attestation audits and related
supporting assignments.
GAGAS state that the public expects auditors to observe the principles
of serving the public interest and maintaining the highest degree of
integrity, objectivity, and independence in discharging their
professional responsibilities. Serving the public interest and honoring
the public trust are critical when performing government audits.
Auditors increase public confidence when they conduct their work with
an attitude that is objective, fact-based, nonpartisan, and non-
ideological with regard to audited entities and users of the auditors'
reports. Auditors also should be intellectually honest and free of
conflicts of interest in discharging their professional
responsibilities.[Footnote 33] Management of the audit organization
sets the tone for ethical behavior throughout the organization by
maintaining an ethical culture, clearly communicating acceptable
behavior and expectations to each employee and creating an environment
that reinforces and encourages ethical behavior throughout all levels
of the organization. [Footnote 34] The credibility of auditing in the
government sector is based on auditors' objectivity and integrity in
discharging their professional responsibilities.[Footnote 35]
Nationwide Audit Quality Problems Are Rooted in DCAA's Poor Management
Environment:
We found audit quality problems at DCAA offices nationwide, as
demonstrated by serious quality problems in the 69 audits and cost-
related assignments we reviewed, DCAA's ineffective audit quality
assurance program, and DCAA's rescission of 80 audit reports in
response to our work. [Footnote 36] Of the 69 audits and cost-related
assignments we reviewed for this report, 65 exhibited serious GAGAS or
other deficiencies similar to those found in our prior investigation,
including compromise of auditor independence, insufficient audit
testing, and inadequate planning and supervision. Although not as
serious, the remaining four audits also had GAGAS compliance problems.
The 69 audits and cost-related assignments we reviewed included 43
audits that DCAA reported were performed in accordance with GAGAS and
26 non-GAGAS cost-related assignments, including 10 overpayment and 16
paid voucher assignments. According to DCAA officials, DCAA rescinded
the 80 audit reports because the audit evidence was outdated,
insufficient, or inconsistent with reported conclusions and opinions
and reliance on the reports for contracting decisions could pose a
problem. Nearly one third (24) of the 80 rescinded reports relate to
unsupported opinions on contractor internal controls, which were used
as the basis for risk-assessments and planning on subsequent internal
control and cost-related audits. Other rescinded reports relate to CAS
compliance and contract pricing decisions. Because the conclusions and
opinions in the rescinded reports were used to assess risk in planning
subsequent audits, they impact the reliability of hundreds of other
audits and contracting decisions covering billions of dollars in DOD
expenditures. We found that DCAA's focus on a production-oriented
mission led DCAA management to establish policies, procedures, and
training that emphasized performing a large quantity of audits to
support contracting decisions over audit quality. An ineffective
quality assurance structure compounded this problem.
Audit Quality Problems Found in All Audits GAO Reviewed:
We found audit quality problems, including GAGAS compliance problems,
with all 37 audits of contractor internal controls and the 4 incurred
cost and the 2 request for equitable adjustment audits we reviewed at 7
FAOs across the 5 DCAA regions covered in this audit. In addition, none
of the 26 cost-related assignments we reviewed from these same FAOs
included sufficient testing to identify contractor overpayments and
billing errors. For additional details on our analysis of these DCAA
audits and assignments, including narrative case-studies, see
appendixes I and II.
Internal Control Audits:
DCAA performs attestation audits of contractors' systems for cost
accounting, estimating, and billing to gather evidence to express an
opinion on the adequacy of the contractor's systems and related
internal controls for compliance with applicable laws and regulations
and contract terms. A contractor must have an adequate accounting
system to be awarded a government cost-reimbursement contract, an
adequate billing system to submit invoices for payment without
government review, and an acceptable estimating system to support a
contracting officer's approval of pricing proposals. A secondary
objective of DCAA's audits of contractor systems and controls is to
determine the degree of reliance that can be placed on the contractor's
internal controls as a basis for planning the scope of other related
audits. For example, if a contractor receives an adequate opinion on
various systems control audits, auditors assess risk as low and reduce
the level of testing on subsequent internal control and cost-related
audits, including audits of contractors' annual incurred cost claims.
Although the reports for all 37 audits of contractor internal controls
that we reviewed stated that the audits were performed in accordance
with GAGAS, we found GAGAS compliance issues with all of these audits.
Examples of GAGAS compliance issues we found included:
Independence issues. For 7 audits we reviewed, DCAA independence was
compromised because auditors provided material nonaudit services to a
contractor they later audited; experienced access to records problems
that were not fully resolved; or significantly delayed report issuance
in order to allow the contractors to resolve cited deficiencies. GAGAS
state that auditors should be free from influences that restrict access
to records or improperly modify audit scope.[Footnote 37]
Insufficient evidence. We found that 33 of the 37 internal control
audits did not include sufficient testing of internal controls to
support auditor conclusions and opinions. GAGAS for examination-level
attestation engagements require that sufficient evidence be obtained to
provide a reasonable basis for the conclusion that is expressed in the
report.[Footnote 38] However, our review of audit documentation often
found that only two, three, or sometimes five transactions were tested
to support audit conclusions, and the audit documentation did not
contain a justification for the small sample sizes selected for
testing. For internal control audits, which are relied on for 2 to 4
years and sometimes longer, the auditors would be expected to test a
representative selection of transactions across the year and not
transactions for just one day, one month, or a couple of months.
[Footnote 39] For many controls, the procedures performed consisted of
documenting the auditors' understanding of controls, and the auditors
did not test the effectiveness of the implementation and operation of
controls.
Generally, the basis for an auditor's determination of sufficient
testing should include (1) an adequate risk assessment, taking into
consideration any auditor alerts arising from related audits, past
findings, and corrective actions; (2) the contractor's overall control
environment; and (3) the nature and volume of transactions and
associated materiality and risk of error. For example, decisions on
sufficient testing of contractor internal controls would include
consideration of the number and types of contracts or proposals; the
nature, dollar amount, and volume of transactions; and key control
attributes or special characteristics of the transactions. Further, a
representative selection would include a representative number of
transactions from a population of transactions representing a
reasonable period of time, in order for test results to support
conclusions and opinions on the overall adequacy of the contractor's
systems and effectiveness of the related controls. For example, under
the GAO/PCIE Financial Audit Manual,[Footnote 40] the minimum sample
size for an attribute sample of a control would be 45 items.
Reporting problems. According to GAGAS, audit reports should, among
other matters, identify the subject matter being reported and the
criteria used to evaluate the subject matter. Criteria identify the
required or desired state or expectation with respect to the program or
operation and provide a context for evaluating evidence and
understanding the findings.[Footnote 41] None of the 37 internal
control audit reports we reviewed cited specific criteria used in
individual audits. Instead, the reports uniformly used boilerplate
language to state that DCAA audited for compliance with the "FAR, CAS,
DFARS, and contract terms." As a result the user of the report does not
know the specific Federal Acquisition Regulation (FAR), Cost Accounting
Standards (CAS), or contract terms used as criteria to test contractor
controls. This makes it difficult for users of the reports to determine
whether a particular report provides the level of assurance needed to
make contracting decisions.
The lack of sufficient support for the audit opinions on 33 of the 37
internal control audits we reviewed rendered them unreliable for
decision making on contract awards, direct billing privileges, the
reliability of cost estimates, and reported direct cost and indirect
cost rates. For example, the FAR requires[Footnote 42] government
contracting officers to determine the adequacy of a contractor's
accounting system before awarding a cost-reimbursement contract. Of the
9 audits of contractor accounting system internal controls that we
reviewed, only two of the audits included sufficient testing to support
DCAA's audit opinion that internal controls over the contractors'
accounting systems were adequate. In addition, none of the 20 audits of
contractor billing system internal controls we reviewed contained
sufficient testing of controls to support the reported opinions.
Adequate opinions on billing system audits are the basis for DCAA
decisions to approve contractors for the direct bill program, whereby
contractors submit invoices directly to a government disbursing office
without prior review.[Footnote 43] Four of the 6 audits of contractor
estimating system controls that we reviewed did not include sufficient
testing to support the reported opinions. DOD requires[Footnote 44]
that large contractors have acceptable estimating systems. Opinions on
contractor estimating systems support DCAA decisions on the extent of
testing performed on contract proposals. Neither of the two internal
control audits of contractor indirect and other direct costs we
reviewed included sufficient testing to support reported opinions. As
shown in figure 1, at the time these audits were performed, DCAA policy
guidance provided for three categories of opinions on internal control
audits. This policy provided for different opinions and criteria for
judging them based on the severity of the problems identified.
Professional standards have long recognized different levels of
severity with regard to reporting deficiencies and material weaknesses
in internal controls.
Figure 1: DCAA Opinions on Contractor Internal Control Systems Audits:
[Refer to PDF for image: illustrated table]
Risk: Low;
DCAA opinion: Adequate;
Criteria: No significant deficiencies were identified in the audit;
Resultant Actions: Scope of future audits will be decreased based on
assurance provided by adequate controls.
Risk: Medium;
DCAA opinion: Inadequate in part;
Criteria: Auditors identified one or more significant deficiencies that
affect parts of the contractor‘s system;
Resultant Actions: Contractor is required to make improvements, and
DCAA is to perform follow-up testing within 6 months. Inadequate in
part opinion also requires expanded audit scopes on future and
concurrent audits until the contractor‘s corrective actions are
confirmed by the auditors.
Risk: High;
DCAA opinion: Inadequate;
Criteria: Auditors identified one or more significant deficiencies that
render the entire contractor system unreliable;
Resultant Actions: Contractor is required to make improvements and DCAA
is to perform follow-up testing within 6 months. Inadequate opinion
requires expanded audit scopes on other audits because controls do not
provide reasonable assurance that data generated by the contractor‘s
system are reliable.
Source: GAO analysis of DCAA policy.
[End of figure]
Supervisors of the DCAA internal control audits we reviewed dropped
auditor findings of significant deficiencies from the audit reports or
treated them as suggestions for improvement without adequate support,
including instances of FAR noncompliance that should have been reported
as material weaknesses. In some cases, auditors reported "inadequate-in
part" opinions when the severity of the deficiencies or material
weaknesses identified would have called for "inadequate" opinions.
On December 19, 2008, DCAA revised its policy to eliminate the
"inadequate-in-part" opinion and the requirement to report suggestions
for improvement.[Footnote 45] The new DCAA policy defines "significant
deficiency/material weakness" as an internal control deficiency that
(1) adversely affects the contractor's ability to initiate, authorize,
record, process or report government contract costs in accordance with
applicable government contract laws and regulations; (2) results in a
reasonable possibility that unallowable costs will be charged to the
government; and (3) the potential unallowable cost is not clearly
immaterial. The new DCAA policy also establishes new guidance on
reporting audit opinions on contractors' internal control systems. For
example, the new DCAA policy states that audit reports that identify
any significant deficiencies/material weaknesses in contractors'
internal control systems will include opinions that the systems are
"inadequate." The policy notes that the contractor's failure to
accomplish any control objective tested in DCAA's internal control
audits will or could ultimately result in unallowable costs being
charged to government contracts, even when the control objective does
not have a direct relationship to charging costs to government
contracts. As an example, the policy notes the control objective
related to ethics and integrity is not directly related to charging
costs to government contracts, but that the contractor's failure to
accomplish the control objective creates an environment that could
ultimately result in mischarging to government contracts.
By eliminating the "inadequate-in-part" opinion, the new policy does
not recognize different levels of severity and could unfairly penalize
contractors whose systems have less severe deficiencies by giving them
the same opinion--"inadequate"--as contractors having material
weaknesses or serious deficiencies that in combination would constitute
a material weakness.
At the time we finalized our draft report for DOD comment, DCAA had
rescinded 18 of the 33 audits of contractor internal controls that we
determined did not contain sufficient testing to meet GAGAS.[Footnote
46] Unreliable audit opinions on contractor internal controls pose a
significant risk because DCAA generally performs these audits on a 2-to
4-year cycle and the audit results are relied on for several years to
make decisions on testing in various audits of contractor internal
controls and cost-related assignments. In response to our earlier
investigation in November 2008, DOD added DCAA audits not meeting
professional standards to its list of material weaknesses.[Footnote 47]
Table 2 provides details on five case studies that are typical of the
flawed internal control audits that we reviewed during the course of
our work. For more detail on the internal control audits we reviewed,
see appendix I.
Table 2: Summary of Five Selected Internal Control Audits:
Case: 1;
Region: Western;
Audit type: Billing system (2004);
Case details:
* DCAA auditors inappropriately planned and performed a billing system
audit of a federally funded research and development center (grantee)
with $1.5 billion in annual funding. The grantee does not have a
"billing system";
* The grantee is funded by a line of credit, which provides for cash
draws and transaction reporting by the grantee's accounting system;
* DCAA auditors spent 530 hours revising Single Audit Act cash
management audit documentation to address procedures required in DCAA's
standard audit program for billing system internal controls and
developed a billing system audit report, when the auditors could have
simply forwarded the results of work on the grantee's cash management
system performed under the Single Audit Act to the federal agency's
buying command;
* As a result of our review, DCAA reassessed the need to perform a
billing system audit for the grantee and determined that it would rely
on the Single Audit reports in the future.
Case: 2;
Region: Western;
Audit type: Accounting system (2004);
Case details:
* This audit involving accounting controls for one of the five largest
DOD contractors working in Iraq was initiated in November 2003;
* In September 2005, after nearly 2 years of audit work, DCAA provided
draft findings and recommendations to the contractor that included 8
significant deficiencies in the contractor's accounting design and
operation;
* The contractor objected to the findings, stating that the auditors
did not fully understand its new policies and procedures, which were
just being developed for the fast track effort in Iraq;
* Following the contractor's objections, various supervisory auditors
directed the auditors to revise and delete some workpapers, generate
new workpapers, and in one case, copy the signature of a prior
supervisor onto new workpapers making it appear that the prior
supervisor had approved a revised risk assessment;
* On August 31, 2006, after dropping 5 significant deficiencies and
downgrading 3 significant deficiencies to suggestions for improvement,
DCAA reported an "adequate" opinion on the contractor's accounting
system without adequate audit evidence for the changes;
* The interim audit supervisor, who instructed the lead auditor to copy
and paste the prior supervisor's name onto key risk assessment
workpapers, was subsequently promoted to be the Western Region's
quality assurance manager where he served as quality control check over
thousands of audits, including those GAO reported on last year;
* In April 2007, the Special IG for Iraq Reconstruction (SIGIR)
reported that despite being paid $3 million to complete the renovation
of a building in Iraq, the contractor's work led to plumbing failures
and electrical fires in a building occupied by the Iraqi Civil Defense
Directorate;
* DCAA rescinded the audit report on December 2, 2008.
Case: 3;
Region: Eastern;
Audit type: Billing system (2005);
Case details:
* In May 2005, DCAA reported an inadequate-in-part opinion on the
billing system internal controls of a second of the five largest DOD
contractors;
* After issuing the report, DCAA auditors helped the contractor develop
policies and procedures related to accounts receivable, overpayments,
and system monitoring before performing a required follow-up audit--a
serious impairment to auditor independence;
* In June 2006, DCAA reported an adequate opinion on the contractor's
billing system internal controls, including the policies and procedures
DCAA helped the contractor develop;
* As a result of GAO's review, DCAA rescinded the follow-up audit
report on March 6, 2009.
Case: 4;
Region: Central;
Audit type: Billing system; (2005);
Case details:
* This audit, which was initiated in July 2005, covered a new billing
system at a business segment of another of the five largest DOD
contractors. Although DCAA considers new systems to be high-risk and
requires increased testing, auditors deleted key audit steps related to
contractor policies and internal controls over progress payments from
the standard audit program without explanation and performed little or
no testing of the contractor's billing controls;
* The contractor objected to requests for documentation to test whether
billing clerks had received necessary training;
* One auditor told GAO he did not perform other tests because "the
contractor would not appreciate it";
* The auditors provided draft findings and recommendations to the
contractor in February 2006 that included six suggestions to improve
the system related to the need for internal audits, oversight of
subcontractor accounting systems, and improvements in policies and
procedures and desk instructions;
* Instead of issuing the report, when audit work was completed and
noting the status of any contractor actions to address identified
control weaknesses, the auditors monitored contractor corrective
actions for 7 months, dropping the two suggestions for improvement
related to internal audits and monitoring subcontractor accounting
systems. The failure to monitor subcontractor accounting systems should
have been considered a significant deficiency;
* On September 15, 2006, DCAA reported an "adequate" opinion on the
contractor's billing system;
* Following GAO's review of this audit, DCAA rescinded the audit report
on February 10, 2009.
Case: 5;
Region: Central;
Audit type: Billing system (2006);
Case details:
* A fraud investigation by the Army's Criminal Investigative Division
was under way at the time DCAA performed this contractor's billing
system audit. The FAO was aware of the substance of the Army's
investigation;
* The auditor requested increases in budgeted audit hours to perform
increased testing because of fraud risk and the contractor's use of
temporary accounts for charging costs that had not yet been authorized
by the contracting officer;
* The auditor drafted an "inadequate" opinion on the contractor's
billing system, which was overturned by the supervisor and FAO manager;
* Despite a reported $2.8 million in fraud for this contractor, DCAA
reported an "inadequate-in-part" opinion related to 3 significant
deficiencies in the contractor's billing system on August 31, 2005, and
an "adequate" opinion on September 11, 2006, related to a follow-up
audit;
* The auditor, whose performance appraisal was lowered for performing
too much testing and exceeding budgeted audit hours, was assigned to
and then removed from the follow-up audit. The auditor left DCAA in
March 2007;
* Following GAO's review, DCAA rescinded both audit reports on November
20, 2008.
Source: GAO analysis of DCAA audit documentation and auditor
interviews.
[End of table]
Cost-Related Assignments:
The 32 cost-related assignments we reviewed did not contain sufficient
testing to provide reasonable assurance that overpayments and billing
errors that might have occurred were identified. As a result, there is
little assurance that any such errors, if they occurred, were corrected
and that related improper contract payments, if any, were refunded or
credited to the government. Contractors are responsible for ensuring
that their billings reflect fair and reasonable prices and contain only
allowable costs, and taxpayers expect DCAA to review these billings to
provide reasonable assurance that the government is not paying more
than it should for goods and services. Further, we found that DCAA does
not consider some cost-related assignments to be GAGAS audits, even
though these assignments are used to provide assurance of the
reasonableness of contractor billings, for example:
Paid voucher reviews. DCAA performs annual testing of paid vouchers
(invoices) to determine if contractor voucher preparation procedures
are adequate for continued contractor participation in the direct-bill
program.[Footnote 48] Under the direct-bill program, contractors may
submit their invoices directly to the DOD disbursing officer for
payment without further review. Although DCAA does not consider its
reviews of contractor paid vouchers to be GAGAS engagements; it has not
determined what standards, if any, apply to these assignments. In
addition, for the 16 paid voucher assignments we reviewed, we found
that DCAA auditors failed to comply with CAM guidance.[Footnote 49]
Rather than documenting the population of vouchers, preparing sampling
plans, and testing a random (statistical) sample, auditors generally
did not identify the population of vouchers, did not create sampling
plans, and made a small, nonrepresentative selection of as few as one
or two invoices for testing to support conclusions on their work. Even
when DCAA auditors tested 20 or 30 invoices, they did not test billing
controls or review supporting documentation for goods and services
purchased. Instead, the auditors performed limited procedures such as
determining whether the vouchers were mathematically correct and
included current and cumulative billed amounts. Based on this limited
work, the auditors concluded that controls over invoice preparation
were sufficient to support approval of the contractors' direct billing
privileges. However, the limited work performed does not provide
assurance that contractor billings are accurate and comply with
applicable laws, the FAR, CAS, and contract terms. This is of
particular concern because we determined that Defense Finance and
Accounting Service (DFAS) certifying officers rely on DCAA voucher
reviews, and they do not repeat review procedures they believe to be
performed by DCAA.
Professional literature contains guidance to help auditors determine
the level of testing that should be performed to obtain sufficient,
appropriate evidence to support a conclusion that internal controls are
effectively designed, implemented, and operating effectively. Inquiry
alone does not provide sufficient, appropriate evidence to support a
conclusion about the effectiveness of a control. Some of the factors
that affect the risk associated with a control include:
* the nature and materiality of misstatements that the control is
intended to prevent,
* the inherent risk associated with the related account(s) and
assertion(s),
* whether there have been changes in the volume or nature of
transactions that might adversely affect control design or operating
effectiveness,
* the degree to which the control relies on the effectiveness of other
controls (i.e., information technology controls),
* the competence of personnel who perform the control or monitor its
performance, and whether there have been changes in key personnel who
perform the control or monitor performance, and:
* whether the control relies on performance by an individual or is
automated (an automated control would generally be expected to be lower
risk if relevant IT general controls are effective).[Footnote 50]
Professional standards[Footnote 51] state that the auditor should focus
more attention on the areas of highest risk. As the risk associated
with the control being tested increases, the evidence that the auditor
should obtain increases. In addition, the GAO/PCIE Financial Audit
Manual provides guidance on sampling control tests that would be
relevant to DCAA testing of contractor invoices.[Footnote 52] The
auditor should assess risk in determining the control attributes to be
tested and select a sample that the auditor expects to be
representative of the population. Attribute sampling requires random or
systematic, if appropriate, selection of sample items without
considering the transactions' dollar amount or other special
characteristics. To determine the sample size, the auditor uses
professional judgment to determine three factors--confidence level,
[Footnote 53] tolerable rate (maximum rate of deviations from the
prescribed control that the auditor is willing to accept without
altering the preliminary control risk), and expected population
deviation rate (expected error rate).[Footnote 54]
Finally, the American Institute of Certified Public Accountants (AICPA)
Audit and Accounting Guide: Audit Sampling[Footnote 55] (Audit Guide)
contains attestation guidance on the application of SSAEs in specific
circumstances, including engagements for entities in specialized
industries. The Audit Guide states that an auditor using nonstatistical
sampling is not required to compute the sample size using statistical
theory. However, sample sizes of statistical and nonstatistical samples
ordinarily would be comparable when the same sampling parameters are
used.[Footnote 56]
Overpayment assignments. DCAA intends these audits to verify that
contractors have billing procedures and internal controls in place to
identify and resolve contractor overpayments in a timely manner. DCAA
guidance states that these engagements should be conducted in
accordance with GAGAS to the extent applicable under the circumstances.
[Footnote 57] However, none of the 10 overpayment assignments we
reviewed were performed or reported as GAGAS engagements. We found that
auditor judgments about the population and selection of transactions
for these assignments did not provide a representative basis for
testing and concluding on contractor controls over billings and
payments received. For example, for the 10 assignments we reviewed, the
auditors selectively reviewed an accounts receivable aging report to
identify overpayments and determine if they had been resolved. The
auditors did not attempt to identify the population of transactions
subject to overpayments and over billings during the year, and they did
not document their rationale for selecting a particular dollar
threshold, number of transactions, or time period for testing
contractor invoices. Our assessment of these assignments includes the
same concerns regarding insufficient evidence to support the auditors'
conclusions as discussed above for annual testing of paid vouchers. As
a result, this work does not provide reasonable assurance that
contractors have adequate controls in place to identify and correct
overpayments and billing errors and make appropriate, timely refunds
and adjustments.
Incurred cost audits. The purpose of incurred cost audits is to examine
contractors' cost representations and opine on whether the costs are
allowable, allocable to government contracts, and reasonable in
accordance with the contract and applicable government acquisition
regulations.[Footnote 58] DCAA performs these audits as GAGAS
attestation engagements. For the four incurred cost audits we reviewed,
we found that the auditors did not adequately document their judgments
about control risk or the sampling and test methodologies used. In
addition, we found that the auditors traced claimed pool and base costs
(indirect costs) to the contractor's accounting books and records to
determine their accuracy and allowability. However, the auditors did
not perform sufficient, detailed testing of support for claimed
indirect and direct costs. The scope of work performed was not
sufficient to identify claimed costs, if any, that were not adequately
supported or unallowable costs, if any, that should have been
questioned.
In addition to the testing failures we identified on the 32 cost-
related assignments, several additional issues came to our attention
during our review:
Exempting from professional standards certain assignments that were
used as support for internal control system audits. We noted that paid
voucher reviews and overpayment assignments, which were used to support
direct-bill decisions and billing system audits, were not performed
under GAGAS, even though some of them used the same terminology as
GAGAS engagements to describe the work performed, including
"comprehensive examination" and "audit." According to DCAA's CAM and
DCAA officials, paid voucher reviews and most overpayment assignments
are not intended to meet GAGAS standards. However, paid voucher reviews
are intended to serve as audits of contractor payments, and DCAA's
standard audit program for overpayment assignments states that the
assignments are to be performed in accordance with GAGAS, unless there
are specific exceptions. When these types of assignments are not
conducted under professional standards, it is important for the report
to clearly state the procedures performed and the intended uses of the
report, such as verifying compliance with certain FAR requirements, in
order to provide context for understanding the stated conclusions of
the work and avoid misleading users of the report.
Auditor objectivity issues. We also determined that DCAA's role with
regard to making decisions to approve contractors for participation in
the direct-bill program[Footnote 59] presented an impairment to auditor
objectivity--which includes being independent in fact and appearance
when providing audit and attestation engagements.[Footnote 60] The
objectivity impairment relates to DCAA's audit role in authorizing
contractors to participate in the direct-bill program, which places it
in the position of making decisions that impact its nonaudit workload
related to the review of contractor invoices prior to payment. For
example, when contractors do not have direct billing privileges, DCAA
acts as the authorized representative of the DOD contracting officer in
reviewing contractor invoices prior to submission for payment. However,
if DCAA auditors determine that a contractor has an adequate billing
system, DCAA may authorize a contractor to participate in the direct-
bill program, thereby eliminating workload related to review of the
contractor's invoices prior to payment. In addition, the 20 billing
system audits and follow-up audits we reviewed lacked sufficient
testing to support reported opinions, or the opinions reported were
inconsistent with the audit evidence. DCAA had approved all but 2 of
the 16 contractors involved in these audits for the direct bill
program.
At the end of our audit, DCAA had not rescinded any of the memorandums
or reports on the results of the cost-related assignments we reviewed.
Table 3 provides details on five selected case studies of flawed cost-
related assignments that we reviewed during the course of our work.
Table 3: Summary of Five Selected Cost-Related Assignments:
Case: 1;
Region: Eastern;
Type of assignment: Paid voucher review (2004); Non-GAGAS;
Case details:
* This contractor generates $1.1 billion in annual billings to the
government;
* The auditor assessed risk as low for this assignment without
documenting the basis for the decision. The auditor then judgmentally
selected 3 vouchers totaling $88,000 for testing out of a total of 222
vouchers submitted to the government for payment from March 2003
through February 2004;
* The auditor tested the first voucher selected and performed limited
testing on the remaining 2 vouchers. The workpapers do not include any
evidence to show that the auditor performed most of the audit steps
required in the standard audit program;
* Despite limited testing, on March 31, 2004, DCAA prepared a
Memorandum for the Record, stating "continued reliance can be placed on
the contractor's procedures for the preparation of interim vouchers..."
and "the contractor has met the criteria for continued participation in
the direct billing program."
Case: 2;
Region: Mid-Atlantic;
Type of assignment: Paid voucher review (2004); Non-GAGAS;
Case details:
* In 2004, DCAA reviewed interim vouchers submitted by a contractor
with $40 million in annual sales;
* The auditor chose a nonrepresentative selection of 3 vouchers
totaling $621,000 from a 3-month period. The auditor should have used a
population covering a 12-month period because this assignment was
designed to cover a 1-year period;
* The auditor did not document the sample selection methodology as
required by DCAA's CAM. Although testing of 3 vouchers is not
sufficient to support a conclusion on the effectiveness of the
contractor's controls over preparation of interim vouchers, the auditor
removed one of the 3 vouchers from testing and did not document a
reason;
* The auditor did not identify any errors in testing the two remaining
vouchers;
* On August 31, 2004, DCAA reported "continued reliance can be placed
on the contractor's procedures for the preparation of interim vouchers"
and "the contractor had met the criteria for continued participation in
the direct billing program."
Case: 3;
Region: Western;
Type of assignment: Paid voucher; review (2005); Non-GAGAS;
Case details:
* This DOD contractor with over $1 billion in annual billings to the
government was one of several contractors that performed work to
support the FBI's Trilogy investigative systems upgrade project;
* The auditor tested less than 20 vouchers of 5,530 vouchers issued in
a 12-month period;
* On April 14, 2005, DCAA issued a Memorandum for the Record, stating
"continued reliance can be placed on the contractor's procedures for
the preparation of interim vouchers" and "the contractor has met the
criteria for continued participation in the direct-bill program;
* One year later, a GAO audit report revealed that during the time of
this DCAA assignment, the contractor had over billed the FBI by over
$400,000 in labor and improper first-class travel costs.
Case: 4;
Region: Central;
Type of assignment: Overpayment assignment (2005); Non-GAGAS;
Case details:
* This DCAA assignment covered one of the five largest DOD contractors;
* The auditor tested 4 transactions from a listing of potential
underpayments and overpayments prepared by the contractor. The auditor
did not independently verify the accuracy or completeness of the
contractor's listing;
* The audit program required the auditor to determine whether the
contractor monitors the billings submitted by its top 3 to 5
subcontractors. However, the auditor performed this procedure for only
1 subcontractor based on "auditor judgment" and did not document the
basis for this judgment in the audit documentation;
* The auditor also relied on the unverified contractor-provided listing
to identify refunds to the government. The auditor then "judgmentally
selected" 2 refunds for testing from the contractor's listing;
* The auditors' conclusions that the contractor's controls are
sufficient to detect and correct billing errors and overpayments were
not supported by sufficient testing or other independent evidence.
Case: 5;
Region: Western;
Type of assignment: Incurred cost; audit (2004); GAGAS;
Case details:
* This audit covered a $516 million incurred cost claim submitted by a
contactor performing reconstruction work in Iraq;
* The auditors reported about $6 million in questioned costs and about
$83 million in unsupported costs based on assist audits (portions of
the audit performed by other FAOs) that had not been received by the
report issue date;
* Although the auditors charged 2,292 hours to this assignment, GAO
determined that the auditors did not perform sufficient work to support
the audit opinion. For example, the auditors traced claimed pool and
base costs to the contractor's accounting books and records using a
threshold of $5 million for cost-type contracts and $2 million for time
and materials contracts, but did not perform detailed testing of
support for transactions. Tracing amounts to the general ledger is not
sufficient work to support an examination-level opinion and the
auditors did not document the basis for the judgment used to determine
the multimillion dollar thresholds;
* Further, the auditors relied on testing performed in a related
accounting system audit, which DCAA rescinded on December 2, 2008, in
response to GAO concerns;
* As a result, the auditor's risk assessment used to plan the incurred
cost audit is no longer supported.
Source: GAO analysis of DCAA audit documentation and auditor
interviews.
[End of table]
We did not attempt to re-perform these assignments to find out whether
actual overpayments or billing errors existed. For additional details
on the cost-related assignments we reviewed, see appendix II.
Poor Management Environment and Quality Assurance Structure at DCAA
Impacted Audit Quality:
We found that a management environment and agency culture that focused
on facilitating the award of contracts and an ineffective audit quality
assurance structure are at the root of the agencywide audit failures we
identified. DCAA's mission and management goals focus on producing a
large quantity of audits to support procurement and contract
administration rather than assuring proper contract costs that help
save taxpayer dollars. In addition, an ineffective audit quality
control system and a "clean" peer review opinion compounded the
problem, hindering DCAA management from identifying and correcting
agencywide audit quality problems.
DCAA's Mission Statement and Strategic Plan Do Not Focus on the Public
Interest:
DCAA's current mission statement does not address protecting the public
interest in the manner in which it carries out audits to help assure
that contractors charge fair and reasonable prices that comply with
applicable laws and regulations, cost accounting standards, and
contract terms. Instead, DCAA's mission statement calls for it to
perform all necessary contract audits for DOD and provide accounting
and financial advisory services regarding contracts and subcontracts to
all DOD components responsible for procurement and contract
administration. Similarly, DCAA's 2006 strategic plan focused on
various processes and outputs. DCAA's strategic plan contains the
following five strategic goals with targeted completion dates from 2006
through 2008:
1. fostering a quality work-life environment that promotes trust,
teamwork, mutual respect, superior job performance and high morale;
2. assuring customer satisfaction by providing timely and responsible
audits and financial services that meet or exceed customer requirements
and expectations;
3. attaining the highest level of professional competence through
continuous improvement in the management and performance of audits and
services;
4. providing best value audit and financial services through continuous
evaluation and improvement of audit and administrative processes; and:
5. providing an integrated information technology structure that
promotes effectiveness and efficiency in providing services for
internal and external customers.
DCAA objectives under each strategic goal focus on process improvements
and do not contain a clear plan for achieving the respective goal or
adequate quantitative and qualitative measures for determining success,
for example:
* One DCAA quality of work-life objective is to assess whether the
participative work team concept is the best model for facilitating
continuous process improvement. The underlying activities include
internal meetings and brainstorming sessions, literature reviews, and
developing recommendations for executive committee review. None of the
activities included refer to identifying best practices or working with
outside experts.
* Another objective is to hold or lower attrition in high turnover
areas. DCAA activities in this area include analyzing causes of
attrition, and conducting surveys of new hires and departing employees.
None of the related activities include surveys of like organizations,
consideration of best practices, or identifying and addressing causes
of high attrition. Moreover, in response to our requests for attrition
data, DCAA provided high-level summaries without any analysis.
* DCAA's strategic goal for customer satisfaction, included the
objective of increasing by 20 percent annually the number of incurred
cost audit reports issued with contractor cumulative allowable cost
worksheets, completing 100 percent of identified incurred cost audits
necessary to accomplish Defense Contract Management Agency (DCMA)
performance goals for contract close-out and canceling funds.[Footnote
61] DCAA's strategic plan contains no explanation of the importance of
these objectives or how they link to DCAA's mission.
* A key goal related to best value audit services is for DCAA to manage
its cost per direct audit hour at a level sufficient to maintain DCAA's
competitive advantage over the comparable national public firm
composite rate. One of the ways DCAA has achieved a low cost per audit
hour is to maintain a pay structure that caps journey-level auditors at
the GS-12 level. In addition, our work identified numerous instances
where entry-level auditors with little or no experience often perform
audit assignments by themselves. However, lower grade levels and
limited experience can place auditors at a disadvantage when dealing
with contractor officials.
The Government Performance and Results Act of 1993 (GPRA)[Footnote 62]
directed federal agencies to shift their focus from traditional
concerns of staffing and activity levels to a broad focus on outcomes
or results by (1) defining a clear mission and desired outcomes instead
of outputs, (2) measuring performance to gauge progress, and (3) using
performance information as a basis for decision making. The act
required agencies to meet with Congress and key stakeholders to clearly
define their mission and develop long-term strategic goals as well as
annual goals that were linked to them. Although these legislated
requirements were directed at federal agencies, including DOD, DCAA's
mission statement and strategic plan were not revised to conform to
GPRA requirements.
Performance Metrics Were Designed To Measure Output:
GPRA also requires that once federal agencies establish their strategic
goals they are to develop results-oriented measures for assessing
performance in meeting those goals and publicly report on how well they
are doing. However, most of DCAA's performance metrics continued to
focus on output. Several DCAA managers noted that fear of outsourcing
the contract audit function led DCAA to emphasize performance metrics
that demonstrated high productivity and low cost. In fiscal year 2008,
DCAA reported some results-oriented performance measures, such as
return on investment and net savings related to questioned cost.
However, most of DCAA's metrics focused on production and audit cost,
including cost per direct audit hour, 30-day cycle time on forward
pricing audits, and dollars audited per hour. In addition, DCAA's focus
on completing over 30,000 assignments annually with about 3,600
auditors continued to emphasize production of audits instead of
performing quality audits that assured taxpayers that the government
was paying fair and reasonable prices for contracted goods and
services.
DCAA's Audit Quality Assurance Program Was Ineffective:
DCAA's audit quality assurance program was not properly implemented,
resulting in an ineffective quality control process that accepted
audits with significant deficiencies and noncompliance with GAGAS and
DCAA policy. Moreover, even when DCAA's quality assurance documentation
showed evidence of serious deficiencies within individual offices,
those offices were given satisfactory ratings. GAGAS require that each
audit organization performing audits and attestation engagements in
accordance with GAGAS should have a system of quality control that is
designed to provide the audit organization with reasonable assurance
that the organization and its personnel comply with professional
standards and applicable legal and regulatory requirements, and have an
external peer review at least once every 3 years.[Footnote 63]
Our analysis of DCAA audit quality review documentation for 14 of 48
offices covered in audit quality reviews during fiscal years 2004
through 2006--the period covered in the last DOD OIG peer review--found
that although DCAA gave satisfactory ratings to 13 of the 14 FAOs, DCAA
reviewers reported that 10 of these offices had 2 or more instances of
serious GAGAS noncompliance, including inadequate planning, lack of
proper supervision, and insufficient support for reported conclusions
and opinions. However, DCAA gave only 1 of the 14 FAOs reviewed an
unsatisfactory rating. The failed FAO had 5 of 9 assignments reviewed
with at least two significant instances of noncompliance with GAGAS or
DCAA policy. Further, although DCAA headquarters performed a follow-up
review to confirm that problems identified at the failed office were
corrected, DCAA headquarters officials told us they did not perform
follow-up reviews to assure that the problems identified at other
offices were corrected.
In response to a DOD IG finding that DCAA quality assurance reviews did
not cover a sufficient number of internal control system audits, DCAA
increased the number of audits covered to date in its fiscal year 2007
and 2008 quality assurance reviews. However, DCAA continued to
inappropriately conclude that audits "demonstrated professional
judgment," allowing reviewers to disregard serious deficiencies with
GAGAS in concluding on overall audit quality.[Footnote 64] DCAA failed
only 1 of the 40 FAOs as a result of its fiscal year 2007 and 2008
audit quality reviews. Our analysis of DCAA's audit quality results
showed that 19 of the 40 FAO's had two or more audits with at least 2
instances of significant noncompliance with GAGAS or DCAA policy.
However, 18 of these FAOs received a satisfactory rating. DCAA
headquarters has not yet followed up with offices that had deficient
audits.
The examples in table 4 show the disparity between DCAA quality
assurance reports of a "satisfactory level of compliance" and actual
results documented by quality assurance reviewers. The examples below
also illustrate the long-term nature of this problem.
Table 4: Summary of Selected DCAA Audit Quality Review Results:
Region: Eastern;
Number and type of audits: 5 incurred cost audits;
DCAA audit quality review conclusions and findings: On October 28,
2008, DCAA reported a satisfactory level of compliance for the FAO
reviewed. Supporting documentation showed that reviewers found that 2
of 5 audits reviewed had at least 2 instances of significant
noncompliance with GAGAS and DCAA policy, including insufficient
supervisory involvement and inadequate workpaper documentation to
support significant auditor judgments and conclusions.
Region: North-eastern;
Number and type of audits: 8 forward pricing audits;
DCAA audit quality review conclusions and findings: On September 27,
2007, DCAA reported satisfactory compliance by the FAO reviewed.
Supporting documentation showed that reviewers found that 4 of 8 audits
had at least 2 significant instances of noncompliance with GAGAS or
DCAA policy and 2 of the 4 audits had 3 instances of noncompliance,
including inadequate planning and supervision and failure to exercise
reasonable professional judgment.
Region: Central;
Number and type of audits: 8 other (various) assignments;
DCAA audit quality review conclusions and findings: On April 4, 2006,
reviewers gave the FAO reviewed a satisfactory rating. However,
supporting documentation showed that audit quality reviewers found that
2 of 8 assignments had at least two significant deficiencies related to
noncompliance with GAGAS and DCAA policy, including inadequate planning
on 3 assignments and inadequate supervision on 2 assignments. Reviewers
also determined that the auditor on one other assignment had not met
the annual requirement for continuing professional education.
Region: Western;
Number and type of audits: 5 incurred cost audits;
DCAA audit quality review conclusions and findings: On April 26, 2005,
reviewers gave the FAO a satisfactory rating. Although the audit
quality review documentation identified only 1 audit that had at least
2 instances of significant deficiencies, the documentation noted
limited testing and stated that statistical sampling was not used, as
required. The reviewers also found that audit working papers did not
support the conclusions in the audit report. The reviewers noted that
insufficient supervisory involvement was responsible in part for the
deficiencies found in the audit.
Region: Mid-Atlantic;
Number and type of audits: 6 incurred cost audits;
DCAA audit quality review conclusions and findings: On September 29,
2005, reviewers reported a satisfactory level of compliance for this
FAO. However, supporting documentation showed that 4 of the 6 audits
had at least 2 significant deficiencies related to noncompliance with
GAGAS and DCAA policy. For example, audit quality reviewers noted that
the risk assessment for one assignment inappropriately stated the
contractor's accounting system was adequate. In addition, reviewers
stated that conclusions and opinions in reports for three audits were
not based on sufficient evidence. Reviewers also noted that three
audits had significant deficiencies, including insufficient testing,
inadequate procedures to identify illegal acts and noncompliance with
laws and regulations, and reporting problems. Reviewers also found
inaccuracies in reporting on three audits and stated that reports on 2
of the audits should not have been issued and a reported qualification
in the report for the third audit was worded incorrectly and implied
that work had been performed when the related assist audits had not
been completed.
Region: Eastern;
Number and type of audits: 6 internal control audits;
DCAA audit quality review conclusions and findings: On June 8, 2004,
DCAA reported satisfactory compliance by the FAO reviewed. However,
supporting documentation showed that 2 of 6 audits reviewed had at
least 2 instances of significant noncompliance with GAGAS and DCAA
policy, including inadequate supervision, missing workpapers on the
contractor's control environment, and insufficient and incomplete
workpaper evidence to support conclusions in the audit reports.
Region: Northeastern;
Number and type of audits: 8 forward pricing audits;
DCAA audit quality review conclusions and findings: On June 26, 2003,
DCAA reviewers reported satisfactory level of compliance by the FAO
reviewed. Audit quality review documentation showed that reviewers
found that 6 of the 8 audits had at least 2 instances of significant
GAGAS or DCAA policy noncompliance. For example, 2 audits were not
adequately planned and 4 audits had inadequate supervisory involvement.
In addition, supervisory review was performed 10 days after the report
was issued on one audit, and audit work did not support the reported
opinion on a second audit.
Source: GAO analysis of DCAA documentation.
[End of table]
In March 2009, DCAA officials advised us that going forward, DCAA plans
to report all audit quality review findings along with recommendations
for corrective action and follow-up to assure that FAOs have taken
appropriate corrective action.
DOD IG Peer Review Opinion on DCAA's Audit Quality Control System Is
Inconsistent with the Underlying Deficiencies Reported:
The DOD IG reported an adequate ("clean") opinion on DCAA's most recent
peer review results although the reported evidence indicated that
numerous audits had serious deficiencies in audit quality.[Footnote 65]
In conducting DOD's audit oversight review of DCAA audits for fiscal
year 2006, DOD IG audit oversight reviewers considered the same results
of DCAA's internal audit quality assurance reviews that we analyzed and
reviewed numerous additional audits, which also identified significant
GAGAS noncompliance as evidenced by DOD IG peer review findings and
recommendations. Although the DOD IG report contained evidence of
significant, systemic noncompliance with professional standards
throughout DCAA audits that OIG staff reviewed, and the IG report
included numerous findings and recommendations related to those issues,
the DOD IG gave DCAA a "clean" peer review opinion,[Footnote 66]
concluding that:
"In our opinion, the DCAA system of quality control for audits and
attestation engagements performed during the FY ended September 30,
2006, was designed in accordance with quality standards established by
Government Auditing Standards (GAS). Further, the internal quality
control system was operating effectively to provide reasonable
assurance that DCAA personnel were following established policies,
procedures, and applicable auditing standards. Accordingly, we have
determined that the DCAA system of quality control used on audits and
attestation engagements for the review period ended September 30, 2006,
is adequate."
The overall report conclusion in the DOD IG report is not consistent
with the detailed observations in the report, which indicate numerous
significant deficiencies in DCAA's system of quality control.
Furthermore, based on DCAA's actions to rescind dozens of audit reports
[Footnote 67] related to our prior investigation and this audit and our
analysis of DCAA's internal audit quality review procedures and
documentation--all of which relate to the period covered by the DOD IG
peer review--we concluded that DCAA's quality control system for the
period covered by the last DOD IG peer review was not effectively
designed and implemented to provide assurance that DCAA and its
personnel comply with professional standards. The DCAA audits performed
during fiscal years 2007 and 2008 were performed under the same policy
guidance and production-related performance metrics as the earlier
audits and had the same types of GAGAS noncompliance, as indicated by
DCAA's internal audit quality review findings for audit reports issued
in fiscal years 2007 and 2008.
DCAA Lacks a Risk-Based Audit Planning Approach:
In the absence of a risk-based audit planning approach, DCAA has
historically performed 30,000 to 40,000 audits annually to support
contracting community decisions on contract awards, administration, and
close-out using 3,000 to 4,000 auditors--an average of about 10 audit
reports per year for each auditor. The large number of assignments has
contributed to the production-oriented environment and widespread
problems we have identified with audit quality. The failure to perform
quality audits leaves government contracting officers and disbursing
officers with inadequate information, ultimately putting taxpayers at
risk of improper contract payments and fraud, waste, abuse, and
mismanagement. GAO's Standards for Internal Control in the Federal
Government[Footnote 68] require federal agency managers to identify and
assess relevant risks the agency faces from external and internal
sources associated with achieving agency objectives, such as those
defined in strategic and annual performance plans developed under the
GPRA. To do this, management needs to consider all significant
interactions between the entity and other parties as well as internal
factors at the agency and activity levels. The specific risk analysis
methodology used can vary by agency because of differences in agency
missions and the difficulty in qualitatively and quantitatively
assigning risk levels. For example, DCAA would need to consider
requirements in law and federal regulation to audit contractor cost,
price, schedule, systems, and compliance with laws, regulations, cost
accounting standards, and contract terms. DCAA also would need to
consider risks associated with contractor activity and the materiality
of contractor costs. Once risks have been identified, sound management
controls require that they should be analyzed for their possible
effect, and management should decide how to manage the risk and what
actions should be taken.
A risk-based audit approach would help identify and prioritize which
audits are the most important or have the highest return on investment
and determine what constitutes appropriate testing for various audit
and nonaudit services. Basing future audit plans on historical DCAA
audit hour data is problematic because DCAA has not yet determined the
time and effort that would be needed to perform quality audits. For
example, historical audit hour data do not accurately reflect either
the time needed to complete a quality audit or the hours actually
worked on various audits because many auditors performed limited
procedures or they performed audit procedures on their own time to meet
budgeted audit hour metrics. In addition, some audits may not be
necessary. For example, we concluded that 3 of the 37 internal control
audits that we reviewed were not necessary. For one of the three
audits, DCAA could have relied on the audit of a grantee that was
performed under the Single Audit Act.[Footnote 69] DCAA agreed with our
conclusion. Two other unnecessary audits involved estimating systems of
contractors that only have one contract with the government. Because
contract proposals, which would be tested as part of the estimating
system audit for these contractors, are separately audited when they
are submitted, we questioned the need for separate estimating system
audits for these contractors. DCAA officials told us they would
reconsider the need for separate estimating system audits in such
cases.
Developing a risk-based audit approach that considers the risk of
improper contract payments and available resources would also be a
first step in determining the level of audit resources and training
needed to accomplish effective contract audits. In addition,
determining appropriate roles and responsibilities for nonaudit
assignments would further clarify DCAA audit resource needs as well as
needed job skills and funding for buying commands and DCMA.
The most pervasive audit deficiency we identified was insufficient
testing to support DCAA's reported conclusions and opinions. Limited
audit testing was directly related to DCAA's goal of performing 30,000
or more audit assignments annually. Achieving a goal of performing
quality audits will depend, in part, on appropriate guidance on testing
coupled with adequate training and supervision. Quality audits will
also be dependent upon contracting community support of a risk-based
audit approach and an appropriate delegation of nonaudit contract
administration activities and audit responsibilities among DCMA, buying
commands, and DCAA. As noted above, DCAA provides nearly all of its
services to the contracting and finance communities as GAGAS audits.
However, a risk-based audit approach may require these communities to
re-evaluate whether all such services should be provided as audits and
whether DCAA, as an independent audit organization would perform any
nonaudit services.
DCAA Lacks Effective Human Capital Management:
DCAA's deficiencies in audit quality are directly related to its human
capital management. Effective, efficient contract audits and oversight
are dependent on a workforce that has the required skills to meet
organizational goals and perform quality audits that serve the public
interest, especially the taxpayer. Both GAGAS and GAO's Internal
Control Standards[Footnote 70] require that personnel possess and
maintain a level of competence that allows them to accomplish their
assigned duties. GAGAS specifically requires that the staff assigned to
conduct audit or attestation engagements under GAGAS must collectively
possess the technical knowledge, skills, and experience necessary to be
competent for the type of work being performed before beginning that
assignment.[Footnote 71] GAGAS also requires attestation engagements to
be properly supervised.[Footnote 72] Accordingly, agency management has
a responsibility to identify appropriate knowledge and skills needed
for various jobs and provide needed training, as well as candid and
constructive counseling, and performance appraisals. DCAA's human
capital management practices of hiring auditors at the entry-level and
assigning them to complex audits with little classroom training or on-
the-job experience and minimal supervision have contributed to the
audit problems we identified.
Inadequate training and supervision. DCAA headquarters officials
acknowledged that the agency could improve developmental training and
that it does not have continuing training for DCAA auditors throughout
their career, referred to by DCAA as life-cycle training. Given the
complexity of contract audits and identified DCAA audit quality
problems, timely and effective training and appropriate supervision are
critical to achieving effective audits. Auditors also should understand
the professional standards they are required to follow.
In addition, we found that on-the-job-training and supervision, which
are key components of developmental training, were not consistently
provided to new auditors. On-the-job training for new auditors varied
by supervisor and by DCAA field office. For example, we previously
reported[Footnote 73] that one of the offices in our hotline
investigation had addressed this training need by assigning one
supervisor to oversee trainee auditors and assigning trainee auditors
to senior auditors who provided them on-the-job training during a
particular audit. However, we identified 13 CAS compliance audits at
this same office to which trainee auditors were assigned with little or
no training or supervision. In addition, documentation for one of the
team performance awards that we recently obtained from this office
contained evidence that some trainee auditors were immediately given an
audit assignment to carry out on their own. The performance award
documentation stated as an achievement that "new hires were purposely
assigned their own assignments as early as deemed appropriate in order
to instill in them early the concept that they are responsible for the
planning and conduct of their assigned audits. The supervisory and
senior auditor—made a conscious decision to do this to avoid dependency
issues with the new auditors."
Our discussions with auditors in DCAA's 5 regions provide anecdotal
examples of the training problems we found. For example, one auditor
told us that entry level training is a "one-size-fits-all" approach
that does not provide the right training at the right time, while four
auditors told us they were not given enough time to develop their
skills. One consistent comment from auditors was that on-the-job
training was key to auditor effectiveness, but DCAA provided little or
no opportunity for new auditors to obtain this developmental
experience. Several auditors told us that trainees in their offices are
given assignments to do on their own and that while trainees may work
with a senior level auditor, sometimes these senior auditors do not
take a leadership role that would provide a learning experience for
trainees. In addition, several auditors described DCAA's internal
training courses as "good," but noted that the courses covered high-
level conceptual and technical information and did not provide the
detailed knowledge on how to apply this information when performing a
particular contractor audit. Some FAO managers share this concern.
Supervisors responsible for deficient audits identified in GAO's prior
investigation were promoted. At the September 2008 hearing, Committee
Members expressed concerns about DCAA promotions of supervisors who
were responsible for improperly dropped audit findings, unsubstantiated
changes in audit opinions, and abusive management actions against
whistleblowers at locations covered in our investigation. Best
practices of leading organizations making organizational and cultural
changes include top leadership who set the direction, pace, and tone
and provides a clear, consistent rationale that unites staff together
behind a single mission. Agency management plays a key role by setting
and maintaining the organization's ethical tone, providing guidance for
proper behavior, removing temptations for unethical behavior, and
providing discipline, when appropriate. Our review of GAO hotline
allegations received since our investigation showed that meeting
metrics related to producing reports within budgeted hours and planned
time frames resulted in performance awards for auditors who performed
deficient audits with little or no testing and lower performance
ratings and personnel actions that resulted in downgrades and
termination of auditors who did not meet these metrics. Further, our
analysis of performance appraisals and performance award information
for auditors and supervisors at the location in our investigation where
supervisors had been promoted[Footnote 74] showed that the supervisory
auditors responsible for deficient audits at this location were
rewarded with high performance appraisals, cash awards, and promotions.
We obtained performance evaluations and performance award documentation
for auditors and supervisors involved with 12 audits that had serious
deficiencies at the first location we investigated in our prior work.
The DCAA Director told us that there are legal issues associated with
holding employees, such as the supervisory auditors, accountable for
actions that were identified after-the-fact. However, the two
supervisory auditors responsible for the deficient audits were approved
for promotion even though Western Region managers who made promotion
decisions were aware of the GAGAS compliance problems. DCAA's Western
Region management had received the DOD IG's January 24, 2007,
memorandum of investigation covering 10 audits performed at this
location that did not meet GAGAS. Further, during the summer of 2007,
Region management was responding to issues identified in our hotline
investigation, which mirrored the IG's concerns and raised concerns
about GAGAS compliance with four additional audits. Despite these
findings, we found no evidence that supervisors and auditors who did
not follow GAGAS and DCAA policy were disciplined, counseled, or
required to take additional training. Instead, our review of
performance appraisal and awards documentation showed that the
supervisors and auditors responsible for the deficient audits received
performance appraisals ranging from "exceeds fully successful" to
"outstanding" along with numerous cash awards. One of the two
supervisors responsible for inappropriate decisions to drop audit
findings and change opinions without supporting evidence was promoted
on October 14, 2007, and the second supervisor was selected for
promotion on July 25, 2008--3 days after our investigative report was
issued. DCAA placed a hold on the second supervisor's promotion pending
further investigation. In addition, a senior auditor who dropped audit
findings without support at the direction of the second supervisor was
promoted to a supervisory auditor position on January 6, 2008. In
contrast, the performance appraisal of the senior auditor witness from
that office who testified at the Committee's September 2008 hearing was
lowered two levels from "outstanding" to "fully successful" following
the submission of her hotline complaint, and she received no cash
awards. DCAA has rescinded all 12 audit reports and re-performed the 12
audits associated with our investigation at this field location.
Allegations about abusive management actions have continued. We found
that DCAA's current organization is highly decentralized, fostering a
culture of region autonomy. Within this culture, DCAA's Western Region
appears to have continuing problems with unresolved allegations of
abusive management actions. For example, 21 of the 34 DCAA hotline
allegations we received since our July 2008 report,[Footnote 75]
include examples of abusive management actions, such as auditors being
penalized for attempting to perform what they believe was sufficient
testing to support audit opinions and auditors not completing work
within established timeframes. Nine of these 21 allegations relate to
DCAA's Western Region--the subject region in our prior hotline
investigations. Seven of the 9 allegations relate to current problems
in the Western Region. Our review of DCAA anonymous Web site contacts
as of the end of May 2007 showed that over 40 percent (65 of 152) of
the DCAA contacts also relate to the Western Region, including several
that pertain to abusive management actions.[Footnote 76] Although DCAA
headquarters officials have followed up on some of the complaints about
management abuse that they received, decisions on disciplinary or
corrective action typically have been delegated to region management.
DCAA headquarters officials explained that in several cases, Western
Region management has not agreed to take disciplinary or other
available corrective actions. The officials told us that DCAA hotline
staff have no recourse in these situations.
DCAA Has Made Progress, but Correcting Fundamental Problems in Agency
Culture That Have Impacted Audit Quality Will Require Sustained
Leadership:
Although DCAA has taken several positive steps, much more needs to be
done to address widespread audit quality problems. DCAA's production-
oriented culture is deeply imbedded and likely will take several years
to change. Under the decentralized management environment, there has
been little headquarters oversight of DCAA regions, as demonstrated by
nationwide audit quality problems. Further, DCAA's culture has focused
on hiring and promoting from within the agency and most training has
been conducted by agency staff. This has led to a very insular culture
where there are limited perspectives on how to make effective
organizational changes. In response to our July 2008 investigative
report,[Footnote 77] DOD's former Comptroller/CFO and Defense Business
Board (DBB) conducted reviews[Footnote 78] of DCAA operations and made
recommendations for corrective actions. The recommendations of the DBB
are consistent with many of the recommendations discussed later in this
report. DCAA has taken actions to revise performance metrics, change
certain policy guidance, and obtain an independent organizational
assessment (staff survey); however, DCAA has not yet addressed the
fundamental weaknesses in its mission, strategic plan, audit approach,
and human capital practices. Moreover, DCAA actions to date have
focused on process and have not addressed the agency's decentralized
organizational structure that has fostered a culture of DCAA region
autonomy. On October 23, 2008, the DBB discussed its preliminary
findings and recommendations at a public meeting, and on January 22,
2009, the DBB released its DCAA study report, which concluded that:
* DCAA's mission focused primarily on supporting the procurement
community with no mention of protecting taxpayer interest. The current
mission statement also provided for advisory services that raised
serious questions about DCAA's independence and objectivity under
GAGAS.
* DCAA's strategic plan did not address essential elements required by
GPRA, and it did not address emerging issues that could affect mission
accomplishment or contain a human capital strategic plan despite
spending 80 percent of its budget on personnel.
* None of DCAA's 24 performance measures addressed audit quality, such
as conformance to GAGAS, and only 8 could be tied to DCAA's strategic
plan.
* DCAA's decentralized organizational culture dilutes effectiveness of
managerial oversight and affects GAGAS compliance and audit quality.
* DCAA has not established a human capital strategic plan as a key tool
to facilitate human capital management and workforce development in
support of DCAA's mission and implementation of its strategic plan.
The following discussion summarizes the status of DCAA corrective
actions on identified weaknesses, including actions on key DBB and DOD
Comptroller/CFO recommendations.
DCAA's Mission Statement and Strategic Plan Have Not Yet Been Revised:
The DBB report, released in January 2009, pointed out that DCAA had
five versions of a mission statement, noting that each version focused
primarily on supporting the procurement community. The Board concluded
that DCAA's mission should be refocused to protect the taxpayer's
interests, writing: "The mission fostered the culture of supporting
contracting officials, and the value system was one of quantity
(number, cost, and timeliness of audits) over quality—which was further
reinforced by the performance metrics that drove the organization." In
addition, the Board reported that instead of complying with GPRA
strategic planning requirements for long-term goals and objectives for
major operations and functions, DCAA's plan resembled a short-term
process improvement checklist and did not address enterprise risk,
external factors, or emerging issues that could affect mission
accomplishment. In addition, the Board noted that DCAA's strategic plan
did not include an adequate human capital strategy to facilitate
workforce development, recruiting, retention, and succession planning.
The Secretary of Defense Has Not Yet Developed a DCAA Mission Statement
That Focuses on Protecting the Public Interest:
The DBB report recommended that the Secretary of Defense revise DCAA's
mission to focus on protecting the interest of taxpayers, with the
taxpayer as the primary customer, and that DCAA establish a core value
of performing high quality, independent, and objective contract audits
that adhere to GAGAS and ensure that taxpayer dollars are spent on fair
and reasonable contract prices. The DBB did not address any amendments
that might need to be made to the FAR, DFARS, and DOD Directives and
policy documents that reflect DCAA's primary role as an advisor to
government contracting officers and disbursing officers.[Footnote 79]
Leading organizations that have undergone cultural and organizational
transformation have identified top leadership involvement in developing
a mission statement and strategic plan as a best practice. These
organizations consider top leadership commitment in setting the
direction, pace, and tone for the transformation as essential to
provide a clear, consistent rationale that unites agency components
behind the mission to guide the transformation. In meetings with DCAA
officials, we expressed our concern that the Secretary of Defense had
not taken action to revise DCAA's mission statement. On March 12, 2009,
following a discussion on the preliminary results of our audit, the
DCAA Director submitted a proposed revision to DCAA's mission statement
to the Comptroller/CFO for review. The proposed revision inserted
phrases that refer to "...serving the public interest" and "...ensure
taxpayer dollars are spent on fair and reasonable contract prices."
Although the revised mission statement had not been approved by the
Secretary of Defense as of the end of July 2009, these changes would be
positive.
DCAA Has Not Yet Developed a Strategic Plan To Provide a Framework for
Organizational and Cultural Reform:
The DBB also recommended that DCAA develop a strategic plan that
cascades from the revised mission statement and concurrently develop
(1) an annual performance operating plan and a balanced scorecard tied
to the strategic plan and (2) a human capital strategic plan. In
addition, the DBB recommended that DCAA obtain an independent
assessment of resource needs and engage an external professional
organization to assist in a cultural transformation.
DCAA officials told us they are having difficulty identifying an
independent external professional organization to assist the agency in
developing a strategic plan because DCAA audits most of the
organizations that should be able to provide this type of assistance.
In her February 27, 2009, response to the DBB report, the DCAA Director
stated that DCAA expects to complete action on this recommendation by
September 2009. With regard to the recommendation to develop a balanced
score card, the DCAA Director reported that based on agreements with
prior DOD Comptroller/CFOs, DCAA plans to use a monthly status report
of agency performance measures rather than developing a balanced score
card. Together with the change in performance measures for fiscal year
2009, DCAA implemented the monthly performance report in October 2008.
The DCAA Director stated that DCAA will refine the annual performance
plan in accordance with development of a revised strategic plan.
The DCAA Director also stated that DCAA initiated a process to
reengineer its human capital strategic plan in November 2008. The
Director stated that DCAA obtained example plans from other
organizations and attended training on human capital plan preparation
and maintenance. DCAA is also seeking assistance from external
organizations in reengineering its human capital plan.
DCAA's Director Took Immediate Action To Eliminate Production Metrics,
but Concerns about Audit Quality Measures Remain:
The Committee's September 2008 DCAA oversight hearing raised concerns
that DCAA's performance metrics focused on producing reports rather
than performing quality audits and that auditors who attempted to
perform quality audits were penalized for not meeting production goals.
The DCAA Director acknowledged problems with the agency's metrics and
stated that she had initiated a project to assess the agency's use of
performance measures that would be completed by September 30, 2008.
Performance metrics provide the basis for measuring achievement of
agency mission and strategic goals. Accordingly, performance measures
should be consistent with agency strategic goals. Although DCAA's
mission statement and strategic plan have not yet been revised to
provide new goals, the DCAA Director took action in September 2008 to
eliminate production-oriented performance measures. On September 30,
2008, the Director issued a policy memorandum that eliminated 18
performance measures, identified 9 performance measures with goals for
use in fiscal year 2009, and clarified the use and level of reporting
on the revised measures. Some of the new performance metrics focus on
outcomes, while others continue to focus on producing low cost audits
in fixed time frames.
New Performance Metrics Intended To Focus on Achieving Quality Audits:
The DOD Comptroller/CFO required DCAA to develop standard metrics to
measure and re-enforce compliance with GAGAS and CAM across DCAA by
February 28, 2009. The DCAA Director reported that the new metrics
established on September 30, 2008, met this requirement. DCAA
identified the following six new performance metrics as focusing on the
intended outcome-related goal of achieving quality audits that comply
with GAGAS.[Footnote 80]
1. Obtaining an unqualified DOD IG peer review opinion.
2. DCAA's internal quality assurance program results show that 100
percent of the audits reviewed reflected professional judgment.
3. Checklist confirmation that issued reports did not include serious
deficiencies.
4. A goal that 45 percent of audit reports will have findings as an
indication of the tangible value of the audit work performed.
5. A goal that 15 percent of the audits will use quantitative methods
to measure the extent to which advanced level audit techniques are
used.
6. A goal that auditors will meet 100 percent of their continuing
professional education requirements on time.
Only metrics number 1, 3, and 6 have a direct relationship to audit
quality. Although metric number 2 could improve audit quality if
properly implemented, DCAA gave passing scores to deficient audits.
Given the problems with DCAA's ineffective quality assurance program
and DOD IG peer review results, for these three metrics to achieve the
intended audit quality goal, significant changes will be needed in
policy guidance and training on audit standards, appropriate
procedures, and audit documentation in order to comply with GAGAS. The
fourth goal that 45 percent of DCAA audit reports will have findings is
approximately the same as the actual percentage of 41 percent of the
reports in 2008. Because findings would support recommendations for
corrective action, this metric could contribute to improvements in
accountability over contractor cost and billings. Regardless of the
goal, findings should be reported as appropriate based on the
completion of quality audits. Further, the use of quantitative methods
of analysis in audit reports needs to be supported by training on the
appropriate methods for sampling and testing contract costs, controls,
and compliance to help auditors perform sufficient testing to support
audit conclusions and opinions.
Performance Metrics That Continue To Measure Output:
Although three of DCAA's fiscal year 2009 metrics are important in that
they address responsiveness to contracting officer requests for audits,
if not properly managed, they could impact the effectiveness of DCAA's
new audit quality metrics. In the past, DCAA's efforts to meet
contracting officer requests for audits within specified time frames
caused auditors to sacrifice audit quality. The following three
performance metrics continue to address issuing reports within
specified times to support contract awards and closeouts.
* A forward-pricing audit timeliness goal of 95 percent based on
agreement with requesters.
* Incurred cost audit timeliness goals of 90 percent of corporate
audits completed within 12 months, 90 percent of major contractor
audits completed in 15 months, and 95 percent of non-major contractor
audits completed in 24 months.
* An efficiency goal of cost per direct audit hour of less than $113.45
to be monitored at the agency level only.
It is critical that agreements with the contracting community on
timeliness goals for forward-pricing and incurred cost audits allow
performance of sufficient audit procedures to help contracting officers
ensure that prices paid by the government are fair and reasonable, and
that contract costs comply with applicable laws, regulations, cost
accounting standards, and contract terms. In addition, keeping cost per
direct audit hour in line with past practices indicates that DCAA
likely would continue to use trainee or junior auditors on assignments
without senior auditor or supervisory auditor involvement. GAGAS
requires that staff assigned to perform the audit or attestation
engagement must collectively possess adequate professional competence
for the tasks required.[Footnote 81] Moreover, DCAA has not agreed to
develop a risk-based audit approach to address how it will perform
required audits with available audit resources, reassess the need to
perform 30,000 or more audits annually, and establish priorities for
performing quality audits that meet GAGAS within available resources.
On October 30, 2008, DCAA required regional audit managers to provide
training on changes in performance metrics to all FAOs by December 31,
2008, as part of the effort to get the word out that DCAA's mission
should be to protect taxpayer interest and that auditors should perform
quality audits that meet GAGAS. The DCAA Director stressed to us that
budgeted audit hours would be captured for planning purposes, but they
were never intended and should not have been used to evaluate auditor
performance. The DCAA Director also told us that DCAA auditor
performance appraisals should not have considered exceeding budgeted
audit hours as a performance failure. In addition, DCAA implemented an
anonymous Web site for capturing feedback on inappropriate use of the
new performance measures and abusive management actions.
Inconsistent Implementation and Training on New Metrics:
During random telephone calls made to 17 auditors across 15 FAOs in the
five DCAA regions, we found mixed results on FAO implementation of
DCAA's new performance metrics. DCAA's Assistant Director of Operations
told us she also had become aware of some problems with regional audit
managers meeting the requirement to provide training to FAOs on
implementation of the new DCAA performance metrics. The Operations
Assistant Director told us that she planned to follow-up with all FAOs
in this regard. In response to our telephone calls, for example:
* Auditors at 13 of the FAOs told us that metrics related to meeting
budget hours for completing audits have been relaxed. Although most of
these auditors were not aware of audit completion dates in fiscal year
2009 program plans for their offices, two auditors told us that audit
completion dates had been pushed back to allow more time for performing
individual audits. An auditor at a Northeast Region FAO told us the use
of budget hours was flexible before the metrics changes, so there was
no noticeable difference. An auditor at a Western Region FAO said that
although budget hours are no longer a metric for individual auditor
performance, there is still a lot of pressure on auditors to meet
budgeted hours.
* Auditors at 5 of the 15 FAOs told us they had received the mandatory
training on changes in performance metrics prior to December 31, 2008.
However, auditors at 4 FAOs told us they received the mandatory
training after December 31, 2008, including two auditors at one Eastern
Region FAO who told us they did not receive the required training until
February 13, 2009. Auditors at the other 6 FAOs told us they received
the metrics training, but they could not remember the dates of the
training.
* Auditors at 5 FAOs told us they were permitted to charge from 1 to 2
hours of administrative time per pay period for reading e-mails on DCAA
policy changes and new policy memorandums. Auditors at 2 FAOs said they
were not given an administrative code for this purpose. One of these
auditors told us they read the policies on their own time. Auditors at
the remaining 8 FAOs did not mention a time limit for reading DCAA
policy memoranda. DCAA headquarters officials told us that auditors
should be permitted to charge administrative codes for this purpose and
that they are working to resolve this issue across DCAA.
The DCAA Director advised DCAA employees that the new performance
metrics would be revisited after 6 months to determine if changes are
needed. On February 11, 2009, DCAA revised its fiscal year 2009 job
objectives/performance plans to reflect the new performance measures,
and DCAA's Deputy Assistant Director of Operations advised us that DCAA
initiated an assessment of the new performance metrics in April 2009.
DCAA Has Centralized, but Has Not Yet Restructured Its Audit Quality
Assurance Program:
DCAA has taken some actions to improve its quality assurance program.
However, staffing difficulties and other issues have left the outcome
of this important initiative uncertain. As previously discussed, GAGAS
require that each audit organization performing audits and attestation
engagements in accordance with GAGAS should have a system of quality
control that is designed to provide the audit organization with
reasonable assurance that the organization and its personnel comply
with professional standards and applicable legal and regulatory
requirements, and have an external peer review at least once every 3
years.[Footnote 82] In addition, considering the large number of DCAA
audit reports issued annually and the reliance the contracting and
finance communities have placed on DCAA audit conclusions and opinions,
an effective quality assurance program is key to protecting the public
interest. Such a program would report review findings along with
recommendations for any needed corrective actions; provide training and
additional policy guidance, as appropriate; and perform follow-up
reviews to assure that corrective actions were taken. When we briefed
DCAA on our preliminary findings in March 2009, DCAA had not yet taken
action to correct serious deficiencies in its quality assurance
program, including problems with DCAA's application of the professional
judgment standard, whereby quality assurance program officials gave
satisfactory ratings when significant noncompliance with GAGAS had been
identified by reviewers.
In response to our previous report, on August 20, 2008, the DOD
Comptroller/CFO required that DCAA take certain actions to improve
audit quality, which included a restructuring of DCAA's quality
assurance function. Accordingly, on August 22, 2008, DCAA established a
new headquarters Directorate for Quality Assurance and Integrity, which
centralized the quality assurance function at DCAA headquarters. The
DOD Comptroller/CFO directed that the new Quality Assurance Directorate
be headed by a Senior Executive Service (SES) Deputy Director. Because
DOD did not grant DCAA an additional SES position for this purpose, the
DCAA Director assigned responsibility for leading DCAA's quality
assurance function to a level GS-15, Assistant Director for Integrity
and Quality Assurance. Under DCAA's management environment and culture,
which continue to foster autonomous regions headed by SES-level
directors, the grade level and experience of the GS-15 equivalent
Assistant Director for Integrity and Quality Assurance pose a challenge
when dealing with SES-level regional directors, deputy directors, and
regional audit managers. For example, when presented with our findings
and conclusions that various audits did not comply with GAGAS, DCAA
headquarters policy and quality assurance managers allowed regions and
FAO's to decide whether to rescind the subject audit reports. In March
2009, DCAA officials advised us that the GS-15, Assistant Director for
Integrity and Quality Assurance position is an intended SES position
and that two GS-15 Assistant Directors will perform as Chief of
Integrity and Chief of Quality Assurance.
In centralizing the quality assurance program, DCAA's new quality
assurance organization provides for five GS-14 senior quality assurance
auditors at DCAA headquarters and up to 27 GS-13 quality assurance
auditors in the field assigned across the 5 DCAA regions. However, a
headquarters requirement that all senior quality assurance staff
relocate to DCAA headquarters at Fort Belvoir, Virginia, resulted in
all but one of the five senior staff accepting other positions within
DCAA because they did not wish to relocate. It took several months to
recruit DCAA staff for the senior quality assurance positions at DCAA
headquarters. On July 10, 2009, a DCAA headquarters official advised us
that DCAA had selected staff to fill the two remaining vacancies, and
these staff would be reporting for duty in the next few weeks.
In response to our concerns that DCAA's quality assurance program has
not resulted in audits that comply with GAGAS, DCAA officials advised
us that going forward, DCAA will no longer rate an FAO's overall
compliance with GAGAS and DOD policy. The officials told us that
instead, DCAA headquarters plans to (1) report the detailed results of
the audit quality reviews, (2) make recommendations to FAOs for any
needed corrective actions, (3) conduct follow-up reviews for all FAOs
with identified audit deficiencies to ensure that corrective actions
are taken, and (4) provide training and policy guidance, as
appropriate. If properly implemented, these procedures would help to
assure an effective audit quality assurance program.
DCAA Disagrees with the DBB Recommendation for a Risk-Based Audit
Planning Process:
The DBB recommended that DCAA establish a risk-based planning process
that expands DCAA self-initiated audits and increases the potential for
identifying fraud, waste, and abuse, and higher rates of return to the
taxpayer by April 2009. The DBB intended for DCAA to audit any and all
contracts awarded by the department. On February 27, 2009, in
responding to the DBB recommendation, the DCAA Director stated that (1)
DCAA's practice of auditing only certain contracts was due to
regulation or statute and (2) absent the DCAA access-to-records clause
in certain types of contracts, DCAA has no legal basis to obtain cost
data from a contractor. The DCAA Director suggested that the DBB
recommendation should be directed to the Under Secretary for
Acquisition, Technology and Logistics, who oversees DCMA, and not DCAA.
The DCAA Director told us that she believes that DCMA should address
this recommendation because DCMA decides what audits DCAA should
perform to support contracting decisions and DCMA would need to
initiate action to change audit-related FAR requirements.
Generally, DCAA, as the agent of the Secretary of Defense, has
authority[Footnote 83] to examine records of (1) a contractor
performing any cost-reimbursement, incentive, time-and-materials, labor-
hour, or price re-determinable contracts and subcontractors performing
such contracts of the contractor and (2) to evaluate the accuracy,
completeness, and currency of certified cost or pricing data required
to be submitted pursuant to law, all records of the contractor or
subcontractor related to the proposal, and discussions conducted on the
proposal, pricing of the contract or subcontract or performance of the
contract or subcontract. This authority is implemented by insertion of
the Audit of Records clause in solicitations for negotiated contracts.
[Footnote 84] In addition, the Director of DCAA may require by subpoena
the production of any records of a contractor that the Secretary of
Defense is authorized to audit or examine. While DCAA does not have
access to the records of all DOD contractors or statutory rights of
access to contractor officials, we believe it has sufficient authority
to undertake a risk-based audit approach consistent with its existing
authority. Therefore, we believe the DBB recommendation for DCAA to
develop a risk-based audit planning approach is appropriate. DOD
acquisition officials we met with agree. Further, as previously
discussed, a risk-based audit approach would provide a basis for
determining audit resource requirements.
DCAA has selected the Army Force Management Support Agency[Footnote 85]
to perform its staffing study. However, DCAA is conducting a staffing
study as a stand-alone effort rather than performing the study in
concert with an effort to establish a risk-based planning process. To
provide useful information for decision making, it is important that
the staffing study and risk-based audit planning approach are conducted
as integrated efforts. It is also important for the DOD contracting and
finance communities to be involved in the staffing study analysis and
planning process because, as discussed earlier, a risk-based audit
approach may require these communities to re-evaluate whether all DCAA
services should be provided as audits and whether DCAA, as an
independent audit organization, should perform any nonaudit services.
To address immediate staffing needs, DCAA requested funds for
additional audit staff and training from the Defense Acquisition
Workforce Development Fund,[Footnote 86] including 300 positions for
fiscal year 2009 and another 200 positions in 2010. DCAA received
approval of this request in December 2008. In May 2009, as part of
DOD's request for an additional 9,000 positions for contract management
and oversight, the DCAA request was increased from 500 to 700 new
positions that are to be phased in from fiscal year 2009 through
2011.[Footnote 87] As previously discussed, without developing a risk-
based audit approach, it is difficult to determine the level of
resources needed to perform effective, quality contract audits.
However, federal acquisition and contract audit resources have not kept
pace with the growth on federal procurements. As shown in figure 2,
although procurement obligations related to greater reliance on
contractor-provided services and support of the Global War on Terrorism
have more than doubled since fiscal year 2002, DCAA audit resources
have remained about the same. In addition, contractor and subcontractor
relationships have become more complex, increasing the complexity of
contract audits. These changes underscore the need for a risk-based
audit plan and assessment of auditor resource and training needs.
Figure 2: Comparison of DOD Contract Obligations and DCAA Workforce for
Fiscal Years 2002 through 2008:
[Refer to PDF for image: multiple line graph]
Fiscal year: 2002;
DCAA audit workforce: 3,500;
DOD contract obligations: $171 billion.
Fiscal year: 2003;
DCAA audit workforce: 3,500;
DOD contract obligations: $195 billion.
Fiscal year: 2004;
DCAA audit workforce: 3,500;
DOD contract obligations: $231 billion.
Fiscal year: 2005;
DCAA audit workforce: 3,500;
DOD contract obligations: $270 billion.
Fiscal year: 2006;
DCAA audit workforce: 3,500;
DOD contract obligations: $299 billion.
Fiscal year: 2007;
DCAA audit workforce: 3,600;
DOD contract obligations: $331 billion.
Fiscal year: 2008;
DCAA audit workforce: 3,600;
DOD contract obligations: $383 billion.
Source: GAO analysis of unaudited obligations data from the Federal
Procurement Data System and acquisition workforce data from the Office
of Personnel Management.
[End of figure]
Although DCAA has undertaken certain initiatives to improve the
effectiveness of audits of contractor billings and internal control
systems, these efforts are not targeted for completion until September
2010 and September 2012, respectively, and they are not part of a
comprehensive audit strategy or framework. Once decisions are made on
changes in various audit procedures for these audits, related audit
guidance and training would be needed to help ensure the new procedures
are effectively implemented.
DCAA Issued Revised Policy Guidance To Address Auditor Independence,
Assure Management Involvement in Key Decisions, and Address Audit
Quality Issues:
Our investigation and audit identified problems and concerns related to
auditor independence, the need for management involvement in key
decisions, and audit quality. In response to our work, the DBB and DOD
Comptroller/CFO made several recommendations for DCAA actions to
address these concerns. Specific DCAA actions and our assessment
include the following.
Auditor independence. The DBB recommended that DCAA address advisory-
type (nonaudit) services by (1) discontinuing participation on
Integrated Product Teams and Source Selection Evaluation Boards, both
of which impair auditor independence in fact and appearance under
GAGAS; (2) reevaluating the role and number of Financial Liaison
Advisors (FLA) to ensure independence and objectivity in both fact and
appearance; and (3) working with the DOD acquisition leadership to
explore alternatives for providing technical advice and support to the
contract management community while adhering to the auditor
independence standards in GAGAS.
The DCAA Director responded that DCAA discontinued participation in
Integrated Product Teams on August 4, 2008, and Source Selection
Evaluation Boards on September 12, 2008. On November 23, 2008, DCAA
realigned all FLAs to report directly to DCAA headquarters and
completed an assessment of the number of advisors. DCAA is continuing
to assess the functions performed by FLAs to assure their independence.
The DCAA Director stated that if there is a significant change in the
advisory functions, DCAA will initiate discussions with DOD acquisition
leadership. We support efforts to reevaluate DCAA's nonaudit advisory
services given the problems identified in our investigation. Although
our review of DCAA's CAM guidance found that DCAA had established
appropriate guidelines to avoid independence issues, we found that the
auditors had not followed DCAA policy. According to the DCAA Director,
the DBB's primary concern is that DCAA participation in these advisory
services created the appearance of a lack of independence.
Requirement for DCAA management involvement in key decisions. DCAA
issued policy memorandums requiring that (1) FAO managers sign all
audit reports issued by the FAO; (2) auditors elevate memorandums on
disagreements with supervisors and FAO managers on draft audit opinions
to the highest level necessary, including the DCAA Director, for
resolution; and (3) auditors elevate problems in accessing contractor
records to FAO managers, contracting officers, and regional offices for
appropriate handling.
DCAA action to require FAO managers to sign all audit reports issued by
the FAO addresses concerns identified in our investigation that
supervisors could inappropriately issue reports with adequate ("clean")
opinions without review by FAO managers. Similarly, the policy to
elevate disagreements on changes to audit opinions responds to findings
in our investigation that supervisors ignored auditors' objections to
dropped findings and changed opinions, and the auditors had no
opportunity to elevate their disagreement beyond the supervisors. The
access-to-records policy clarified actions required when auditors are
denied access to records and required FAO managers to brief their staff
on the revised guidance. The revised policy guidance emphasized that
auditors (1) should follow procedures for addressing denial of access
to records, which include notifying the FAO manager, contracting
officer, and DCAA region; (2) take appropriate actions to effect a
suspension or withholding of any unsupported costs billed to the
government until the data are received and a determination is made
regarding the allowability of the costs; and (3) question the
unsupported costs in the audit report if the supporting documentation
is not received prior to the completion of fieldwork. Although our work
identified some access-to-records problems, in these cases, there was
no evidence that DCAA supervisors elevated the issue to management or
to procurement officials to initiate enforcement action, as set out in
existing DCAA policy.
Guidance to improve audit quality. On August 6, 2008, the DCAA Director
requested that each FAO hold a stand-down day (where staff were
relieved of assigned duties to take mandatory training) to discuss
audit quality and the requirement to comply with GAGAS requirements for
competence, integrity, objectivity, and independence in performing
contract audits. In addition, DCAA issued policy guidance on adequate
audit documentation and testing, including the following guidance that
applied to assignments we reviewed for this report:
* "Workpaper Documentation of Judgmental Selections"--requires a
description of the universe (population) from which items are selected
for testing, identification of items and attributes to be tested, and
an explanation to support that the judgmental selection will result in
adequate audit coverage.
Emphasizing the requirement that audit documentation include a
description of the population used for sampling and identification of
items and attributes to be tested is appropriate. However, the
requirement for an explanation in the audit documentation that the
judgmental selection will result in adequate audit coverage needs to be
sufficiently justified. GAGAS and AICPA standards require that auditors
document significant decisions affecting the audit objectives, scope
and methodology, findings, conclusions, and recommendations resulting
from professional judgment.[Footnote 88]
* "Audit Guidance for Annual Testing of Contractor Eligibility for
Direct Bill," which is intended to determine whether continued reliance
can be placed on the contractor's procedures for preparation of interim
vouchers. This policy change clarified and consolidated audit steps
related to the contractor's compliance with contract provisions, added
audit steps for reviewing vouchers under time-and-material and labor-
hour contracts, and removed the requirement to verify that the
contractor's Central Contractor Registration is current. The policy
memorandum states that this scope of work performed does not constitute
an audit or attestation engagement under GAGAS.
It is within DCAA's purview to determine whether these procedures
constitute an audit. However, because direct-bill decisions present a
risk of undetected improper contract payments, prudent decisions to
continue a contractor's direct-bill authorization would necessarily be
based on testing a statistical sample of invoices[Footnote 89] and
include a review of supporting documentation, including documentation
to confirm the government received goods and services noted on the
billing invoice. We confirmed that Defense Finance and Accounting
Service certifying officers rely on DCAA reviews, and they do not
repeat review procedures they believe to be performed by DCAA.
Human Capital Management and Cultural Transformation:
The DBB made two recommendations to improve DCAA human capital
management and agency culture, namely that DCAA (1) develop a human
capital strategic plan as a key tool to facilitate human capital
management and workforce development and (2) engage an external
professional organization to assist in a cultural transformation that
includes emphasizing core values such as quality, independence, ethics,
and objectivity rather than a mindset focused on quantity and
productivity. DCAA has not yet developed a human capital strategic plan
as a key tool to facilitate human capital management and workforce
development. In May 2009, DCAA finalized an agreement with the Naval
Post Graduate School, Center for Defense Reform, for assistance on
cultural reform. According to GAO's Internal Control Standards,
[Footnote 90] operational success is possible only when the right
personnel for the job are on board and are provided the right training,
tools, structure, incentives, and responsibilities. Accordingly,
management should ensure that skill needs are continually assessed and
that the organization is able to obtain a workforce that has the
required skills that match those necessary to achieve organizational
goals. In addition, training should be aimed at developing and
retaining employee skill levels to meet challenging organizational
needs; qualified and continuous supervision should be provided to
ensure that internal control objectives are achieved; and performance
evaluation and feedback, supplemented by an effective reward system,
should relate employee performance to the organization's success.
Lack of a human capital strategic plan. The lack of a human capital
management strategic plan has limited the effectiveness of DCAA's
hiring, training, and staff development efforts. DCAA officials told us
they view contract auditing as a highly specialized profession that
requires knowledge of acquisition law and regulations and government
procurement and contract management processes. As a result, DCAA
officials believe that auditors must be hired at the entry level and
trained to perform contract audits. The officials also believe that
because DCAA is the only contract audit agency in the federal
government and it operates the only federal contract audit training
institute, DCAA is in the best position to train contract auditors.
However, DCAA is not the only agency that performs contract audits.
Many IG offices, including the DOD IG, the military service audit
agencies, several executive agency IGs, and GAO all perform contract
audits. Further, DCAA has not provided training that is designed to
develop contract audit skills at successively higher levels, and it has
not provided adequate or continuous supervision of audit staff.
Moreover, our work has shown that performance evaluations and feedback
have not always related performance to the agency's success, as was the
case when supervisors who were responsible for improperly dropping
audit findings and changing draft audit opinions received high
performance evaluations and cash awards.
At the September 2008 hearing, the DCAA Director acknowledged the need
to develop revised training to address audit quality issues. However,
it will take considerable time to develop a revised training program to
address the range of changes in audit policies, processes, and
procedures for performing quality audits in accordance with GAGAS.
However, on April 8, 2009, DCAA revised its Supervisory Development
Training Curriculum to emphasize leadership skills and better reflect
the day-to-day activities performed by supervisors. This revision was
based on feedback received through DCAA's suggestion program, anonymous
Web site contacts, and focus groups and is not based on a study or
expertise of an outside professional organization. In addition, DCAA
has begun a reassessment of the 2-week technical indoctrination class
for new hires.
Although it is appropriate to consider staff input in developing
training courses, the development of in-house training by agency
personnel may not result in a design that encourages participants to
develop more critical analysis of the underlying principles or ways to
bring about organizational change. Outside expertise helps ensure that
an organization benefits from outside subject matter experts as well as
education and training professionals who have a broad perspective on
innovative approaches to best practices or best learning design.
DCAA has difficulty identifying an independent professional
organization to assist in cultural transformation. According to the
DCAA Director, DCAA faces challenges in engaging a professional
organization to assist with cultural change because (1) many external
organizations that provide this service are audited by DCAA and to
preserve the appearance of independence under the auditing standards,
DCAA cannot engage organizations that it audits and (2) based on
initial discussions with various organizations, DCAA believes this
effort could cost from $1 to $2 million or perhaps more and DCAA would
need additional funding to pay for this assistance. However, based on
an assumption that DCAA would receive funding for this effort, the
Director established a completion date of January 2010 with training of
the workforce potentially extending into fiscal years 2011 and 2012. In
the face of these challenges, the DCAA Director took action on three
other initiatives related to cultural change. The DCAA Director stated
that shortly after issuance of our July 2008 report, DCAA initiated a 1-
to 2-year project to accomplish an organizational assessment using the
Baldrige National Quality Program[Footnote 91] criteria with assistance
from Baldrige experts within the Army. In addition, as required by the
DOD Comptroller/CFO in September 2008, the Director asked the Office of
Personnel Management to conduct an independent organizational survey of
DCAA. As previously discussed, to help ensure that DCAA's new
performance metrics resulted in appropriate cultural change with regard
to the new emphasis on audit quality, DCAA established an anonymous Web
site for obtaining feedback on the inappropriate use of the performance
measures.
In May 2009, DCAA asked the Naval Postgraduate School, Center for
Defense Reform to assist DCAA with cultural transformation as
recommended by the DBB. The Center began work in June 2009 to help DCAA
identify issues facing the organization and develop an action plan.
Delay in reporting results of DCAA's organizational survey. DCAA's
independent organizational survey was completed during the fall of
2008, and DCAA officials said the assessment results would be finalized
in March 2009, but then amended the date for completing the assessment
of the survey results to late July 2009. Therefore, the survey results
were not available to us for review.
DCAA's anonymous Web site contacts underscore the need for a separate
hotline office. DCAA's anonymous Web site was established as a
mechanism for monitoring compliance with DCAA's new performance
metrics; however, it has become an internal hotline, with many auditors
reporting the same issues as those presented in hotline complaints
received by GAO. The DBB report stated that DCAA would benefit from the
establishment of a Chief of Internal Review to perform critical
inspector general functions, such as performing periodic reviews and
evaluations, serving as an ombudsman between staff and DCAA management,
and addressing hotline complaints. Instead of establishing a separate
Internal Review function, in March of 2009, the DCAA Director divided
responsibilities of its Operations Directorate between the Operations
Assistant Director and Deputy Assistant Director to provide dedicated
staff to handle auditor concerns reported to the internal DCAA
anonymous Web site. DCAA's Assistant Director of Operations along with
a Division Chief and three program managers were made responsible for
the DCAA hotline function, and the Deputy Assistant Director of
Operations was given responsibility for day-to-day operations.
Our review of DCAA headquarters handling of DCAA auditor concerns and
hotline allegations sent to DCAA's anonymous Web site determined that
internally reported DCAA auditor concerns represent problems across all
five DCAA regions. As with GAO hotline complaints, the largest number
of problems reported to DCAA's anonymous Web site related to DCAA's
Western Region. Our review of DCAA documentation and discussions with
auditors and DCAA officials indicate that current handling of
internally reported DCAA auditor concerns and allegations appears to be
timely, objective, and fact-based. The Assistant Director of Operations
has made good progress in establishing credibility and trust in the
DCAA hotline function. It will be important for any future inspector
general or ombudsman to carry forward in this role. The DCAA Director's
response to the DBB report did not address the recommendation to
establish a Chief of Internal Review. We agree with the DBB
recommendation. It is important for DCAA to have a hotline function
that is separate from management and operations. Currently, the
Operations Assistant Director has been reassigned to handle this
function on a temporary basis. However, given the size of the DCAA
organization, the extensive number of internal DCAA hotline complaints-
-which totaled about 150 at the end of May 2009--and the likelihood of
continuing hotline contacts that would need to be addressed as DCAA
undergoes its cultural transformation, a permanent internal review or
inspector general function is warranted.
Legislative and Other Actions To Improve DCAA's Effectiveness and
Independence:
In addition to correcting the fundamental weaknesses in mission and the
overall management environment discussed above, certain legislative and
other actions, such as changes in organizational placement, could
enhance DCAA's effectiveness and independence. Successful management
initiatives for cultural and organizational change in large private and
public sector organizations can often take several years to accomplish.
Changing DCAA's organizational placement without first correcting
fundamental weaknesses in mission and the overall management
environment would not assure effective audits. Given this time frame
and pursuant to your request, we identified legislative and other
actions that decision makers can consider to improve DCAA's
effectiveness. In the short term, Congress could enhance DCAA's
effectiveness and independence by granting DCAA certain authorities and
protections similar to those offered to presidentially appointed
inspectors general under the Inspector General Act of 1978, as amended
[Footnote 92] (IG Act). The IG Act contains provisions that enhance the
independence of presidentially appointed IGs, including protections
from removal without congressional notification, access to independent
legal counsel, public reporting of audit results, rights to take
statements from contractor and other personnel, and budget visibility.
These provisions would enhance the important DCAA initiatives currently
under way. Continued monitoring and oversight will be essential to
assuring the successful implementation of DCAA's management
initiatives. In the longer term, Congress could consider changes in
organizational placement after current reform efforts have been
effectively implemented. However, moving DCAA as an organization would
require careful analysis and planning before implementation.
Short-Term Legislative Actions:
In addition to DCAA management reforms already under way and our
additional recommendations, we identified certain legislative
protections and authorities under the IG Act that could enhance DCAA's
effectiveness. Legislation would be needed in order to grant DCAA such
protections and authorities.
Leadership. The IG Act provides for the President to appoint the IG,
with Senate confirmation, at many federal agencies.[Footnote 93] Under
the act, Congress must be notified in advance of removing the IG, and
only Congress can eliminate the office of an IG. Currently, the head of
DCAA is appointed and can be removed by the Secretary of Defense.
Further, DCAA was created and can be reorganized or reassigned by
departmental order without notice. IG Act protections Congress could
grant to DCAA would therefore include (1) Senate confirmation of a
presidentially appointed DCAA Director[Footnote 94] and (2) removal of
the DCAA Director conditioned on congressional notification. [Footnote
95] Specifically, the act provides that an inspector general may be
removed from office by the President and any removal is to be reported
to both Houses of Congress 30 days prior to the removal. In addition to
these IG Act protections, Congress could build additional provisions
into legislation, to include the following:
* Requirements that the DCAA Director possess the appropriate
professional qualifications. For example, provisions for appointment of
the DCAA Director could require selection from among individuals who
possess demonstrated ability in managing and leading organizations,
specific accounting or auditing background, general knowledge of
contract management, and knowledge of and extensive practical
experience in financial management practices in large governmental or
business entities.
* A mandate permitting the DCAA Director to hold a renewable term
appointment for between 5 to 7 years. Legislation should provide that
the DCAA Director can be removed only for cause or other stated
reasons. These protections would allow the head of DCAA to provide
stability and continuity of leadership that span presidential
administrations and prevent removal except for cause or other disclosed
reasons.
* Conflict of interest provisions for the DCAA Director and other key
staff in addition to those provisions currently in law. This would be
intended to ensure that selection of the audit agency head would not
involve a "revolving door" situation between contractors and the
contract audit agency.
Access to independent legal counsel. The IG Act provides for
independent legal advice for IGs rather than requiring the use of
agency legal counsel.[Footnote 96] Currently, DCAA relies upon DOD
legal counsel. DCAA officials told us that the DCAA Director has not
always been apprised of legal decisions by DOD counsel that have
impacted DCAA operations. Further, according to the DCAA Director, the
lack of independent counsel led to a situation where DOD attorneys
provided questionable legal counsel to a DCAA field office supervisor
without the DCAA Director's knowledge. Obtaining independent legal
counsel would avoid conflicts of interest between DOD and DCAA, thereby
helping to improve DCAA's effectiveness.
Budget. The IG Act requires separate budgets for Offices of Inspector
General (OIG) within agency budgets, allowing Congress to review IG
budget requests separately. DCAA currently does not have this
protection. IGs that are appointed by the President with Senate
confirmation receive a separate appropriation, preventing agencies from
reprogramming IG funds to other programs and activities. However, there
is currently little visibility of DCAA's budget because it is funded
under the Operations and Maintenance, Defense-wide appropriation, which
includes numerous DOD agencies, such as the Defense Contract Management
Agency (DCMA), the Defense Logistics Agency, the Defense Finance and
Accounting Service, and some buying command activities. Therefore,
DCAA's share of annual appropriations is subject to reprogramming,
sometimes without congressional notification. According to the DCAA
Director and documentation provided by the Director and Office of
Comptroller/CFO, in the past, DOD has reprogrammed funding between DCAA
and other DOD activities on numerous occasions. Because these
reprogrammings were below the $15 million threshold for congressional
notification, Congress did not have notice of these funding decreases
at the time they occurred. For fiscal year 2009, DOD reprogramming
increased DCAA's funding by $3.5 million. Legislation similar to the IG
Act could grant DCAA a separate budget[Footnote 97] to provide
visibility and protections from reprogramming of funds to other agency
priorities.
Increased authority and independence. Legislation could strengthen
DCAA's audit authority by providing the same level of access to records
and personnel available to IGs.[Footnote 98] Currently, DCAA has
statutory rights of access to certain records related to cost-type
contracts or those that contain cost and pricing data, but not to
contractor personnel. As a result, DCAA's subpoena power is limited to
certain records and does not cover contractor personnel. While we
recognize that DCAA auditors have ongoing discussions with contractor
personnel, they do not have statutory authority to compel contractor
officials to meet with them and submit to interviews. IGs have
authority, including subpoena power, to access all records, reports,
audits, reviews, documents, papers, recommendations, or other material
available that relate to programs and operations for which the IG has
responsibilities. Further, IG subpoena authority extends beyond access
to records and documents in that IG auditors can administer or take an
oath in order to obtain information. Our discussions with DCAA auditors
and reviews of audit documentation identified numerous instances where
requests for contractor records were not met.[Footnote 99] Obtaining
increased access to contracting companies, especially their staff and
documentation, would be an important provision to improve the
effectiveness of DCAA audit staff.
Reporting and oversight of audit results. The IG Act provides for semi-
annual reports to the agency head and appropriate committees of
Congress summarizing results of significant audits and
investigations.[Footnote 100] DCAA currently has no external reporting
requirement, reducing opportunities for oversight and transparency.
Congress could mandate some form of external DCAA reporting in
legislation similar to the IG Act. Moreover, DCAA does not currently
provide copies of its audit reports to other federal agencies that use
the same contractors that DOD uses. According to the DCAA Director,
DCAA's appropriations are specific to DOD contractor audits, and unless
federal agencies request and reimburse DCAA for audit services, DCAA
cannot provide them with copies of its audit reports even though its
DOD audits of systems and related internal controls, cost accounting
system compliance, etc. may cover their contractors. Legislation could
also expressly allow DCAA to provide audit results to other agencies, a
step that would improve its visibility and effectiveness for the
government as a whole.
Legislation to grant DCAA similar protections and authorities as those
provided in the IG Act could enhance reform efforts that are already
under way. Although we found that a lack of DOD Comptroller/CFO and IG
oversight has impaired DCAA's effectiveness, DOD has begun work to
provide improved oversight of DCAA's operations. In August 2008, the
DOD Comptroller/CFO conducted a "tiger team" review of DCAA's audit
quality assurance program, and DOD approved a more comprehensive
Defense Business Board (DBB) study. The new DOD Comptroller/CFO
recognized the need for DCAA oversight and on March 16, 2009, approved
the charter for a DCAA Oversight Committee. Committee members include
the Auditors General of the Army, the Navy, and the Air Force; the DOD
Director of Defense Procurement and Acquisition Policy; and the DOD
Deputy General Counsel for Acquisition and Technology. The Committee
held its first meeting in early April 2009. During May 2009, the DCAA
oversight committee members reviewed selected DCAA audits and visited a
DCAA field office. In addition, the committee members have indicated
that they plan to review this report, our earlier investigative report,
the DOD Comptroller/CFO "tiger team" report, the DBB report, and the
upcoming DOD IG report that follows up on issues from our July 2008
report. The committee plans to assess DCAA actions on recommendations
in these reports and identify any gaps for further action. We note that
DCAA has already taken numerous actions to respond to our initial
investigative report as well as DOD Comptroller/CFO and DBB
recommendations.
Long-Term Legislative Actions To Move DCAA:
Most of the impairments to DCAA effectiveness that we identified can be
addressed within DCAA's current organizational placement. However, to
address the Committee's interest in how changes in DCAA's
organizational placement could improve DCAA effectiveness and
independence, we considered potential approaches to moving DCAA. During
the 1980s, there were numerous proposals to reorganize DCAA's
organizational structure, including legislative proposals that would
have placed DCAA in the Office of the Under Secretary of Defense
(Acquisition), or in the DOD Office of Inspector General (OIG), or
placed only DCAA's post-contract audits in the OIG. We analyzed these
proposals in an April 1991 report[Footnote 101] and concluded that they
were not workable because they posed conflict of interest or
duplication of effort issues.
We believe that it is prudent to consider changes in organizational
placement after DCAA has had sufficient opportunity to effectively
implement current reform efforts necessary to address fundamental
operational issues. Legislation to move DCAA as an organization would
require careful analysis and planning before implementation. Moving
DCAA at this time would be a bold step with possible unintended
consequences, and decision makers would need to carefully weigh the
costs and benefits of moving DCAA before the fundamental operational
issues are addressed. As discussed below, regardless of its ultimate
placement in the government, DCAA still needs to address the
fundamental weaknesses in its mission, strategic plan, metrics, audit
approach, and human capital management.
Elevating DCAA within DOD:
Elevating DCAA within DOD as a separate component reporting to the
Deputy Secretary of Defense could give more authority to the DCAA
Director and increase visibility of the organization both within and
outside of DOD.[Footnote 102] Because DOD positions reporting to the
Secretary level are established by law, moving DCAA to the department
level would require new legislation. To avoid any ambiguities or
questions about whether the Secretary of Defense currently possesses
the statutory authority to transfer the supervision of DCAA to the
Deputy Secretary, we believe additional legislation that sets out
appropriate relationships would be the best approach.[Footnote 103] In
addition, this option would require some level of administrative
change. For example, management and oversight of the contract audit
function would become the responsibility of Deputy Secretary, a
separate appropriation would need to be established, and some form of
periodic external reporting to Congress would be appropriate. We note
that authorizing legislation to move DCAA could also include similar
protections and authorities as those under the IG Act if these
provisions have not already been enacted.
Although this option could enhance DCAA auditor objectivity and
independence, under this organizational placement, DCAA would still
need to resolve the management environment and cultural problems that
have had a negative impact on audit quality, including pressure by
contractors and contracting officers on audit scope and findings,
conclusions, and recommendations. DCAA also would need DOD commitment
to strengthening DCAA's contract audit function through continued
monitoring and oversight. Leadership from the Deputy Secretary of
Defense would be critical to help DCAA address these matters. A key
factor will be whether the Deputy Secretary has the necessary time to
focus on DCAA. The amount of time needed should be less once the
fundamental improvements are accomplished.
Establishing an Independent, Governmentwide Contract Audit Agency:
Numerous governmentwide acquisition management reform efforts are
currently under way that could impact the contract audit function.
These efforts include congressional oversight and reform legislation
and Presidential direction on developing governmentwide guidance for
reviews of existing contracts to identify contracts that are wasteful,
inefficient, or otherwise unlikely to meet agencies' needs, and to
formulate corrective action in a timely manner, as well as interest
group studies. For example, in the National Defense Authorization Act
for Fiscal Year 2008, Congress created the Commission on Wartime
Contracting to study federal agency contracting for the reconstruction,
logistical support of coalition forces, and the performance of security
functions in Iraq and Afghanistan. The Senate Committee on Homeland
Security and Governmental Affairs also recently created a new
Subcommittee on Contracting Oversight. Several Members of the House
Oversight and Government Reform Committee created the Clean Contracting
Coalition to take a similar governmentwide approach. The House
Oversight and Government Reform Committee also has been very active in
this area. In addition, the House Armed Services Committee established
an acquisition panel to evaluate DOD's current acquisition system,
analyze the root causes of project or program failures, and the
administrative and cultural pressures that acquisition and program
personnel face. The House and Senate Armed Services Committees also led
the effort to enact the Weapon Systems Acquisition Reform Act of 2009,
[Footnote 104] which requires oversight of cost estimation, systems
engineering, and performance assessment; promotes competition; and
limits organizational conflicts of interest.
On March 4, 2009, the President issued a memorandum directing executive
agencies to (1) increase the use of fixed-price contracts, (2) enhance
the capacity of the acquisition workforce, (3) maximize competition,
and (4) rationalize the choice of government or contractor resources to
perform required services. In addition, the Federal Acquisition
Innovation and Reform Institute--a nonpartisan, nonprofit organization
led by leaders in acquisition and supply management--has called for
acquisition workforce reforms, including a single acquisition job
series that encompasses at a minimum, three functions--program
management, contracting, and a new function called requirements
management--and is considered a professional "super COTR" (contracting
officer's technical representative) position. Over the next several
years, these reform initiatives likely will have a significant impact
on government contracting, including the roles and relationships of
contract auditors and the contracting, program, and finance
communities.
Depending on the outcome of the various contract reform initiatives and
the successful implementation of DCAA management reforms, Congress may
also want to consider increasing the efficacy of these reforms by
establishing an independent governmentwide contract audit agency. The
creation of a statutory governmentwide contract audit agency could
enhance contract auditor effectiveness and independence by placing the
audit agency outside DOD and other federal agencies that make
procurement and contract management decisions. Centralizing the
contract audit function and mandating its use by all federal agencies
also could provide for consistent audit coverage and bring efficiencies
and economies of scale to the contract audit process across the
government. However, this would likely entail significant costs and
operational and accountability considerations and would be an extremely
costly option involving significant infrastructure and reorganization
and would require substantial planning and analysis before deciding
whether to proceed and how to implement any changes. Some of the issues
that would need further study and analysis include the following:
Governance. Governance is the framework of rules and practices by which
a governing body, such as a board of directors, ensures accountability,
fairness, and transparency in the entity's relationship with all of its
stakeholders, including management, employees, and government. In order
to improve governance and accountability at federal agencies, a variety
of laws covering a range of management and administrative practices and
processes have been enacted. Consideration of such provisions for a
governmentwide contract audit agency should include application of
general laws related to funds control, performance and financial
reporting, accounting and internal control systems, human resources
management, and recordkeeping and access to information, among others.
Further, governance issues unique to a contract audit agency, such as
its relationships to agency contracting officers and the Congress,
should be assessed.
Scope of Work. Scope of work considerations would include roles,
responsibilities, and relationships of the governmentwide contract
audit agency and IGs with regard to contract audits. Another
consideration would be whether the new agency would be available for
consultation as an outside expert on federal agency pre-award issues.
In addition, a determination would need to be made on the handling of
fraud referrals. For example, the central new agency could have an
investigative division or it could refer potential contract fraud to
federal agency IGs for further investigation.
Funding. Congress would need to determine how to fund the new contract
audit agency. For example, funding could be provided through
appropriations or from reimbursement by federal agencies. This decision
would likely be tied to decisions on the governmentwide contract audit
agency's mandate and scope of work and any realignment of contract
audit resources.
Further study and analysis of this option would involve input from the
federal agency IGs and agency contracting and finance communities as
well as government contractors and public interest groups. Numerous
additional issues would potentially be identified and require
substantial time and cost for effective consideration and resolution.
Conclusions:
Successful accomplishment of DCAA reforms will require focused and
committed leadership at the highest levels of DOD and DCAA as well as
fundamental changes in DCAA's culture and possible congressional
action. Without leadership commitment to a strong contract audit
function and substantial changes to DCAA's mission, strategic plan, and
management environment and culture, DCAA will continue to be challenged
in its ability to perform quality audits that protect the public
interest. Many needed changes are planned or under way and can be
completed in the short-term, including revising DCAA's mission
statement, strategic plan, and monitoring, and adjusting performance
metrics. Fundamental structural and cultural changes related to
developing and implementing a comprehensive, risk-based approach for
contract audits that comply with professional auditing standards and
identifying staffing, training, and resource needs will take several
years to accomplish and implement. However, unless the overall problems
with DCAA's culture and management environment that resulted in
pervasive contract audit failures are resolved, billions of taxpayer
dollars will continue to be at risk for fraud, waste, abuse, and
mismanagement.
Recommendations for Executive Action:
We are making 15 recommendations to the Secretary of Defense to improve
the quality of the agency's audits and strengthen auditor integrity,
objectivity, and independence, including recommendations for actions on
findings in this report that are aligned with certain Defense Business
Board (DBB) findings and recommendations.
First, we recommend that the Secretary of Defense revise DCAA's mission
statement to reflect the need for quality contract audits and related
nonaudit services that take into account serving the public interest.
We also recommend that the Secretary of Defense require the Under
Secretary of Defense (Comptroller/CFO) to establish milestones for
completing DCAA corrective actions and monitor and regularly report on
DCAA progress to assure timely completion of critical actions.
In addition, we recommend that the Secretary of Defense direct the
Under Secretary of Defense (Comptroller/CFO) to require the Director of
the Defense Contract Audit Agency (DCAA) to take the following 13
actions.
The following five recommendations cover actions to address our
findings that are similar to DOD Comptroller/CFO and DBB findings.
* In concert with the revised mission statement, develop a strategic
plan with short-term and long-term outcome-related goals.
* To measure progress in achieving strategic goals, ensure that metrics
are tied to the revised mission statement and strategic plan and
support the agency's annual work plan.
* Consult with DOD stakeholders and engage outside experts to develop a
risk-based contract audit approach that identifies resource
requirements and focuses on performing quality audits that meet
generally accepted government auditing standards (GAGAS).
* Establish an SES-level position with responsibility for audit quality
assurance that requires demonstrated knowledge and experience in
applying professional audit standards.
* Consistent with DBB report observations, establish a separate DCAA
internal review organization to conduct critical internal inspector
general functions, including performing periodic internal evaluations
and reviews and addressing DCAA hotline complaints.
The following eight recommendations relate to specific GAO findings in
this report.
* In consultation with DOD stakeholders, review DCAA's current
portfolio of audit and nonaudit services to determine if any should be
transferred or reassigned to another DOD agency or terminated in order
for DCAA to comply with GAGAS integrity, objectivity, and independence
requirements.
* Based on the risk-based audit approach, develop a staffing plan that
identifies auditor resource requirements as well as auditor skill
levels and training needs.
* Establish a position for an expert on auditing standards or consult
with an outside expert on auditing standards to assist in revising
contract audit policy, providing guidance on sampling and testing, and
developing training on professional auditing standards.
* Revise DCAA audit policy to provide appropriate guidance on what
constitutes sufficient testing to comply with GAGAS. Update DCAA's
Contract Audit Manual, as appropriate.
* Develop agencywide training on government audit standards. This
training should emphasize the level of assurance intended by the
various types of engagements and provide detailed guidance on auditor
independence, planning, fraud risk, level of testing, supervision,
auditor judgment, audit documentation, and reporting.
* Conduct a comprehensive, independent review of DCAA's revised audit
quality assurance function. This review should focus on the consistent
application of criteria used for assessing audit quality and assuring
timely, consistent, and appropriate reporting of review results.
* Make appropriate recommendations to address annual quality assurance
review findings of serious deficiencies and GAGAS noncompliance,
provide training, and follow-up to assure that appropriate corrective
actions have been taken.
* Establish policies and procedures to ensure that auditors who make
direct bill decisions are independent of DCAA employees who perform a
DOD management function by reviewing vouchers of contractors not
eligible for the direct billing program, thereby reducing situations
where DCAA auditors are encouraged to reduce their office workload by
approving contractors for the direct-bill program.
Further, we recommend that the Department of Defense Inspector General
take the following two actions.
* Reconsider its overall conclusions in the May 2007 DOD IG report on
the audit of DCAA's quality control system in which it reported an
adequate ("clean") opinion on DCAA system of quality control in light
of the serious deficiencies and findings included in that report and
the additional evidence identified in our audit.
* Based on the above, determine whether the report should be rescinded
or modified.
Matters for Congressional Consideration:
In addition to our recommendations to DOD for improving DCAA audit
quality and auditor objectivity, integrity, and independence, Congress
may wish to consider the following legislative actions for enhancing
DCAA's effectiveness and independence. In considering these options,
the Congress would need to weigh DCAA's ability to accomplish
significant reforms within its current environment and the cost and
administrative effort involved with the alternative options along with
the potential benefits. Timing would also need to be considered, given
significant reforms that DCAA is already undertaking and the additional
burden that a change in organizational placement would add at this
time.
* In the short term, as DCAA makes progress in correcting fundamental
weaknesses that have impacted audit quality, Congress could consider
enhancing DCAA reform efforts by enacting legislation to grant it
protections and authorities similar to those embodied in the Inspector
General Act, as amended.
* In the medium term, Congress could consider elevating the contract
audit function within DOD by moving DCAA from under the DOD
Comptroller/CFO and placing it under the Deputy Secretary of Defense.
* In the longer term, depending on the outcome of acquisition
management reform initiatives under way and the success of DCAA
management reforms, Congress could consider creating an independent,
governmentwide contract audit agency. Legislation to move DCAA should
incorporate the protections and authorities similar to those embodied
in the Inspector General Act, if these have not already been granted to
DCAA.
Agency Comments and Our Evaluation:
We made a total of 17 recommendations, including 15 recommendations to
DOD to improve DCAA's management environment, audit quality, and
oversight; and we made 2 recommendations to the DOD IG regarding DCAA's
last peer review. We received written comments from the Department of
Defense (DOD) on September 8, 2009, and we received written comments
from the DOD Inspector General (IG) on September 3, 2009. DOD stated
that the department concurs with all but one of our 15 recommendations.
DOD also stated that the Department and DCAA are committed to taking
the necessary corrective actions to address our findings and that the
department will continue to monitor DCAA to ensure timely completion of
critical actions to address our recommendations. DOD also provided
comments on our matters for congressional consideration. Although DOD
disagreed with the matters we discussed, we continue to believe these
are valid matters for congressional consideration. The DOD IG concurred
with our recommendation to reconsider the conclusions in its May 2007
peer review report on DCAA; the IG did not concur with our
recommendation to determine whether to rescind or modify its peer
review report. DOD's written comments are reprinted in appendix IV, and
the DOD IG's written comments are reprinted in appendix V. We summarize
and evaluate the DOD and DOD IG comments and responses to our
recommendations below. We made technical corrections and clarifications
suggested by DOD in the body of our report, where appropriate.
DOD Comments and Our Response:
DOD's written comments include (1) comments on our 15 recommendations,
(2) comments on matters we presented for congressional consideration,
(3) a list of DCAA corrective actions, (4) DCAA clarifications, and (5)
comments from the Director, Defense Procurement and Acquisition Policy.
DOD officials fully concurred with 13 of our 15 recommendations for
improving DCAA audits, partially concurred on one recommendation, and
did not concur with one recommendation. We view DOD comments as being
generally responsive to the intent of our recommendations. Our
discussion of DOD's response to our matters discussion and our findings
and recommendations follow. We provide additional comments on specific
sections of the DOD response letter in appendix IV.
With regard to the matters we presented for congressional
consideration, DOD stated that it generally opposes providing DCAA with
authorities similar to those contained in the Inspector General Act.
DOD stated that it specifically opposes certain recommendations based
on the IG model if DCAA remains within DOD, including (1) a
Presidentially-appointed and Senate-confirmed DCAA Director, unless
DCAA is independent of DOD, (2) fixed terms for the DCAA Director, (3)
an independent budget, and (4) mandatory public reporting. DOD also
stated that it plans to take steps to strengthen DCAA's independence by
establishing an appeals process that permits DCAA to seek resolution
when there are differences of opinion as to the resolution of its audit
findings. Finally, DOD opposes moving DCAA from under the DOD
Comptroller/CFO and placing it under the Deputy Secretary. DOD pointed
out that the Deputy Secretary is the Chief Management Officer of one of
the world's largest organizations and backs up the Secretary in the
wartime chain of command, and he does not have the time to provide
oversight and support to individual defense agencies.
Although DOD did not agree with these matters, we believe they provide
important information for Congress to consider. For example, the
Inspector General Act provides many important authorities and
protections for IG's that could enhance DCAA's independence and
effectiveness. DOD disagreed with the Presidential appointment and
Senate confirmation provision because it believes this would inject a
political element into DCAA that is not appropriate and could create
lengthy periods where there is no Director. DOD also opposes fixed
terms for the DCAA Director because it believes the Secretary of
Defense must have the ability to choose an appropriate Director. Our
position with regard to appointments of IGs has been that Presidential
appointments with Senate confirmation enhance their independence from
the entities they audit and investigate. We recognize that DCAA serves
a different role than IGs. We looked to the IG Act model to identify
provisions that enhance the independence of auditors. A political
appointment would elevate the status of the Director among DCAA's
stakeholders and, as a consequence, give DCAA more authority to respond
to actions taken by its stakeholders to influence its independent audit
work. A fixed term would provide stability, especially during a time of
organizational change. DOD also questioned the wisdom of an independent
budget because it would limit its ability to move money into DCAA, as
is occurring now based on funding from the Defense Acquisition
Workforce Development Fund. Separate appropriations are a key
independence provision for IGs. The ability to reprogram funds within
the Defense-wide Operations and Maintenance appropriation can involve
both increases and decreases. Our analysis of DCAA reprogrammings over
the last three years showed that funds were also moved from DCAA to
other DOD organizations within the Defense-wide operations and
maintenance appropriation. In DCAA's case, the reprogrammings to reduce
funding generally related to large unobligated balances--showing that
DCAA under executed its budget. We believe this is important
information that Congress would want to know. Further, we do not see a
reason why DOD could not receive approval to transfer funds to DCAA
from another fund if it had a separate budget. For example, providing
DCAA with funds from the Defense Acquisition Workforce Development Fund
constitutes a transfer (not a reprogramming), the authority for which
is provided in the legislation governing the Fund, 10 U.S.C. § 1705(e).
DOD also opposed mandatory public reporting by DCAA. We believe that
periodic reporting to Congress and the public on the results of DCAA's
work will enhance accountability over DCAA. As discussed in our report,
DCAA needs time to address the fundamental weaknesses in mission and
the overall management environment. However, if DCAA is not successful
in resolving these problems under its current organizational placement,
it will be necessary to consider additional actions. In this regard, it
may be worthwhile to consider elevating DCAA as a component agency
reporting to the Deputy Secretary because this could enhance DCAA's
independence by providing it more authority within DOD and increase
DCAA's visibility both within and outside of DOD.
DOD partially concurred with our recommendation that DCAA consult with
DOD stakeholders and engage outside experts to develop a risk-based
contract audit approach that identifies resource requirements and
focuses on performing quality audits that meet GAGAS. DOD stated that
DCAA already has a risk-based contract audit approach in identifying
resource requirements and considers audit risk in planning various
assignments. DOD stated that DCAA will coordinate with the Under
Secretary of Defense for Acquisition, Technology, and Logistics (USD
(AT&L)) to assess DCAA audit requirements.[Footnote 105] DOD also noted
that one of DCAA's cultural transformation projects is identifying and
resolving differing stakeholder expectations while ensuring DCAA
performs quality audits that meet GAGAS. DOD expects to complete its
assessment of stakeholder needs based on regulatory and statutory
requirements by December 2010. We appreciate these steps; however, we
remain concerned that DCAA's current approach of performing 30,000 to
35,000 audits and issuing over 22,000 audit reports with 3,600 auditors
substantially contributed to the widespread audit quality problems we
identified. Generating that many reports and doing that many audits
with 3,600 auditors leaves very little time to perform in-depth,
complex audits of contractors. While the Director of Defense
Procurement and Acquisition Policy commented that contract audits need
to be completed "in time to be useful," to assure timely, quality
audits, DCAA will need a risk-based approach to determine the
appropriate level of audit and nonaudit effort and staffing.
DOD did not concur on our recommendation to develop policies and
procedures related to direct-billing decisions, stating that (1) the
department believes that a review of the contractor's interim public
vouchers is an integral function of DCAA's continual assessment of a
contractor's billing system (2) DCAA is in the best position to review
and approve contract interim billings based on its thorough
understanding of the contractor's system, (3) DOD believes that our
concerns are mitigated based on the comprehensive supervisory and audit
manager reviews, and (4) DCAA does not believe that the approval of
interim vouchers along with the approval for contractors to be on
direct billing results in a lack of auditor objectivity.
We continue to believe that DCAA's management (nonaudit) responsibility
to perform prepayment reviews of contractor vouchers for DOD and the
auditor's decision making role of approving contractors for direct
billing privileges based on its audit conclusions about the strength of
the contractor's system of internal controls, create audit objectivity
issues. We revised our findings discussion and our recommendation to
clarify this point. Under normal circumstances, DCAA must review
contractor vouchers prior to payment--a management support function for
DOD generally performed by DCAA field office administrative staff. By
obtaining direct billing privileges, contractors can receive payment
for goods and services without a voucher review by DCAA prior to
payment. Because we found that this situation provides an incentive for
DCAA to reduce its administrative workload by recommending that
contractors are placed on direct billing, we recommended that DCAA
develop new policies and procedures to ensure a separation between
staff reviewing vouchers and staff making direct-bill decisions. In
addition, DCAA has not explained the basis for its belief that
administrative staff have a thorough understanding of the contractors'
systems. Further, we disagree with DOD's statement that our concerns
are mitigated based on the comprehensive supervisory and audit manager
reviews because this is not supported by our findings. The fact that
DCAA approvals of contractor direct-bill privileges were not based on
sufficient audit procedures as demonstrated by our work and DCAA's
removal of over 200 contractors from the direct-bill program since our
July 2008 report[Footnote 106] support our concern that the existence
of such an incentive presents an objectivity impairment.
DOD provided additional comments on findings in its transmittal letter.
DOD stated that it disagrees with the suggestion in our report that the
department has not yet begun to address the weaknesses we identified.
Our report neither states nor implies that DOD has not yet begun to
take action. In fact, one of our objectives was to analyze steps DOD
has taken so far, and our report describes in detail the progress made.
Our report acknowledges that several positive steps have been taken by
DCAA, but much more needs to be done to address the fundamental
problems. Thus, solutions to the problems documented in this report
will take time to first implement and then will have to be
independently assessed to make sure they are effective. Our report also
notes that fundamental changes have not taken place. For example, to
date DOD has not revised DCAA's mission statement to reflect the need
to consider the public interest as a key component of its work. In
addition, DCAA has yet to assess the feasibility of 3,600 auditors
issuing over 20,000 reports in one year (22,349 in fiscal year 2008)
and the appropriateness and need for the current combination of audit
and non-audit services that drives this workload. Until these and other
key steps are further along, it will be too early to assess whether
DCAA has fundamentally changed or whether past practices continue.
The DOD comments noted that one of our major findings is the lack of
sufficient testing to support conclusions when giving an opinion on
contractor internal control systems. The comments incorrectly refer to
the requirement for sufficient testing as a GAO requirement and state
that planned staffing increases may not be enough to accomplish audits
required by regulation in light of additional testing stipulated by
GAO. Professional audit standards have always required auditors to
obtain sufficient evidence to provide a reasonable basis for the
conclusion expressed in the report. As stated in our report, testing
methodologies are a matter of professional judgment and can involve
many factors. However, our findings reflect more than a difference of
opinion with DCAA auditors on their exercise of professional judgment
as reflected, in part, by the number of audit reports DCAA rescinded
for insufficient testing. For example, we found insufficient
documentation to support the methodology chosen and insufficient
reasons for minimal testing, such as being told by a DCAA auditor that
a "file size was too large" to test more than two recent vouchers.
Again, DOD must address the feasibility of 3,600 auditors issuing over
22,000 reports annually, most of which were reportedly performed under
auditing standards. This may entail not only a risk-based audit
approach but also exploring changes to the regulations that DOD
represents require tens of thousands of these audits.
DOD also disagreed with our position on the status of actions to
strengthen DCAA's quality assurance program. DOD stated that DCAA has
been proactive in standing up its new Integrity and Quality Assurance
Directorate. DOD also stated that it believes the extensive overhaul of
the quality assurance function accomplished in fiscal year 2009 will
mitigate the prior shortcomings in audit quality that we cited.
Although DOD's comments imply that DCAA has resolved its quality
assurance problems, DCAA has acknowledged that it is not ready to
undergo another peer review at this time. On September 1, 2009, we
received a letter from the DCAA Director, stating that although
improvements were put in place in fiscal year 2009, several significant
improvements will be accomplished in fiscal year 2010. To allow
sufficient time for DCAA to fully implement the necessary corrective
actions, DCAA contacted us for guidance on (1) deferring its external
quality control review for 2 years and (2) requesting that the next
external peer review to cover assignments to be completed in fiscal
year 2011. We agree with DCAA that it is not cost-effective to undergo
an external peer review until an adequate system of quality control is
in place. Expending substantial DOD IG resources when DCAA acknowledges
that several years are necessary for improvements to be fully
implemented is, in our view, an inefficient use of resources. DCAA has
already begun to appropriately disclose in its reports that its audits
do not comply with GAGAS external peer review requirements.
The Director of Defense Procurement and Acquisition Policy (DPAP)
provided additional comments. The Director stated that our report
impugns DCAA's audits and that we adopt the position that because DCAA
is serving the interests of contracting officers, DCAA is therefore not
auditing in the interest of the public. The Director further asserts
that DCAA serves the public interest by providing useful and timely
information to contacting officers, and that it is erroneous to imply
that contracting officers do not seek to protect the public interest.
Also, the Director states that GAO agrees with the Defense Business
Board's recommendation to revise DCAA's mission to reflect a focus on
the taxpayer as the primary customer. Finally, the Director suggests
that our criticism of DCAA's "production-oriented auditing" sets up a
dichotomy between quality and timely audits. We disagree with these
characterizations of our report.
DPAP's statements that our report impugns DCAA's audits and that we
take the position that when DCAA is serving the interests of
contracting officers, it is not auditing in the interest of the public
relate to our summarization of the Defense Business Board (DBB) report
and not our findings. Our report does not endorse the specific
recommendations of the DBB to focus on the taxpayer as the primary
customer. As our report points out, this recommendation does not take
into account the regulatory and policy requirements that establish
DCAA's primary role as an advisor to government contracting officers
and disbursing officers. However, we agree with the DBB that DCAA
should consider the public interest when carrying out GAGAS
engagements. For audits and attestation engagements conducted under
GAGAS, the auditor is expected to objectively and independently acquire
and evaluate sufficient, appropriate evidence, and report on the
results, consistent with the guidance in GAGAS.[Footnote 107] GAGAS
states the principle that "observing integrity, objectivity, and
independence in discharging [auditors'] professional responsibilities
assists auditors in meeting the principle of serving the public
interest and honoring the public trust."[Footnote 108]
DPAP also stated that the contracting officer is bound by regulation to
meet the public interest in the broadest sense, for the entire matter
surrounding a contract and that this includes factors other than DCAA
audit findings and recommendations. As reflected in the extensive
background discussion and elsewhere throughout our report, we recognize
that contracting officers make final contracting decisions, and DCAA
engagements support contracting officers in that process. Because we
did not review the standards that contracting officers must follow, we
did not include references to the requirements for contracting officers
to protect the public interest in their actions. Our report also states
that DCAA contract audit services are intended to be a key control to
help assure that prices paid by the government for needed goods and
services are fair and reasonable and that contractors are charging the
government in accordance with applicable laws, regulations (e.g.,
Federal Acquisition Regulation (FAR) and Defense Federal Acquisition
Supplement (DFARS), standards (e.g., Cost Accounting Standards (CAS)),
and contract terms. In providing this assurance, DCAA audits would
necessarily take into account serving the public interest. However,
when DCAA audits do not meet GAGAS, they do not provide this assurance
and thus are not serving the public interest. We found that DCAA
auditors lacked objectivity and independence when performing GAGAS
audits and engagements. In many cases, this was a result of auditors'
focus on expediency to support client needs and, as the Director also
observes, human capital shortages and poor management decisions. We do
not question the need for contracting officers to use the services of
advocates and assistants in carrying out their duties. However, when
contract auditors represent that they are performing engagements under
GAGAS, their primary focus should be on the integrity, objectivity, and
independence of their work, which serves both contracting officers and
the public interest. Further, the quality of DCAA audits impacts the
quality of information available for contracting officer decisions.
Whether DCAA can adhere to GAGAS on contract audits that provide
minimal time to perform the work is a factor that USD (AT&L) should
consider when establishing requirements for contract audit services. As
we recommended, DOD should reconsider the mix of audit and non-audit
services that it needs.
DOD IG Comments and Our Response:
The DOD IG concurred with our recommendation to reconsider its overall
conclusions in the May 2007 report on the audit of DCAA's quality
control system in which it reported an adequate ("clean") opinion on
DCAA's system of quality control in light of the serious deficiencies
and findings included in that report and the additional evidence
identified in our audit. The IG also stated that it did not concur with
our recommendation to rescind the report and, because of that
statement, we believe the IG misconstrued our recommendation as
expressly calling for a rescission or modification of its peer review
report. Our recommendation was for the IG to determine, based on the
results of our recommended reconsideration of the IG's conclusions,
whether it should rescind or modify the peer review report.
The DOD IG also states that it took alternative action that conformed
to the intent of our recommendation. The DOD IG comments state that it
notified DCAA on August 24, 2009, that the May 2007 "adequate" opinion
on DCAA's system of quality control would expire on August 26, 2009. In
addition, the IG stated, "We have determined that it is not prudent to
allow the adequate opinion from our May 2007 report to carry forward."
However, peer review opinions neither "expire" nor "carry forward"
beyond the period covered by the peer review. Peer review opinions
cover the period to which the opinion applied--in DCAA's case, as of
the end of fiscal year 2006--and the peer reviewed audit organization
need not undergo another peer review during the next 2 years.[Footnote
109] Because it has been more than 3 years since DCAA's last peer
review, DCAA is no longer in compliance with the GAGAS requirement for
an external peer review, and DCAA has taken appropriate action to
disclose this noncompliance in its reports.
As stated in our report, the overall conclusion in the DOD IG report is
inconsistent with the detailed observations in its report, which
indicate numerous significant deficiencies in DCAA's system of quality
control. Further, based on DCAA's actions to rescind 80 audit reports,
39 of which were issued in fiscal year 2006--the period on which the IG
conclusions are based--and the findings in our audit, we concluded that
DCAA's quality control system for the period covered by the DOD IG peer
review was not effectively designed and implemented to provide
assurance that DCAA and its personnel comply with professional
standards.
As agreed with your office, unless you publicly announce the contents
of this report, we plan no further distribution for 30 days from the
report date. At that time, we will send copies of this report to the
Secretary of Defense; the Under Secretary of Defense (Comptroller/CFO);
the Under Secretary of Defense for Acquisition, Technology, and
Logistics; the DOD Director for Defense Procurement and Acquisition
Policy; the Deputy General Counsel for Acquisition; the Secretary of
the Army; the Secretary of the Navy; the Secretary of the Air Force;
the Director of DCAA, the Director of DCMA; the DOD Inspector General;
and the Director of the Office of Management and Budget. In addition,
this report will be available at no charge on the GAO Web site at
[hyperlink, http://www.gao.gov]. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report.
If you or your staff have any questions concerning this report, please
contact me at (202) 512-7922 or kutzg@gao.gov or Gayle Fischer,
Assistant Director, Financial Management and Assurance at (202) 512-
9577 or fischerg@gao.gov.
Signed by:
Gregory D. Kutz:
Managing Director:
Forensic Audits and Special Investigations:
[End of section]
Appendix I: Internal Control System Audits Did Not Meet Professional
Standards:
In performing its audits, the Defense Contract Audit Agency (DCAA)
states that it follows generally accepted government auditing standards
(GAGAS).[Footnote 110] As part of our assessment of DCAA's overall
management environment and quality assurance structure, we reviewed
documentation for selected DCAA audits of contractor systems controls
for compliance with GAGAS. We focused on internal control audits
because contracting officers rely on DCAA audit opinions on contractor
system controls for 3 or more years to make decisions on pricing and
contract awards and DCAA uses the audit opinions to assess risk when
planning subsequent audits. We selected seven DCAA field audit offices
(FAO) across the five DCAA regions that reported predominately adequate
("clean") opinions on contractor controls. For the seven FAOs, we
reviewed 37[Footnote 111] selected audits of contractor internal
control systems, including accounting, estimating, billing, and
indirect and other direct cost systems. As shown in table 5, we
assessed these audits for compliance with eight key areas of GAGAS
requirements: (1) auditor independence;[Footnote 112] (2) adequate
planning; (3) auditor understanding of controls; (4) design of
procedures to detect risk of fraud, abuse, mismanagement, and contract
terms; (5) documentation of sampling and testing; (6) audit evidence
supports conclusions and opinion; (7) proper supervision; and (8)
timely reporting and disclosures.[Footnote 113] We also considered
GAGAS requirements for protecting the public interest when using
auditor judgment.[Footnote 114] As discussed in the body of this
report, the 37 audits we reviewed did not comply with GAGAS in one or
more of these areas. However, we determined that 4 of the 37 audits
included sufficient testing to support reported conclusions and
opinions. Because the conclusions and opinions in the deficient audits
were used to make risk assessments and determine the level of testing
in other DCAA audits, such as annual audits of contract or incurred
cost claims, audits of contract proposals and contractor forward
pricing proposals, progress pay audits, and contract close-out audits,
the audit quality issues related to the GAGAS noncompliance we
identified potentially impacts hundreds of other audits and contracting
decisions covering billions of dollars in DOD expenditures.
Table 5: GAGAS Noncompliance on 37 Selected Audits of Contractor
Controls:
Reasons for GAGAS noncompliance: Independence impairments;
DCAA regions: Northeast: (FAO #1): 0;
DCAA regions: Mid-Atlantic: (FAO #2): 0;
DCAA regions: Eastern: (FAO #3): 1;
DCAA regions: Central (FAO #4 & 5): 2;
DCAA regions: Western (FAOs #6 & 7): 4;
DCAA regions: All regions: 7.
Reasons for GAGAS noncompliance: Inadequate planning;
DCAA regions: Northeast: (FAO #1): 0;
DCAA regions: Mid-Atlantic: (FAO #2): 4;
DCAA regions: Eastern: (FAO #3): 1;
DCAA regions: Central (FAO #4 & 5): 5;
DCAA regions: Western (FAOs #6 & 7): 7;
DCAA regions: All regions: 17.
Reasons for GAGAS noncompliance: Inadequate auditor understanding of
controls;
DCAA regions: Northeast: (FAO #1): 1;
DCAA regions: Mid-Atlantic: (FAO #2): 4;
DCAA regions: Eastern: (FAO #3): 0;
DCAA regions: Central (FAO #4 & 5): 2;
DCAA regions: Western (FAOs #6 & 7): 5;
DCAA regions: All regions: 12.
Reasons for GAGAS noncompliance: Lack of fraud risk detection
procedures;
DCAA regions: Northeast: (FAO #1): 4;
DCAA regions: Mid-Atlantic: (FAO #2): 5;
DCAA regions: Eastern: (FAO #3): 6;
DCAA regions: Central (FAO #4 & 5): 11;
DCAA regions: Western (FAOs #6 & 7): 9;
DCAA regions: All regions: 35.
Reasons for GAGAS noncompliance: Insufficient documentation on sampling
methodology;
DCAA regions: Northeast: (FAO #1): 3;
DCAA regions: Mid-Atlantic: (FAO #2): 5;
DCAA regions: Eastern: (FAO #3): 6;
DCAA regions: Central (FAO #4 & 5): 9;
DCAA regions: Western (FAOs #6 & 7): 4;
DCAA regions: All regions: 27.
Reasons for GAGAS noncompliance: Insufficient evidence to support
conclusions and opinion;
DCAA regions: Northeast: (FAO #1): 3;
DCAA regions: Mid-Atlantic: (FAO #2): 5;
DCAA regions: Eastern: (FAO #3): 6;
DCAA regions: Central (FAO #4 & 5): 11;
DCAA regions: Western (FAOs #6 & 7): 8;
DCAA regions: All regions: 33.
Reasons for GAGAS noncompliance: Improper Supervision;
DCAA regions: Northeast: (FAO #1): 0;
DCAA regions: Mid-Atlantic: (FAO #2): 0;
DCAA regions: Eastern: (FAO #3): 2;
DCAA regions: Central (FAO #4 & 5): 5;
DCAA regions: Western (FAOs #6 & 7): 6;
DCAA regions: All regions: 13.
Reasons for GAGAS noncompliance: Reporting problems;
DCAA regions: Northeast: (FAO #1): 4;
DCAA regions: Mid-Atlantic: (FAO #2): 5;
DCAA regions: Eastern: (FAO #3): 6;
DCAA regions: Central (FAO #4 & 5): 12;
DCAA regions: Western (FAOs #6 & 7): 10;
DCAA regions: All regions: 37.
Total GAGAS noncompliance issues:
DCAA regions: Northeast: (FAO #1): 15;
DCAA regions: Mid-Atlantic: (FAO #2): 28;
DCAA regions: Eastern: (FAO #3): 28;
DCAA regions: Central (FAO #4 & 5): 57;
DCAA regions: Western (FAOs #6 & 7): 53;
DCAA regions: All regions: 181.
Number of audits:
DCAA regions: Northeast: (FAO #1): 4;
DCAA regions: Mid-Atlantic: (FAO #2): 5;
DCAA regions: Eastern: (FAO #3): 6;
DCAA regions: Central (FAO #4 & 5): 12;
DCAA regions: Western (FAOs #6 & 7): 10;
DCAA regions: All regions: 37.
Rescinded reports:
DCAA regions: Northeast: (FAO #1): 1;
DCAA regions: Mid-Atlantic: (FAO #2): 3;
Eastern: (FAO #3): 3;
DCAA regions: Central (FAO #4 & 5): 7;
DCAA regions: Western (FAOs #6 & 7): 4;
DCAA regions: All regions: 18.
Source: GAO analysis of selected DCAA audits.
Note: Because of the large size of the Central and Western regions, we
tested audits at more than one field audit office in these regions.
[End of table]
The following discussion includes examples of GAGAS noncompliance from
specific audits we reviewed.
Independence Impairments:
GAGAS state that the audit organization and the individual auditor
should be free, both in fact and appearance, from personal, external,
and organizational impairments to independence.[Footnote 115] Our
review of 37 audits of contractor internal controls found evidence in
documentation for 7 audits that DCAA independence was compromised
because auditors provided material nonaudit services to a contractor
they later audited; experienced access-to-records problems that were
not resolved; delayed report issuance, which allowed the contractor to
resolve cited deficiencies, without proper reporting; and performed
test work on billings the contractor selected for testing. GAGAS state
that auditors should be free from influences that restrict access to
records or improperly modify audit scope.[Footnote 116] GAGAS also
state that audit organizations should not audit their own work or
provide nonaudit services if the services are significant or material
to the subject matter of the audit.[Footnote 117] The following
examples describe a situation where auditors assisted a Department of
Defense (DOD) contractor in developing billing system policies and
procedures after identifying five significant deficiencies and then
reviewed their own work during a follow-up audit.
Text box:
DCAA Auditors Issued an Adequate Opinion on Controls They Helped
Design; DCAA auditors impaired their independence by performing
nonaudit services for one of the top five DOD contractors in terms of
dollars when they helped the contractor develop policies and procedures
that were material to the billing system they were auditing. On May 12,
2005, DCAA reported an inadequate-in-part opinion on the contractor's
billing system internal controls. The report included five significant
deficiencies, including a failure to maintain current, adequate billing
system policies and procedures. After issuing the report, DCAA auditors
helped the contractor develop adequate policies and procedures related
to accounts receivable, overpayments, and monitoring of the billing
system before performing the required follow- up audit--an impairment
to auditor independence. A year later, after performing the follow-up
audit, DCAA auditors concluded that the contractor had performed
adequate actions to correct all of the billing system deficiencies
previously reported. On June 28, 2006, DCAA reported an adequate
opinion on the contractor's billing system internal controls. Following
GAO's review of these audits, on March 6, 2009, DCAA rescinded the
billing system audit follow-up report.
[End of text box]
We also noted instances of denials and limitations on access to records
by contractors that were not handled properly. For example, during a
billing system audit of one of the top five DOD contractors, an e-mail
message documented in the audit workpapers showed that the auditors
were challenged by a contractor official when they requested
documentation to test whether billing clerks had received required
training. The contractor's e-mail stated, "Here's a question for you.
Can you tell me who and what requirement is making this part of the
[audit]. This is a question that [is] being asked by [the Cash
Manager]." The auditors eventually obtained limited training
documentation from the contractor. Audit documentation and our
interviews with the auditors revealed that the auditors also limited
testing in several other areas "because the contractor would not
appreciate it." Access to records problems and strong external
influence to limit testing are both impairments to independence
according to GAGAS.[Footnote 118]
Inadequate Planning:
GAGAS for attestation engagements state that the work shall be
adequately planned.[Footnote 119] Auditors should communicate
information regarding the nature, timing, and extent of planned testing
and reporting to officials of the audited entity and to the individuals
contracting for or requesting the attestation engagement. Auditors
should also plan work to follow up on actions to address significant
findings and recommendations in previous audits and assess areas of
risk in planning the engagement. However, our review of the audit
documentation determined that 17 of the 37 internal control audits we
reviewed were not adequately planned.
* In five audits, auditors failed to consider risk associated with new
systems that had not yet been audited or systems that had not been
audited in more than 4 years. These audits should have been ascribed a
higher risk level according to DCAA CAM guidance and testing should
have been increased.[Footnote 120] DCAA has rescinded three of the five
audits and is planning new audits, as appropriate.
* Without documenting the basis for their decisions, auditors deleted
audit steps from standard audit programs or did not perform all audit
steps for three of seven audits we reviewed at one FAO. When we asked
the auditors why they omitted key audit procedures in their work, the
auditors told us they used "auditor judgment." However, the auditors
would not explain the basis for their judgments to us or their
rationale for omitting key procedures, such as assessing the
contractor's control environment and testing the implementation of a
contractor's policies and procedures. Because we did not find any
justification for omitting key audit procedures in these three audits,
we determined that they were inadequately planned.
The following case discussion illustrates deficiencies in audit
planning as well as a lack of auditor understanding of contractor
processes and controls.
Text box:
DCAA Erroneously Performed an Audit over a Billing System That Did Not
Exist; In 2004, a Western Region FAO planned a billing system audit of
a federally funded research and development center (grantee) that
receives $1.5 billion annually for research services. However, the
planning for this billing system audit did not take into account the
fact that grantees are funded through letters of credit and do not
actually bill the government. This financial relationship is very
different--and much less complicated--than a situation where a
contractor bills the government for contract costs in accordance with
Cost Accounting Standards and the Federal Acquisition Regulation. For
example, under a letter of credit financing arrangement, grantees draw
funds as disbursements are made and are required to prepare reports of
transactions on their use of the funds and submit them to the funding
agency. Despite this obvious mistake, on May 6, 2005, DCAA auditors
issued a report stating that the grantee had an "adequate billing
system."; Another report issued by the same DCAA office on June 25,
2004, reviewed the grantee's cash management practices under the Single
Audit Act for another federal agency. The auditors could have simply
forwarded this report to the DOD contracting officer--a task that would
take an hour at the most to complete. Instead, DCAA auditors charged
over 530 staff hours to generate documentation to meet DCAA's billing
system audit requirements, even though there was no related "billing
system." As a result of our review, DCAA reassessed the need to perform
a billing system audit for the grantee and determined that it would
rely on the Single Audit Act reports in the future. DCAA has not
rescinded the audit report even though it expresses an opinion on a
nonexistent system.
[End of text box]
Auditors Did Not Properly Document Understanding of Controls for
Several Audits:
GAGAS require that in planning examination-level attestation
engagements, auditors should obtain a sufficient understanding of
internal control that is material to the subject matter and design
procedures to achieve the objectives of the audit.[Footnote 121] The
subject matter or assertion the auditor is testing may relate to the
effectiveness and efficiency of operations, including the use of an
entity's resources; the reliability of financial reporting, including
reports on budget execution and other reports for internal and external
use; compliance with applicable laws and regulations, provisions of
contract, or grant agreements; and safeguarding of assets.[Footnote
122] Although most of the 37 internal control audits we reviewed met
this standard, 12 audits did not. The following case study shows an
example of insufficient understanding of controls.
* On five audits, auditors overstated the strength of the contractor's
control environment in the audit documentation and used this
information to justify performing little or no testing of controls for
accounting and billing system control audits. On two of the five
audits, a Mid-Atlantic Region auditor admitted that he included
inaccurate statements in the audit documentation. These statements
indicated that the contractor performed internal audits and had a
formal management-level monitoring process over accounting and billing
functions. When we requested copies of the internal audits and
management reviews, the auditor admitted that these statements were not
true and that he had made "mistakes." He entered the factually
incorrect information in the audit documentation to justify performing
little or no testing. The auditor was a GS-13 technical specialist who
reviewed the work of other auditors and provided them audit guidance.
DCAA has rescinded four of the five audits and is planning or
initiating new audits.
* On another audit involving a business segment of a third contractor
of the top 5 DOD contractors, auditors did not consider the
contractor's control environment in planning an audit of a new
accounting system--a significant factor that resulted in insufficient
testing. Further, after identifying significant accounting system
deficiencies, including that certain contract costs are manually
processed, are not processed timely, or are not adequately reconciled
to actual incurred costs, the auditors delayed issuance of the audit
report for about 16 months, waiting to see if the contractor would take
corrective actions on the identified deficiencies. Although test
procedures were applied from February 25, 2004, to September 15, 2004,
DCAA reported an "inadequate-in-part" opinion on the contractor's
accounting system on March 14, 2006--nearly 1-1/2 years later, without
performing any additional testing. Following discussions with GAO, DCAA
rescinded this audit report on November 20, 2008.
In the audit described below, the auditor relied on the contractor to
document the auditor's understanding of controls.
[Text box:
DCAA Auditors Relied on the Contractor to Document Internal Controls
without Testing the Accuracy of the Documentation; This case involves a
billing system audit DCAA conducted in 2006. The last time DCAA had
tested the billing system for this contractor was in 2000--a clear
indication that new tests should be performed. At that time, DCAA's CAM
required that contractor internal control systems be audited every 2 to
4 years. However, rather than re-testing the billing system, DCAA
auditors provided the contractor's Information Systems Manager with 6-
year-old documentation obtained during a DCAA auditor's walkthrough of
the billing process in the prior audit. The DCAA auditors asked the
Information Systems Manager to update the documentation by making edits
where necessary. According to the audit workpapers, the 6-year-old
documentation was "edited by the contractor" and provided back to the
DCAA auditor. Based on the contractor's documentation of the billing
system internal controls, the auditor concluded "we can limit our
testing of management reviews, policies and procedures, and
implementation of policies and procedures." The auditor then traced one
paid voucher through the billing process. This procedure relates to
determining whether the auditor's understanding of the process is
correct and is not substantive testing (i.e., detailed tests of
transactions and balances and analytical review procedures.) The
auditor told GAO that she used this "low-risk approach" because she
felt that the contractor's system was "strong" and did not warrant a
higher risk approach. However, according to the documentation GAO
reviewed, the billing system was a software package that downloads
accounting system data to spreadsheets. Manual calculations were then
used to develop invoice amounts--a process that is prone to errors and
does not provide assurance of consistent systematic processing of
invoices. Further, since DCAA's earlier walkthrough in 2000, the
contractor had experienced significant downsizing and restructuring.
The auditor performed no testing of the contractor's billing system
controls in order to determine whether the system was operating
effectively at the time of the audit. The audit report that was issued
on June 21, 2006, with an adequate opinion was not based on sufficient
audit procedures to provide assurance over approximately $76 million in
sales to the government. After GAO raised concerns about this audit,
DCAA rescinded the audit report on March 3, 2009.
[End of text box]
Failure to Design and Perform Procedures to Detect Fraud Risk:
For DCAA examination-level attestation audits of contractor controls
that we reviewed, GAGAS requires auditors to design and perform audit
steps to obtain reasonable assurance of detecting fraud, illegal acts,
or violations of provisions of contracts that could have a material
effect on the subject matter of the engagement or internal control.
[Footnote 123] DCAA management asserts that its examination-level
audits are designed to provide this assurance, and DCAA internal
guidance requires auditors to consider a list of fraud indicators
included in DCAA's CAM[Footnote 124] or the DOD Inspector General's
Handbook on Fraud Indicators[Footnote 125] in planning and performing
their work. However, for 35 of the 37 internal control audits we
reviewed there was no evidence that DCAA auditors designed specific
procedures to identify risk of fraud, illegal acts, violations of
contract terms, or other improprieties. Further, our analysis of audit
workpapers showed that DCAA auditors lacked an understanding of fraud
indicators associated with weak internal controls. For example,
although segregation of duties is a key fraud-prevention control, in
the seven audits where workpapers identified segregation of duties
issues, the auditors did not consider a lack of segregation of duties
to be a fraud risk in 6 of the audits. The auditors did not look for a
compensating control or perform additional procedures to determine
whether the lack of segregation of duties had allowed fraud to occur.
Occurrences of duplicate invoices also would increase the risk of
fraud. However, DCAA's audit program for testing contractor billing
system controls does not include specific procedures to test for
duplicate contractor invoices. We found evidence of testing related to
duplicate invoices in only 2 of the 37 internal control audits we
reviewed. Moreover, in the audit described below, DCAA FAO managers
ordered an auditor to ignore significant fraud risks during an audit.
[Text box:
DCAA FAO and Region Management Prevented an Auditor from Pursuing
Significant Fraud Risks during a Billing System Audit; During a fiscal
year 2003 incurred cost audit of a major defense contractor, a DCAA
Central Region auditor learned of a fraud investigation initiated by
the Army's Criminal Investigative Division (CID) in response to
allegations of contractor fraud reported in August 2002. In July 2004,
during a billing system audit of the same contractor, the auditor
contacted the Army CID investigator to discuss the ongoing fraud
investigation and learned that the fraud related to improper billings.
As a result of this elevated fraud risk, the auditor requested several
nominal increases in budget hours to perform additional testing to
determine the extent of the fraud. The auditor had prior DOD contract
administration experience and intended to use this experience in
applying her audit testing procedures. After approving increases in
budgeted hours for this assignment, the regional audit manager told the
auditor that her concerns were not valid and to remove her "contracting
hat." Eight months later, on April 28, 2005, the auditor submitted a
draft audit report to her supervisor. She concluded that the
contractor's billing system was inadequate--a finding that would have
resulted in the contractor losing its direct-billing privileges. The
auditor noted several deficiencies and concerns, including (1) the lack
of billing policies and procedures, (2) a lack of training for
contractor employees responsible for preparing invoices, (3)
indications that the contractor may have billed the government for
unapproved and unfunded work, and (4) evidence of an ongoing criminal
investigation by the Army CID. After reviewing the report, the
supervisor and FAO manager directed the auditor to change the opinion
from inadequate to inadequate-in-part because the auditor had not
identified any excess or unallowable costs. The audit report, issued on
August 31, 2005, reported an inadequate-in-part opinion and combined
the first two deficiencies, reporting a total of three significant
deficiencies. However, DCAA did not remove the contractor from the
direct-bill program, whereby contractors are authorized to submit
invoices directly to a government paying office without prior review.
The auditor assigned to the original audit was also assigned to the
billing system follow-up audit, but she was subsequently removed from
the follow-up audit because, according to her supervisor, she was
documenting her audit in too much detail. In January 2006, during the
follow-up audit, Army CID concluded its fraud investigation. The
contracting officer's technical representative (COTR) and several
contractor employees were convicted of fraudulently billing the
government using the billing system that DCAA later deemed adequate.
The investigation found that the COTR and the contractor employees were
charging the government for travel to contract-related conferences and
arranging the trips so they could attend a NASCAR race at government
expense. They took government cars on the trips and various contractor
employees each charged the government for use of their personal cars,
with the COTR approving the travel vouchers. In addition, the COTR had
contractor employees cut scrap lumber on government land and stack it
at his home for use as firewood. The government was billed for the
contractor employees' time on behalf of the COTR. In the January 2006
settlement, which totaled over $2.8 million, the COTR and contractor
employees paid fines and restitution, and the COTR also served jail
time. The Army CID Special Agent in charge of the fraud investigation
told us that he had tried on numerous occasions to get the DCAA FAO
manager to stop issuing incurred cost audit reports with "clean"
opinions because the opinions would be contradicted by the findings in
the ongoing fraud investigation. The FAO issued the 2002 incurred cost
audit report on January 5, 2005, stating its opinion that except for
the qualification that the ongoing fraud investigation had developed
information which may impact the costs and transactions in this report,
the claimed direct costs are acceptable and are provisionally approved,
pending final acceptance. DCAA did not include a cautionary note or
similar qualification in the billing system audit report. In September
2006, DCAA reported an adequate ("clean") opinion in the follow-up
audit report on the contractor's billing system controls without
performing work to confirm that the contractor's billing system
policies and procedures were effectively implemented. Following GAO's
review of these audits, on November 20, 2008, DCAA rescinded both
reports because the audit documentation did not support the reported
opinions and initiated a new audit of the contractor's billing system
controls.
[End of text box]
Insufficient Documentation of Sampling and Testing Methodology:
Testing is a critical auditing procedure that allows auditors to
determine whether controls are operating effectively. Although some
testing can involve statistical samples, such samples are not required
under GAGAS. Instead, GAGAS require that auditors prepare attest
documentation in sufficient detail to enable an experienced auditor,
having no previous connection to the audit, to ascertain from the
attest documentation that the evidence supports the auditors'
significant judgments and conclusions. Under GAGAS, attest
documentation should contain the objectives, scope, and methodology of
the attestation engagement, including any sampling and other selection
criteria used.[Footnote 126] Of the 37 internal control audits we
reviewed, 27 audits did not contain workpaper documentation to
demonstrate that the auditors' nonstatistical samples met these
requirements. for example:
* On one billing system audit, the auditor performed testing on two
vouchers. The auditor did not document how he selected the two
vouchers, and he did not document the population of contractor vouchers
in the workpapers or the basis for his judgment on selecting the two
vouchers for testing. When we asked the auditor why he selected two
most recent vouchers for testing and did not document the voucher
population, the auditor told us it was because "the file size was too
large," and he saves the population files on his desktop computer.
* On a billing system audit of one of the five largest DOD contractors
we asked the auditor why he tested only one voucher to assess the
contractor's controls for subcontractor accounting and billing. The
auditor said this was reasonable because DCAA "had tested so many
vouchers before." Other workpaper documentation noted testing was not
performed on the direct-bill section of the audit program. When we
asked the auditor why these procedures were not performed, the auditor
told us that testing was performed by another FAO when the contractor
implemented a new system 2 months earlier, and he decided not to do
testing again because "the contractor would not appreciate it"--an
indication of an auditor independence problem. Moreover, tests of new
billing systems focus on data processing controls and would not take
the place of tests of invoices for compliance with CAS, FAR, and
contract terms.
Although the CAM includes guidance on sufficient testing,[Footnote 127]
auditors appeared to follow general guidance throughout the manual that
advises auditors to use their judgment "to 'test check' a procedure, to
make verifications 'on a selective basis,' or to review a
'representative number' of transactions or items." Several auditors,
field office managers, and DCAA headquarters officials told us that
they believed "spot checks" were sufficient testing to conclude on
controls overall and they did not believe they were required to
document their sampling plans.
[Text box:
DCAA Relied on Faulty Auditor Judgment to Approve Contractor Controls;
An Eastern Region auditor performed minimal testing in an audit of
controls over indirect and other direct cost for a business segment of
one of the top five DOD contractors that billed the government for
about $1 billion during 2006. The auditor did not use statistical
sampling or test a representative selection of accounts payable
transactions. Instead, without documenting the reasons for his
judgments, the auditor tested 6 of 16,000 accounts payable transactions
($86 of $50 million), 3 of 4,500 travel transactions ($2,700 of $15
million), and 3 of 1,600 interdivisional transactions ($5,000 of $16
million). On September 27, 2006, DCAA reported an adequate opinion on
the contractor's controls over direct and indirect costs. However our
review of the audit workpapers revealed:
* no explanation of why so few transactions were tested;
* no rationale for why transactions selected for testing covered the
months of May through July 2005, when transactions occurred throughout
the year, or;
* how the auditor concluded that the system was adequate based on
testing 12 out of about 22,000 transactions.
When we asked the auditors to explain the basis for their selection of
transactions used for testing, FAO management said the selection was
based on auditor judgment; implying auditors could use their
professional judgment without the need to meet any specific criteria in
doing so. GAGAS section 3.34 (GAO-03-673G) states that auditors should
consider the need to protect the public interest when making
professional judgments. GAGAS section 6.02a requires auditors to
perform sufficient testing to support audit conclusions and opinions on
controls. Determining what is sufficient testing requires auditors to
determine an appropriate sample size considering risks, expectation of
misstatements or deviations, and materiality, and select a
representative sample from the population, meaning that all
transactions have a known chance of being selected. GAGAS section 6.24
a. and c. require auditors to document the sampling plan and auditor
judgments made in sampling and testing. This audit did not meet these
GAGAS requirements.
[End of text box]
Insufficient Evidence to Support Audit Conclusions and Opinions:
We found that audit procedures for most of the 37 internal control
audits we reviewed documented the design of controls but did not test
the implementation of controls. As a result, the audits lacked
sufficient evidence to support audit opinions that covered both the
design and implementation of controls. GAGAS for examination-level
attestation engagements require that sufficient evidence be obtained to
provide a reasonable basis for the conclusion that is expressed in the
report.[Footnote 128] GAGAS state that attest documentation serves to
(1) provide the principal support for the auditor's report, (2) aid
auditors in conducting and supervising the attestation engagement, and
(3) allow for the review of the quality of the attestation engagement.
The preparation of attest documentation should be appropriately
detailed to provide a clear understanding of its purpose and source and
the conclusions the auditors reached, and it should be appropriately
organized to provide a clear link to the findings, conclusions, and
recommendations contained in the auditors' report.[Footnote 129]
Overall, we found that 33 of the 37 internal control audits did not
include sufficient testing of internal controls to support auditor
conclusions and opinions. Our review of audit workpapers often found
that only two, three, or sometimes five transactions were tested to
support audit conclusions, for example:
* On several audits, DCAA concluded that a contractor had adequate
controls for removing system access for terminated or transferred
employees. However, the auditors did not document the employee
population from which individual employees were selected for testing
system access, or the methodology used to select them. On none of these
audits did we see evidence that DCAA auditors checked alphabetical
listings of individuals having system access to lists of current
personnel to confirm that access was removed when employees transferred
or left the company. Without documentation of sampling and testing
methodologies, there is no way to ascertain how the auditors came to
their conclusions that controls were adequate or that sufficient
testing was done to support audit conclusions.
* For many controls, DCAA did not perform any testing at all. For
example, at least 6 of the 9 accounting audits we reviewed did not
include procedures for testing contractor segregation of allowable and
unallowable cost; 20 of 22 billing system audits we reviewed did not
include tests to identify duplicate invoices, and 10 of the 22 billing
system audits of contractors that relied on manual procedures to
prepare invoices from accounting system data queries did not check for
compensating controls. For one audit, DCAA issued an adequate opinion
on the accounting system for a major DOD contractor after performing a
walkthrough of the accounting process and interviewing two employees.
[Text box:
Adequate Opinion on Contractor Billing System Was Based on Spot Checks
of 4 Vouchers Generated on the Same Day; A Mid-Atlantic Region auditor
used interviews with contractor staff and limited testing as evidence
that billing system controls were adequate for a DOD contractor with
about $40 million in annual government sales. Workpapers documenting
audit procedures on key internal controls referred to "discussions with
the contractor" rather than independent auditor verification, including
(1) verification of periodic reviews of contractor policies and
procedures, (2) implementation and effectiveness of policies and
procedures, (3) frequency and sufficiency of the contractor's
management reviews, (4) timely processing of offsets, and (5) exclusion
of non-billable items from government billings. Although the audit was
performed from November 2004 through July 2005, according to the
workpapers, the auditor tested a nonstatistical selection of four
vouchers (invoices) totaling $2.3 million that were all processed on
the same day--February 28, 2005. The workpapers contained no
documentation on the population of invoices or the basis for selecting
four vouchers for testing that were all processed on the same day out
of the 8-month period covered by the audit. GAO also determined that
the auditors performed no testing of the contractor's billing system
information technology (electronic data processing) controls. As a
result, this audit can not be relied on for assurance that the
contractor's billing system and related internal control policies and
procedures were adequate as of June 16, 2005.
[End of text box]
Audit Supervision Problems:
GAGAS require that assistants (audit staff) be properly supervised and
that audit documentation contain evidence of supervisory reviews of the
work performed that supports findings, conclusions, and recommendations
contained in the report before the report on the attestation engagement
is issued.[Footnote 130] Although workpaper documentation for the
majority of the 37 audits of contractor internal control systems we
reviewed evidenced supervisory review, we found:
* A lack of proper documentation of supervisory review in 13 audits.
For example, for an Eastern Region accounting system audit, the
supervisory auditor who signed the audit report did not review key
workpapers related to accounting system transaction processing and
transaction testing and cost allocations until 1 to 2 days after the
audit report was issued. This was similar to a situation we found in
our prior investigation, when supervisors at one DCAA field office
frequently reviewed the workpapers for forward pricing reports after
the reports were issued. The auditors also performed insufficient
testing on this audit.
* Audit steps were deleted from the standard audit program in an
accounting system audit and a billing system audit after the
supervisors approved the audit programs. The supervisors did not ensure
that the deleted steps were addressed or that documentation was added
to the workpapers to explain the reasons why the related audit
procedures were not performed.
* For six other audits, audit documentation shows that the supervisors
and FAO managers extended the audit time frames while contractors took
actions to correct significant deficiencies. The audit reports were
issued 1 to 2 years later with adequate ("clean") opinions on controls.
Although this raises serious auditor independence and reporting issues
because identified deficiencies were not reported, we are highlighting
these cases under our discussion of poor supervision to also
demonstrate the importance of "tone at the top."
[Text box:
DCAA Extended Audit and "Scrubbed" Audit Documentation after Contractor
Objected to Findings; A DCAA Western Region FAO failed to provide
proper supervision of auditors throughout an accounting system audit of
one of DOD's five largest contractors working in Iraq. For contractor
fiscal year ended December 31, 2004, the contractor reported over $900
million in sales of which 98 percent related to government contracts,
including $250 million for work in Iraq. The 2004 audit, which was
initiated in November 2003, was transferred among several auditors and
at least three supervisors before its completion and August 2006
publication. In September 2005, the contractor objected to draft
findings and recommendations that included eight significant
deficiencies in the design and operation of the contractor's accounting
system, including inadequate system access controls, lack of policies
and procedures for segregation of duties, lack of periodic
reconciliations of cost accounts to the general ledger, and
insufficient cost ledger information on total base costs by contract
and cost elements for applying indirect rates. The contractor stated
that the auditors did not fully understand the new policies and
procedures that were just being developed for the fast track effort in
Iraq. Following the contractor's objections, the auditors revised and
deleted some workpapers and created new workpapers. GAO's review of the
audit documentation identified several workpapers that were indexed to
supporting documentation that no longer existed. Further, the auditors
told GAO that because they had difficulty finding support for Iraq
vouchers, they relied on voucher reviews performed under other DCAA
audits. GAO also found evidence in the audit documentation that the
final supervisor instructed the final lead auditor to insert the
signature of a prior supervisor on an electronic workpaper after it had
been revised, thereby making it appear that the prior supervisor had
approved the workpaper revisions. On August 31, 2006, after "scrubbing"
the audit documentation at the supervisor's request, dropping five
significant deficiencies and downgrading three significant deficiencies
to suggestions for improvement, DCAA reported an adequate ("clean")
opinion on the contractor's accounting system. Waiting to review audits
with significant deficiencies until the end of the job after the work
has been completed, raises questions about proper and timely
supervision. The audit supervisor, who authorized the electronic
recording of the prior supervisor's name on the audit documentation and
supervised the issuance of the audit report, was subsequently promoted
to be the Western Region Quality Assurance Manager, where he went on to
act as a quality control check over thousands of audits--including
several of the audits investigated in GAO's prior work. Following GAO's
review, DCAA rescinded the audit report on December 2, 2008.
[End of text box]
Reporting Problems:
Audit reports are DCAA's principal work product. According to GAGAS,
audit reports should, among other criteria, (1) identify the subject
matter being reported, the criteria used to evaluate the subject
matter, the conclusion or opinion, and state that the opinion was as of
a certain date; (2) include a statement of the nature and scope of the
work performed and state that the audit was performed in accordance
with GAGAS; (3) disclose any reservations about the engagement,
including any scope limitations; (4) state the intended use of the
report, if limited; and (5) state the time frame[Footnote 131] covered
by the audit. Our review of audit documentation and DCAA final audit
reports determined that none of the 37 DCAA reports on contractor
systems internal controls met these reporting standards, for example:
* The reports did not cite the specific criteria used in individual
audits. Criteria represent the laws, regulations, contracts, grant
agreements, standards, measures, expected performance, defined business
practices, and benchmarks against which performance is compared and
evaluated. Criteria identify the required or desired state or
expectation with respect to the program or operation and provide a
context for evaluating evidence and understanding the findings.
[Footnote 132] Instead, the DCAA reports uniformly used boilerplate
language to state that DCAA audited for compliance with the "FAR, CAS,
DFARS, and contract terms." As a result the user of the report does not
know the specific Federal Acquisition Regulation (FAR), Cost Accounting
Standards (CAS), or contract terms used as criteria to test contractor
controls. This makes it very difficult for users of the reports to
determine whether the report provides the level of assurance needed to
make contract management decisions. In addition, audit documentation
for many of the audits we reviewed did not identify the audit work
performed to provide assurance that contractors complied with specific
requirements in CAS, FAR, DFARS, or contract terms.
* Six of the 37 audit reports were not issued at the time[Footnote 133]
the work was completed. These reports were issued from 8 months to over
2 years after the audits were completed. Frequently, we found that the
delays were the result of serious findings, which led DCAA to withhold
issuance of the report while the contractor addressed the problems.
Because testing was not updated or was not sufficiently updated, the
reported audit opinions, which related to controls at the time the
reports were issued, were not adequately supported and may have been
inaccurate.
* The audit reports stated the period during which the audit was
performed but did not disclose the scope and timing for tests of
vouchers, transactions, or control attributes. Some tests covered a few
days in only one month or a 3-month period and did not test controls
across the year audited. As a result, testing did not support the
reported audit opinions as of the report dates.
* Contractors imposed restrictions on the scope of four audits by
denying DCAA access to certain records. The access-to-records issues
were not fully resolved or disclosed by the auditors.
* The scope of 33 audits was limited by DCAA imposed, or implied,
restrictions, including inadequate audit resources, unclear audit
guidance on nature and extent of testing, and time constraints that
prevented auditors from performing sufficient work to support reported
opinions on contractor internal controls. DCAA officials told us that
DCAA does not have sufficient resources to perform full-scope audits of
contractor internal controls.
Failure to issue reports when sufficient evidence has been obtained to
support an auditor's conclusion puts decision makers at risk of relying
on out-dated or inaccurate information. Also, when DCAA auditors do not
perform the scope of work necessary to support the reported audit
opinions, the audit reports provide a false level of assurance.
Following our discussion of these audits with DCAA headquarters
officials, DCAA rescinded 4 of the 6 audit reports that did not
accurately relate the period of testing to the audit opinion, and it
rescinded 18 audit reports where the scope of work did not support the
audit opinions. The discussion below describes a particularly egregious
example of this problem.
[Text box:
Two Years after Testing Controls, DCAA Reported the Results of an Audit
of a Multibillion Dollar Contractor's Billing System; In July 2003,
DCAA initiated a billing system audit of a contractor doing business in
Iraq with sales of $6.3 billion at the two divisions under audit. More
than 2 years after performing test procedures and after spending 1,025
hours on the audit, the FAO issued an opinion that the contractor's
billing system controls were adequate as of August 31, 2005, without
updating the testing. In 2003, DCAA auditors tested 38 vouchers
submitted for payment within a 12-day period. DCAA auditors identified
numerous billing errors, including two instances where billings did not
comply with the Federal Acquisition Regulation (FAR). On August 12,
2004, DCAA auditors prepared a draft report with an adequate opinion
and three suggestions for improvement. DCAA auditors did not perform
testing in 2004 or in 2005 despite the number of errors found as a
result of limited test procedures performed in 2003. As a result, the
evidence does not support the opinion that the contractor's billing
system controls are adequate as of August 31, 2005. Additionally, there
is no evidence in the workpapers that the contractor resolved the
errors DCAA identified and the underlying system deficiencies that
caused those errors. This is of special concern because billing errors
and system deficiencies at this contractor put multiple agencies at
risk. For example, this contractor does work not only for DOD but also
for the Departments of Agriculture, Commerce, Interior, and NASA, and
several other agencies. The lead auditor told us that this audit was
delayed because numerous auditors were assigned over the course of this
audit, and the contractor's work in Iraq took precedence over this
audit. However, we found no evidence supporting a decision not to issue
this report when the testing was completed in 2003. Following GAO's
review, DCAA rescinded the audit report on April 7, 2009.
[End of text box]
[End of section]
Appendix II: DCAA Does Not Perform Sufficient Work to Identify and
Collect Contractor Overpayments:
DCAA performs assignments that are designed to test various contractor
costs as allowable, reasonable under the related contracts, the Federal
Acquisition Regulation (FAR), and Cost Accounting Standards (CAS).
Although DCAA uses the term "audit" generically, some of these
assignments are audits and other assignments relate to financial and
advisory services. We reviewed 32 cost-related assignments[Footnote
134] performed by seven geographically disperse field audit offices
(FAO) across the five DCAA regions (the same offices as in appendix I)
to assess whether (1) the tests of contractor costs, billings, and
payments were effective in identifying overpayments, billing errors,
and unallowable cost[Footnote 135] and (2) DCAA identified and reported
unallowable and unsupported costs, overpayments, and billing errors so
that the government was in a position to collect or recover improper
costs and billings through refunds, contract adjustments, or offsets.
The 32 DCAA cost-related assignments we reviewed included 16 paid
voucher reviews, 10 overpayment assignments, 4 incurred cost audits,
and 2 request for equitable adjustment (REA) audits.[Footnote 136]
Although DCAA performs incurred cost and REA audits as engagements in
accordance with generally accepted auditing standards (GAGAS), DCAA
does not consider paid voucher reviews or overpayment audits to be
GAGAS assignments. DCAA performed the paid voucher reviews to assess
the accuracy of contractor billings to support decisions to approve
contractors for participation in the direct-bill program,[Footnote 137]
whereby the contractor submits invoices directly to a federal agency
paying office without government review of the invoices prior to
payment. Overpayment assignments review contractor controls for
identifying and refunding, offsetting, or adjusting contract
overpayments and billing errors.
Similarly, DCAA performs overpayment assignments at the request of
contracting officers to determine (1) whether contractor controls are
effective in identifying overpayments made by disbursing officers or
over billings and billing errors made by contractors and (2) if
contractors are making timely refunds, offsets, or adjustments.
At the time the 32 cost-related assignments were performed, FAR §
52.232-25(d) imposed a requirement on contractors to immediately notify
the contracting officer and request instructions for disposition of any
overpayment when the contractor becomes aware of a duplicate or
overpaid contract financing or invoice payment.[Footnote 138] Also, FAR
32.604(b)(4) provides that contractors shall repay debts under a demand
letter within 30 days, except for certain debts covered by specific
terms of the contract.[Footnote 139] This time period is incorporated
into most contracts under FAR Clause 52.232-17(a). We found that DCAA
auditors are not consistent when assessing the timeliness of refunds
and offsets. Specifically, although DCAA's overpayment work program
cites 30 to 60 days after the overpayment occurred as timely,[Footnote
140] some DCAA auditors considered 90 days as timely which effectively
minimized the impact on the contractors' cash flow.
We also found limited testing in the four incurred cost audits we
reviewed. DCAA considers incurred cost audits to be GAGAS attestation
engagements. Incurred cost audits examine contractors' annual claims
for payment of cost incurred. DOD contracting officers rely on DCAA
incurred cost audits to approve contractor claims for payment.[Footnote
141] DCAA incurred cost audits and proposal audits are the source of
most DCAA questioned costs and dollar recoveries. Dollar recoveries are
based on contracting officer agreement with DCAA questioned costs.
[Footnote 142] DOD contracting officers are responsible for enforcing
DCAA recommendations to disallow questioned cost. Figure 3 provides a
comparison of costs questioned by DCAA auditors and questioned costs
sustained (recovered) by DOD contracting officers.
Figure 3: DCAA Questioned Costs and Amounts Sustained by Contracting
Officers:
[Refer to PDF for image: multiple line graph]
Fiscal year: 2000;
Questioned costs: $5.0 billion;
Questioned costs sustained: $3.4 billion.
Fiscal year: 2001;
Questioned costs: $6.8 billion;
Questioned costs sustained: $4.6 billion.
Fiscal year: 2002;
Questioned costs: $4.0 billion;
Questioned costs sustained: $3.0 billion.
Fiscal year: 2003;
Questioned costs: $4.2 billion;
Questioned costs sustained: $2.8 billion.
Fiscal year: 2004;
Questioned costs: $4.7 billion;
Questioned costs sustained: $3.5 billion.
Fiscal year: 2005;
Questioned costs: $5.5 billion;
Questioned costs sustained: $3.2 billion.
Fiscal year: 2006;
Questioned costs: $5.3 billion;
Questioned costs sustained: $3.4 billion.
Fiscal year: 2007;
Questioned costs: $4.9 billion;
Questioned costs sustained: $3.1 billion.
Fiscal year: 2008;
Questioned costs: $6.7 billion;
Questioned costs sustained: $4.2 billion.
Source: GAO analysis of DCAA data.
[End of figure]
For one of the four incurred cost audits we reviewed, DCAA rescinded
the related accounting system audit report in response to concerns we
identified with that report. For a second incurred cost audit we
reviewed, DCAA rescinded the related billing system report. Risk
assessments for determining the nature, extent, and timing of testing
for incurred cost audits are based in part on the results of accounting
and billing system audits. Therefore, a rescission of an accounting or
billing system audit would call into question the risk assessment
performed for the related incurred cost audits.
The case study examples in table 6 illustrate significant problems we
identified with the DCAA cost-related assignments we reviewed. As
previously discussed, the level of testing in these assignments was not
sufficient to identify all potential contractor billing errors and
overpayments.
Table 6: Case Studies of Problem DCAA Cost-Related Assignments:
Region: Central;
Type of assignment: Paid voucher review (2006); Non-GAGAS;
Details of review:
* For this review of paid contractor invoices, the auditor relied on
the results of DCAA's 2005 billing system audit and did not test any
invoices. The workpapers stated that the auditor also relied on the
results of the 2005 paid voucher assignment. However, that assignment
did not test any 2006 invoices;
* Further, as a result of GAO's work, DCAA had rescinded the 2005
billing system audit report on February 10, 2009;
* As a result, there is no audit support for DCAA's approval for this
contractor to directly bill the government.
Region: Central;
Type of assignment: Paid voucher; review (2005); Non-GAGAS;
Details of review:
* In planning this work, the auditor improperly assessed risk as low
and deleted several steps from the standard "audit" program;
* The auditor did not identify the population of vouchers (invoices)
and selected two invoices for testing, but only tested one of them;
* The auditor tested one invoice to see if the payment received by the
contractor matched the amount billed;
* On January 23, 2006, DCAA issued a Memorandum for the Record, stating
"reliance can be placed on the contractor's procedures for preparation
of interim vouchers. Accordingly, the contractor has met the criteria
for continued participation in the direct billing program."
Region: Western;
Type of assignment: Paid voucher; review (2005); Non-GAGAS;
Details of review:
* Without documenting the population of vouchers or the total dollars
billed during the contractor's fiscal year, the auditor tested 8 of 734
vouchers issued from April 16, 2004, through March 25, 2005;
* The supervisor incorrectly directed the auditor to test a final
voucher. Paid voucher assignments focus on interim vouchers as a basis
for making direct-bill decisions. Final vouchers are submitted to close
out a contract;
* The auditor did not identify any errors in the vouchers tested;
* On September 30, 2005, the auditor prepared a Memorandum for the
Record, stating that "continued reliance can be placed on the
contractor's procedures for preparation of interim vouchers.
Accordingly, the contractor has met the criteria for continued
participation in the direct billing program."
Region: Eastern;
Type of assignment: Paid voucher review (2004); Non-GAGAS;
Details of review:
* Although the contractor generated $1.1 billion in annual billings to
the government, the auditor assessed risk as low for this assignment.
Without documenting the basis for the risk assessment, the auditor
judgmentally selected 3 vouchers totaling $88,000 for testing out of a
total of 222 vouchers submitted to the government for payment from
March 2003 through February 2004;
* The auditor tested the first voucher selected and performed limited
testing on the remaining 2 vouchers;
* The workpapers do not include any evidence to show that the auditor
performed most of the audit steps required in the standard audit
program;
* Despite limited testing, on March 31, 2004, DCAA prepared a
memorandum for the record, stating "continued reliance can be placed on
the contractor's procedures for the preparation of interim vouchers"
and "the contractor has met the criteria for continued participation in
the direct billing program."
Source: GAO analysis of DCAA audit documentation.
[End of table]
[End of section]
Appendix III: Objectives, Scope, and Methodology:
Pursuant to a request from the Chairman and Ranking Member of the
Senate Committee on Homeland Security and Governmental Affairs, we
conducted an agencywide performance audit to assess the effectiveness
of Defense Contract Audit Agency (DCAA) audits for helping to assure
that prices paid by the government for needed goods and services are
fair and reasonable and that contractors are charging the government in
accordance with applicable laws, regulations, cost accounting
standards, and contract terms. The overall objectives of our work were
to (1) conduct a broad assessment of DCAA's management environment and
quality assurance structure, (2) evaluate DCAA corrective actions in
response to our prior investigation[Footnote 143] and DOD Comptroller/
CFO "tiger team" and Defense Business Board (DBB) studies, and (3)
identify potential legislation and other actions that could improve
DCAA's effectiveness and independence.
To address our first objective, we evaluated DCAA's contract audit
guidance and policies and its quality assurance program and assessed
the quality of a nationwide selection of DCAA audits. We evaluated the
results of internal DCAA audit quality assurance reviews on audits
issued from fiscal year 2003 through 2008. We also reviewed a total of
69 DCAA audits and cost-related assignments.[Footnote 144] In reviewing
DCAA audits, we used generally accepted government auditing standards
as our criteria.[Footnote 145] The 69 DCAA audits and cost-related
assignments we reviewed included 37 audits of contractor internal
controls and 32 cost-related audits and assignments. We did not assess
a statistical sample of DCAA audits. Rather, we focused on DCAA offices
that reported predominately adequate, or "clean," opinions on audits of
contractor internal controls over cost accounting, billing, and cost
estimating systems issued in fiscal years 2005 and 2006.[Footnote 146]
We selected DCAA offices that reported predominately adequate ("clean")
opinions on contractor systems and related internal controls because
contracting officers rely on these opinions for three or more years to
make decisions on pricing and contract awards, and payment. For
example, audits of estimating system controls support negotiation of
fair and reasonable prices.[Footnote 147] Also, the Federal Acquisition
Regulation (FAR) requires contractors to have an adequate accounting
system prior to award of a cost-reimbursable or other flexibly-priced
contract.[Footnote 148] Billing system internal control audit results
support decisions to authorize contractors to submit invoices directly
to DOD and other federal agency disbursing offices for payment without
government review.[Footnote 149] In addition, DCAA uses the results of
internal control audits to assess risk and plan the nature, extent, and
timing of tests for other contractor audits. When a contractor has
received an adequate opinion on its systems and related controls, DCAA
would assess the risk for subsequent internal control and cost-related
audits as low and would perform less testing on these audits.
Using this approach, we identified seven geographically disperse DCAA
field offices within the 5 DCAA regions and targeted 39 audits of
contractor cost accounting, billing, and estimating system controls
issued during fiscal years 2004 through 2006 for review.[Footnote 150]
These were the most recent completed fiscal years at the time we
initiated our audit. Two of the 39 internal control audits we
identified were performed as assist audits to a billing system audit
and we considered them as part of the billing system audit we reviewed.
Therefore, we reviewed a total of 37 audits of contractor internal
controls for compliance with GAGAS and DCAA policy. We also considered
whether DCAA adequately applied internal control standards in its
audits that are applicable to the private sector.[Footnote 151] We did
not review classified audits performed by DCAA's field detachment
office. Although our selection of the seven offices and 37 internal
control audits was not statistical, it represented about 9 percent of
the total 76 DCAA offices that issued audit reports on contractor
internal controls and nearly 18 percent of the 40 offices that issued 8
or more reports on contractor internal controls during fiscal year
2006. Of the 37 internal control audits we reviewed, 32 reports were
issued with adequate opinions and 5 reports were issued with inadequate-
in-part opinions. Table 7 summarizes the number and types of contractor
internal control audits we reviewed for seven FAOs across the 5 DCAA
regions.
Table 7: Summary of DCAA Audits Reviewed for GAGAS Compliance:
Region/FAO: Northeast: FAO #1;
Type of internal control audit:
Accounting system: [Empty];
Indirect & other direct cost: [Empty];
Billing system: 3;
Estimating system: 1;
Total internal control audits: 4.
Region/FAO: Mid-Atlantic: FAO #2;
Type of internal control audit:
Accounting system: 2;
Indirect & other direct cost: [Empty];
Billing system: 3;
Estimating system: [Empty];
Total internal control audits: 5.
Region/FAO: Eastern: FAO #3;
Type of internal control audit:
Accounting system: 1;
Indirect & other direct cost: 1;
Billing system: 3;
Estimating system: 1;
Total internal control audits: 6.
Region/FAO: Central: FAO #4;
Type of internal control audit:
Accounting system: 2;
Indirect & other direct cost: [Empty];
Billing system: 2;
Estimating system: 1;
Total internal control audits: 5.
Region/FAO: Central: FAO #5;
Type of internal control audit:
Accounting system: 2;
Indirect & other direct cost: [Empty];
Billing system: 5;
Estimating system: [Empty];
Total internal control audits: 7.
Region/FAO: Western: FAO #6;
Type of internal control audit:
Accounting system: [Empty];
Indirect & other direct cost: 1;
Billing system: 3;
Estimating system: 1;
Total internal control audits: 5.
Region/FAO: Western: FAO #7;
Type of internal control audit:
Accounting system: 2;
Indirect & other direct cost: [Empty];
Billing system: 1;
Estimating system: 2;
Total internal control audits: 5.
Total:
Type of internal control audit:
Accounting system: 9;
Indirect & other direct cost: 2;
Billing system: 20;
Estimating system: 6;
Total internal control audits: 37.
Source: GAO analysis of DCAA management information system data.
[End of table]
At the same seven DCAA field offices, we selected 34 cost-related
assignments performed during the same period as the internal control
audits we reviewed and analyzed supporting documentation to determine
whether the assignments included sufficient testing to assess whether
(1) the tests of contractor costs, billings, payments were effective in
identifying overpayments, billing errors, and unallowable cost[Footnote
152] and (2) DCAA reported overpayments, billing errors, and
unallowable and unsupported costs, so that the government was in a
position to recover improper payments through refunds, contract
adjustments, or offsets and avoid payment of unsupported and
unallowable costs. Upon reviewing documentation for the 34 cost-related
audits, we determined that one of these assignments covered the risk
assessment portion of an incurred cost audit and was not a complete
audit. Documentation for a second assignment to test for overpayments
was terminated and the audit procedures were rolled into a billing
system audit. Consequently, as shown in table 8, we reviewed a total of
32 cost-related DCAA assignments. These assignments included paid
voucher reviews and overpayment control assignments and audits of
requests for equitable adjustment (REA)[Footnote 153] and contractor
incurred cost claims.
Table 8: Summary of DCAA Cost-Related Assignments Reviewed:
Region/FAO: Northeast: FAO #1;
Type of Assignment:
Paid Voucher review: [Empty];
Over payment assignment: 1;
REA audit: 2;
Incurred Cost audit: 2;
Total assignments: 5.
Region/FAO: Mid-Atlantic: FAO #2;
Type of Assignment:
Paid Voucher review: 4;
Over payment assignment: 1;
REA audit: [Empty];
Incurred Cost audit: 1;
Total assignments: 6.
Region/FAO: Eastern: FAO #3;
Type of Assignment:
Paid Voucher review: 3;
Over payment assignment: 3;
REA audit: [Empty];
Incurred Cost audit: [Empty];
Total assignments: 6.
Region/FAO: Central: FAO #4;
Type of Assignment:
Paid Voucher review: 1;
Over payment assignment: 1;
REA audit: [Empty];
Incurred Cost audit: [Empty];
Total assignments: 2.
Region/FAO: Central: FAO #5;
Type of Assignment:
Paid Voucher review: 5;
Over payment assignment: 2;
REA audit: [Empty];
Incurred Cost audit: [Empty];
Total assignments: 7.
Region/FAO: Western: FAO #6;
Type of Assignment:
Paid Voucher review: 3;
Over payment assignment: 1;
REA audit: [Empty];
Incurred Cost audit: [Empty];
Total assignments: 4.
Region/FAO: Western: FAO #7;
Type of Assignment:
Paid Voucher review: [Empty];
Over payment assignment: 1;
REA audit: [Empty];
Incurred Cost audit: 1;
Total assignments: 2.
Total:
Type of Assignment:
Paid Voucher review: 16;
Over payment assignment: 10;
REA audit: 2;
Incurred Cost audit: 4;
Total assignments: 32.
Source: GAO analysis of DCAA management information system data.
[End of table]
The details of our assessments of DCAA audits of contractor internal
control systems and cost-related audits and assignments are included in
appendixes I and II, respectively. Examples of our findings are
included in the body of this report to help illustrate the effect of
our findings related to DCAA's management environment.
To assess DCAA's management environment and quality control system, we
reviewed DCAA's mission statement, strategic plan, performance metrics,
quality assurance program, audit planning and policy guidance, and
human capital management. We evaluated the results of internal DCAA
audit quality assurance reviews on audits issued from fiscal year 2004
through 2008. We used requirements in the Government Performance and
Results Act,[Footnote 154] GAGAS,[Footnote 155] and GAO's Standards for
Internal Control in the Federal Government[Footnote 156] as our
criteria.
We analyzed the findings, conclusions, and recommendations in the DOD
Inspector General's (IG) 2007 report on its oversight review of DCAA,
[Footnote 157] which serves the purpose of a peer review. We did not
review DOD IG documentation for the oversight review. In assessing the
DOD IG peer review conclusions and opinion, we considered the
inconsistencies between the findings and recommendations in the IG
report. In addition, we considered the results of our analysis of DCAA
audits in our prior investigation; our review of the 69 DCAA audits and
related assignments covered in this report; the results of DCAA's
internal quality assurance reviews; and DCAA's actions to rescind 80
audit reports.
To achieve our second objective, we reviewed the status of several key
actions that DCAA initiated as a result of our earlier investigation,
including efforts to:
* revise DCAA's mission statement and strategic plan to focus on
protecting the public interest;
* change performance metrics to focus on audit quality instead of
performing large quantities audits;
* end DCAA involvement with integrated product teams, which we
identified as an impairment to DCAA's independence;
* improve audit quality by revising audit policy guidance and
realigning DCAA's audit quality assurance structure; and:
* update training courses to reflect changes in DCAA's mission,
metrics, and audit policy.
Although the October 2008 Defense Business Board report recommended
that the Secretary of Defense revise DCAA's mission statement to focus
on protecting the public interest, at the time we completed our work in
July 2009, DCAA's mission statement had not yet been revised. To assess
changes in performance metrics, we analyzed DCAA's new metrics and
determined whether changes made in September 2008 were effective in
shifting DCAA focus from report production to performing quality audits
and if the new metrics had been integrated into DCAA's performance
plans, auditor expectations, and performance appraisal standards. In
addition, we made selected calls to one or more auditors in 15 selected
DCAA offices that were separate from the offices we visited to review
audit documentation and interviewed auditors about their experience
with changes in DCAA policies and performance metrics. We also
considered 34 additional hotline allegations we received from auditors
across the 5 DCAA regions after our investigative report was issued. We
used GAGAS criteria[Footnote 158] to assess the effectiveness of DCAA
policy changes and DCAA's centralization of the audit quality function
aimed at improving auditor independence and audit quality. We used
GAO's Internal Control Standards as our criteria for assessing DCAA's
management environment, culture, need for a risk-based audit approach,
and human capital practices.
To achieve our third objective to identify potential legislative and
other actions to improve DCAA's effectiveness, we considered DCAA's
current role and responsibilities; the framework of statutory authority
for auditor independence in the Inspector General Act of 1978, as
amended;[Footnote 159] best practices of leading organizations that
have made cultural and organizational transformations; our past work on
DCAA organizational alternatives;[Footnote 160] GAGAS criteria for
auditor integrity, objectivity, and independence; and GAO's Standards
for Internal Control[Footnote 161] on managerial leadership and
oversight. We identified potential short-term and longer term
legislative actions and organizational changes that could enhance
DCAA's effectiveness and independence.
Throughout our audit we met with the DCAA Director and DCAA
headquarters policy, quality assurance, and operations officials and
DCAA Region and FAO managers, supervisors, and auditors. We also met
with DOD Office of Inspector General (OIG) auditors responsible for
DCAA audit oversight and DOD IG hotline office staff. We assessed the
reliability DCAA data used in our work by reviewing DCAA procedures for
assuring the reliability of reported performance data, discussing the
compilation and use of these data with DCAA operations personnel, and
performing analytical procedures to determine the reliability of
specific data used in our analysis. For example, we determined that
DCAA assignments initiated in one year and completed in the second year
were double counted. We eliminated duplicate records from data used for
our analysis. We also met with the former DOD Comptroller/CFO to
discuss plans for the Office of Comptroller/CFO and Defense Business
Board reviews, and we continued to meet with and obtain information
from the new DOD Comptroller/CFO and his staff. We also met with the
Comptroller's new DCAA Oversight Committee, which includes the Auditors
General of the Army, the Navy, and the Air Force; the DOD Director of
Defense Procurement and Acquisition Policy; and the DOD Deputy General
Counsel for Acquisition.
We conducted this performance audit from August 2006 through December
2007, at which time we suspended this work to complete our
investigation of hotline complaints regarding audits performed at three
DCAA field offices. We resumed our work on this audit in October 2008
and performed additional work through July 2009 to evaluate DCAA's
quality assurance program during fiscal years 2007 and 2008, assess
DCAA corrective actions, and consider organizational placement options.
We conducted our audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable
basis for findings and conclusions based on our audit objectives. We
performed our investigative procedures in accordance with quality
standards set forth by the Council of the Inspectors General on
Integrity and Efficiency (formerly the President's Council on Integrity
and Efficiency).
[End of section]
Appendix IV: Comments from the Department of Defense:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
Under Secretary Of Defense:
Comptroller:
1100 Defense Pentagon:
Washington, Dc 20301-1100:
September 4, 2009:
Mr. Gregory Kutz:
Managing Director, Forensic Audits and Special Investigations:
Government Accountability Office (GAO):
441 G. St., NW:
Washington, DC 20548:
Dear Mr. Kutz:
This is the Department of Defense (DoD) response to the GAO draft
report GAO09-468, "DCAA Audits: Widespread Problems with Audit Quality
Require Significant Reform," dated July 31, 2009 (GAO code 195099). We
thank you for the opportunity to respond to the GAO draft report and
recommendations. Those recommendations directed to the DoD Inspector
General will be provided directly by that office under separate cover.
The Department concurs with all but one of the GAO recommendations
(Enclosure 1). We disagree with some of GAO comments for Congressional
consideration (Enclosure 2). Enclosure 3 contains a listing of
corrective actions DCAA has implemented since 2008. As part of our
review of the GAO draft report, we noted several areas where we believe
further clarification and explanation are needed so the circumstances
can be completely understood. The clarifying comments are provided in
Enclosure 4. Comments from the Director, Defense Procurement and
Acquisition Policy are provided as Enclosure 5.
The Department and the Defense Contract Audit Agency (DCAA) are
committed to taking the necessary corrective actions to address the GAO
findings. This office will continue to monitor DCAA to ensure timely
completion of critical actions to address the GAO's recommendations. To
assist with this monitoring, in March 2009, I established a DCAA
Oversight Committee to provide my office advice and recommendations
related to the oversight of DCAA. This committee includes Auditors
General of the Army, the Navy, and the Air Force; the Director of
Defense Procurement and Acquisition Policy; and the DoD Deputy General
Counsel for Acquisition and Technology. The committee will assess
DCAA's activities, its corrective actions taken to this and other
oversight reports, and identify any gaps. I have also assigned a member
of my senior staff to assist in the oversight efforts.
We acknowledge that the draft GAO report raises serious issues that we
need to continue to address. We will continue to improve audit quality,
especially for internal control audits. We will reassess the number of
audits that DCAA performs and ensure that adequate staffing is
available to conduct those audits in accordance with generally accepted
government auditing standards (GAGAS). We will ensure that DCAA has
adequate independence. We will also ensure that an appeals mechanism is
created to provide a process for resolving disputes between DCAA and
the contracting organizations.
While we acknowledge that continued work on these serious issues is
required, we disagree with the suggestion in the GAO report that we
have not yet begun to address the weaknesses. The GAO report states
that "DoD and DCAA have not yet addressed the fundamental weaknesses in
DCAA's mission, strategic plan, metrics, audit approach, and human
capital practices that have had a detrimental effect on audit quality."
We believe that we have begun to address these issues. The audit
assignments covered by this review were completed 3-5 years ago,
several years before DCAA implemented a series of corrective actions
beginning in late 2008. Although a significant number of short-term
actions have been completed, DCAA has many long-term actions still in-
process. It may take several years to experience the full effect on the
execution of the DCAA audits. Enclosure 3 contains the list of
corrective actions DCAA has implemented in late 2008 and to-date in
2009.
While we acknowledge GAO's findings are serious, DCAA has and continues
to play a vital role in support of the contracting process in ensuring
that DoD pays a fair and reasonable price in accordance with applicable
regulations in protecting the taxpayers' dollars. In FY 2008 alone,
DCAA audits recommended reductions in proposed or billed costs of $17.9
billion (referred to as questioned costs) and $7.2 billion in estimated
costs where the contractor did not provide sufficient information to
explain the basis of the estimated amounts (referred to as unsupported
costs). Additionally, the current Director of Defense Procurement and
Acquisition Policy, a key DCAA stakeholder, has stated that he finds
DCAA's work critical to the acquisition process (Enclosure 5).
DCAA's important work was showcased in three hearings of the Commission
on Wartime Contracting in 2009. One hearing focused on contractor
business systems, a type of audit that is the subject of the GAO
report. Through June 2009, DCAA has cited deficiencies in contractor
systems in over half of the 200 audits performed on the contractors
performing effort in-theater. The Commission remarked that hundreds of
millions of dollars have been recovered as a result of DCAA's audits
and that DCAA's efforts were extraordinary considering the performance
of audits in a war zone. Several of the Commissioners remarked during a
recent hearing that DCAA was the finest audit organization they had
worked with and the most forthright and responsive of all the
organizations that have interacted with the Commission to date.
Several of the key actions DCAA has taken to address DCAA's management
environment involved the use of external organizations to guide DCAA
through its "cultural transformation." For example, DCAA has engaged
the Naval Post Graduate School's Center for Defense Management Reform
to assist with the development and execution of various long-term
organizational improvement projects. These projects address the
following questions:
1. How can DCAA put people first to guide its decisions, actions and
values? For example, how can DCAA place an increased emphasis on "soft
skills" such as building morale and developing employees (in terms of a
broad understanding as well as technical proficiency)?
2. How can DCAA develop leaders to serve the employees and the
organization?
3. How can DCAA structure the organization to facilitate compliance
with GAGAS, maximize audit results/return on investment (ROI), and
better align Agency workload/resources?
4. How can DCAA identify and resolve differing stakeholder expectations
with contracting officers, contractors, the public (Congress), and
external review organizations?
DCAA has also engaged the Army Force Management Support Agency (AFMSA)
to assess DCAA's risk-based audit requirements planning process for FY
2010. AFMSA will also assist in translating the requirements planning
into staffing needs.
One of the major findings reported by the GAO is the lack of sufficient
transaction testing to support the conclusions when giving an opinion
on contractor internal control systems. We concur that many of the
assignment working papers did not reflect the level of testing required
by the GAO to opine on the system of internal controls. DCAA has
rescinded audit reports and initiated full scope internal control
audits at these locations. In light of the GAO's findings, DCAA will be
assessing the need to opine on contractor internal controls or whether
an opinion on the sufficiency of the contractors' business systems for
Government contracting purposes is appropriate. We suggest that the GAO
and the DoD Inspector General (IG) work closely with DCAA in its
assessment and redesign of testing procedures for opining on contractor
business systems.
It is worth noting that the additional transaction testing will require
an increase in audit staff at DCAA. Some of the increase is already
underway through the use of the Defense Acquisition Workforce
Development Fund. Using this fund, DCAA has increased staffing by 300
in FY 2009 and plans to increase by an additional 200 each in FYs 2010
and 2011, with a total increase of 700 by the end of FY 2011. However,
this may not be enough to accomplish the audits required by regulation
in light of the additional testing stipulated by the GAO. We will
continue to monitor the staffing situation at DCAA. But to accomplish
the significant increase in testing during internal control audits,
DCAA will be required to defer lower risk assignments to FYs 2010 and
2011, which could have a negative impact on the timely closing of
contracts prior to the cancellation of funds. The overall issue of risk
assessment, as outlined in the GAO draft report, is one of the main
discussion topics I have assigned to the DCAA Oversight Committee.
The Department concurs with the GAO that the root causes for many of
the GAGAS noncompliances related to the prior DCAA performance
measures. As the GAO acknowledges, in September 2008, DCAA took
aggressive action by revising the performance measures to promote
quality audits. During FY 2009, DCAA has continually assessed the
performance measures by conducting focus groups in several regions
(including the DCAA Western Region). In general, the focus groups
confirmed that there was much less emphasis on performance measures
than in the past.
The GAO draft report states that DCAA has taken some actions to improve
its quality assurance program; however, it stated that staffing
difficulties and other issues have left the outcome of this important
initiative uncertain. We disagree. DCAA has been proactive in standing
up its new Integrity and Quality Assurance Directorate - essentially a
new quality assurance organization that reports directly to the
Director/Deputy Director. DCAA has revised its quality assurance
program for reporting GAGAS noncompliances and requires audit offices
to provide corrective action plans that address all GAGAS
noncompliances reported. The Headquarters Quality Assurance
organization will follow-up on each systemic noncompliance to ensure
the field audit offices have corrected their processes. In July 2009,
DCAA was authorized a Senior Executive Service position to lead the
Quality Assurance Directorate. We believe the extensive overhaul of the
quality assurance function accomplished in FY 2009 will mitigate the
prior shortcomings in audit quality cited by the GAO.
In January 2009, the DCAA Director established a Senior Advisory
Council for Improvement which is led by the Director and comprised of
Headquarters senior executives. The Council's primary purpose is to
establish and monitor the actions in response to the report issued in
January 2009 by the Independent Review Panel to the Defense Business
Board and findings from the GAO and DoD IG reviews. The establishment
of this council exemplifies the Director's efforts in ensuring key
Agencywide actions are managed at the Headquarters level versus the
regional level. We believe the establishment of this DCAA Headquarters
council, in addition to re-aligning the Quality Assurance Program to
report directly to the Director/Deputy Director, results in significant
progress toward addressing the GAO's concerns with DCAA's
"decentralized structure that has fostered a culture of DCAA region
autonomy."
The GAO draft report states that the supervisors responsible for
deficient audits identified in GAO's prior investigation were promoted
even though the GAO investigation disclosed significant GAGAS
noncompliances with the audits they supervised. The GAO states that
"despite these findings, we found no evidence that supervisors and
auditors who did not follow GAGAS and DCAA policy were disciplined,
counseled or required to take additional training." DCAA has required
several of the supervisors to take additional supervisory and
management training courses. They have completed some of these courses
and are scheduled to take additional training in the next fiscal year.
Based on advice provided by the DoD Washington Headquarters Services
Office of General Counsel, DCAA did not take performance or conduct
actions against these supervisor;. Additionally, all DCAA employees,
including the employees involved in the GAO's 2008 hotline
investigation, have completed annual training on auditor "independence"
and training in audit quality, including GAGAS, at mandatory standdown
days in August 2008 and 2009.
We appreciate the recommendations made by the GAO. We believe the
implementation of these recommendations along with the many actions
that the Department and DCAA have already completed will improve DCAA
culture and management environment to ensure taxpayer dollars are
protected and DoD audit needs are met. DoD and DCAA leaders are
committed to maintaining a strong contract audit function.
My point of contact on this matter is Mr. M. Wayne Goff. He can be
reached by e-mail at wayne.goff@osd.mil or by telephone at 703-602-
0374.
Sincerely,
Signed by:
Robert F. Hale:
Enclosures: As stated:
[End of letter]
Enclosure 1:
GAO Draft Report Dated July 31, 2009:
GAO-09-468 (GAO Code 195099):
"DCAA Audits: Widespread Problems With Audit Quality Require
Significant Reform"
Department Of Defense Comments To The GAO Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
revise the Defense Contract Audit Agency's (DCAA) mission statement to
reflect the need for quality contract audits and related nonaudit
services that take into account serving the public interest.
DOD Response: Concur. The Department is currently seeking final
coordination on a revised DCAA mission statement which is included in
an updated DoD Directive 5105.36, DCAA.
Recommendation 2: The GAO recommends that the Secretary of Defense
require the Under Secretary of Defense (Comptroller/CFO) to establish
milestones for completing DCAA corrective actions and monitor and
regularly report on DCAA progress to assure timely completion of
critical actions.
DOD Response: Concur. The Department will continue to establish
milestones for completing DCAA corrective actions. DCAA already
provides USD(C) a monthly status report of the actions taken in
response to the recommendations made by the Independent Review Panel of
the Defense Business Board as well as recommendations from various GAO
and DoD IG reviews. DCAA will expand its improvement plan to
incorporate the GAO's recommendations. USD(C) has assigned a senior
staff member to assist in oversight and has created the DCAA Oversight
Committee, including all three auditors general from the Services, the
OSD Deputy General Counsel for Acquisition and Logistics, and the
Director of Defense Procurement and Acquisition Policy, to assist in
oversight efforts.
Recommendation 3: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the Defense Contract Audit Agency (DCAA) in concert with
the revised mission statement, develop a Strategic Plan with short-term
and long-term outcome-related goals.
DOD Response: Concur. DCAA has already started developing a revamped
Strategic Plan with short-term and long-term outcome-related goals that
is in concert with the proposed mission statement. Assuming the revised
mission statement will be approved by about October 2009, DCAA is
expected to complete its strategic plan by November 30, 2009 for
publication and dissemination to the DCAA workforce.
Recommendation 4: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to measure progress in achieving strategic goals,
ensure that metrics tie to the revised mission statement and strategic
plan and support the agency's annual work plan.
DOD Response: Concur. USD(C) will require DCAA to measure progress in
achieving strategic goals. Once DCAA's revised mission statement and
strategic plan are finalized, USD(C) will require DCAA to ensure that
DCAA performance measures tie to the revised mission statement and
strategic plan and support the Agency's annual work plan.
Recommendation 5: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to consult with DoD stakeholders and engage
outside experts to develop a risk-based contract audit approach that
identifies resource requirements, and focuses on performing quality
audits that meet generally accepted government auditing standards
(GAGAS).
DOD Response: Partially Concur. The majority of DCAA audits and other
services are required by laws and regulations as outlined in the GAO
draft report. DCAA already has a risk-based contract audit approach in
identifying resource requirements. DCAA performs annual audit
requirements planning procedures to establish staffing requirements
based on its regulatory/statutory audit requirements and audit risk. An
example of DCAA's risk-based audit approach for incurred cost audit
requirements is DCAA's performance of desk reviews of the low risk
contractor's incurred costs on a cyclical basis in lieu of performing a
full incurred cost audit every year. Nevertheless, USD(C) will task
DCAA to coordinate with the Under Secretary of Defense for Acquisition,
Technology, and Logistics to assess DCAA audit requirements since any
significant change in DCAA audit requirements would involve a change in
acquisition policy. In addition, DCAA has engaged the Naval Post
Graduate School to assist in its "cultural transformation." One of the
projects is identifying and resolving differing stakeholder
expectations while ensuring DCAA performs quality audits that meet
GAGAS. DCAA's efforts will include consulting with DoD stakeholders and
engaging outside experts as part of this project. The Department will
complete its assessment by December 2010.
Recommendation 6: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to establish an SES-level position with
responsibility for audit quality assurance that requires demonstrated
knowledge and experience in applying professional audit standards.
DOD Response: Concur. In August 2008, DCAA established the position of
Assistant Director, Integrity and Quality Assurance with responsibility
for DCAA's quality assurance program. On July 9, 2009, this position
was approved as an SES-level position and the job announcement has been
published. DCAA expects to fill this position by October 2009.
Recommendation 7: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to establish a separate DCAA internal review
organization to conduct critical internal inspector general functions,
including performing periodic internal evaluations and reviews and
addressing DCAA hotline complaints.
DOD Response: Concur. DCAA will establish a separate internal review
organization to conduct critical internal inspector general functions,
including performing periodic internal evaluations and reviews and
addressing DCAA hotline complaints and serve as the Agency's ombudsman.
The new organization will be established by December 2009.
Recommendation 8: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to review DCAA's current portfolio of audit and
nonaudit services to determine if any should be transferred, or
reassigned to another DoD agency, or terminated in order for DCAA to
comply with GAGAS integrity, objectivity, and independence
requirements.
DOD Response: Concur. USD(C) will require DCAA to assess its current
portfolio of audit and nonaudit services to determine if any should be
transferred, or reassigned to another DoD agency, or terminated in
order for DCAA to comply with GAGAS integrity, objectivity, and
independence requirements. DCAA will report the results of its
assessment to USD(C) by March 2010. However, as stated above, the
majority of DCAA audits and non-audit services are required by
regulation or statute. As acknowledged by the GAO in its report, DCAA
has already performed some of this assessment resulting in
the elimination of DCAA auditor participation as members of Integrated
Product Teams and Source Selection Evaluation Boards.
Recommendation 9: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA based on the risk-based audit approach to develop
a staffing plan that identifies auditor resource requirements as well
as auditor skill levels and training needs.
DOD Response: Concur. DCAA is entering into an agreement with the Army
Management Support Agency to evaluate DCAA's requirements planning
process and resulting staffing assessment for FY 2010. The Army will
also provide an overall opinion on the sufficiency of DCAA staffing to
provide audit coverage in line with its mission and strategic plan and
fully comply with Generally Accepted Government Auditing Standards. In
addition, DCAA has an internal education specialist to provide expert
advice on DCAA training and an internal statistician to provide expert
advice on statistical sampling audit techniques and training.
Recommendation 10: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to establish a position for an expert on auditing
standards or consult with an outside expert on auditing standards to
assist in revising contract audit policy, providing guidance on
sampling and testing, and developing training on professional auditing
standards.
DOD Response: Concur. The USD(C) will require DCAA to consult with an
outside expert on auditing standards to assist in revising contract
audit policy, providing guidance on sampling and testing, and
developing training on professional auditing standards.
Recommendation 11: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to revise DCAA audit policy to provide appropriate
guidance on what constitutes sufficient testing to comply with GAGAS.
Update DCAA's Contract Audit Manual, as appropriate.
DOD Response: Concur. USD(C) will require DCAA to issue audit policy on
what constitutes sufficient testing to comply with GAGAS and update
DCAA's Contract Audit Manual. DCAA will complete this action by
December 2009.
Recommendation 12: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to develop agency wide training on government
audit standards. This training should emphasize the level of assurance
intended by the various types of engagements and provide detailed
guidance on auditor independence, planning, fraud risk, level of
testing, supervision, auditor judgment, audit documentation, and
reporting.
DOD Response: Concur. DCAA is currently developing a revised training
course on Generally Accepted Government Auditing Standards. This course
will emphasize the level of assurance intended by the various types of
engagements and provide guidance on auditor independence, planning,
fraud risk, level of testing, supervision, auditor judgment, audit
documentation, and reporting. All DCAA employees have been notified
that they will be required to take this course in FY 2010. DCAA is also
increasing the level and complexity of GAGAS training in all courses.
Recommendation 13: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to conduct a comprehensive, independent review of
DCAA's revised audit quality assurance function. This review should
focus on the consistent application of criteria used for assessing
audit quality and assuring timely, consistent and appropriate reporting
of review results.
DOD Response: Concur. On July 30, 2009, DCAA requested the DoDIG to
perform its external quality review of DCAA's Quality Control System
for audits and attestation engagements for the period ending September
30, 2009.
Recommendation 14: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to make appropriate recommendations to address
annual quality assurance review findings of serious deficiencies and
GAGAS noncompliance, provide training, and follow-up to assure that
appropriate corrective actions have been taken.
DOD Response: Concur. The DCAA Integrity and Quality Assurance
organization has already established a process for making
recommendations to address annual quality assurance review findings of
serious deficiencies and GAGAS noncompliance to the Director DCAA on a
real-time basis. Based on these recommendations, DCAA will ensure that
any necessary training is provided and appropriate corrective actions
have been taken.
Recommendation 15: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense (Comptroller/CFO) to require the
Director of the DCAA to establish policies and procedures to ensure
that auditors who make direct bill decisions are independent of
management employees who review vouchers of contractors not eligible
for the direct bill program, thereby reducing situations where DCAA
auditors are encouraged to reduce their workload by approving
contractors for the direct bill program.
DOD Response: Nonconcur. The Department believes that a review of the
contractor's interim public vouchers is an integral function of DCAA's
continual assessment of a contractor's billing system. A DCAA auditor
who audits the contractor's billing system (and potential subsequent
approval for direct bill) is in the best position to review and approve
contract interim billings based on their thorough understanding of the
contractor's system. In regards to the GAO concern that DCAA auditors
may not report findings to reduce their workload by approving
contractors for the direct bill program, the Department believes the
GAO's concerns are mitigated based on the comprehensive supervisory and
audit manager reviews. DCAA does not believe that the approval of
interim vouchers along with the approval for contractors to be on
direct bill results in a lack of auditor objectivity (see Enclosure 4,
Comment 8). It should also be noted that since July 2008, the number of
contractors on the direct bill program have been reduced by over 200
contractors and segments of many of the largest defense contractors
have been removed from the direct bill program in FY 2009. In October
2008, DCAA issued clarifying guidance on contractor eligibility to
participate in the direct bill program. This memorandum includes
guidance on ensuring sufficient testing is performed when determining a
contractor is eligible for direct bill.
[End of Enclosure 1]
Enclosure 2:
GAO Draft Report Dated July 31, 2009
GAO-09-468 (GAO Code 195099)
"DCAA Audits: Widespread Problems With Audit Quality Require
Significant Reform"
Department Of Defense Comments To The GAO Recommendations For
Congressional Consideration
Recommendation 1: In the short term, as DCAA makes progress in
correcting fundamental weaknesses that have impacted audit quality,
Congress could consider enhancing DCAA reform efforts by enacting
legislation to grant it protections and authorities similar to those
embodied in the Inspector General Act, as amended.
DOD Response: Nonconcur. DoD generally opposes providing DCAA with
authorities similar to those contained in the Inspector General Act.
DoD specifically opposes certain recommendations based on the IG model.
We do not believe that the DCAA Director should be a Senate confirmed
position unless DCAA is independent of DoD. Presidential nomination and
Senate confirmation injects a political element into DCAA that is not
appropriate and inevitably creates lengthy periods when there is no
Director. We also oppose fixed terms for the DCAA Director. If DCAA
remains part of DoD, the Secretary of Defense must have the ability to
choose an appropriate Director. We also question the wisdom of an
independent budget (which would prevent or limit our ability to move
money into DCAA, as is occurring now based on funding from the Defense
Acquisition Workforce Development Fund). Nor do we support mandatory
public reporting, an additional burden on an agency that is already
struggling to meet its many mission demands.
While we do not support independence based on the IG model, we plan to
take steps to strengthen DCAA's independence by establishing an appeals
process that permits DCAA to seek resolution when there are differences
of opinion as to the resolution of its audit findings. Under this
process, DCAA could appeal differences first to the Director of Defense
Procurement and Acquisition Policy (DPAP). If DCAA disagreed with the
DPAP decision, DCAA would be permitted to appeal to the Under
Secretaries of Acquisition, Technology, and Logistics and Comptroller,
acting as a team. We expect that appeals at the Under Secretary level
would be rare and would involve only the most important issues.
Recommendation 2: In the medium term, Congress could consider elevating
the contract audit function within DOD by moving DCAA from under the
DOD Comptroller/CFO and placing it under the Deputy Secretary of
Defense.
DOD Response: Nonconcur. DoD strongly opposes this recommendation. The
Deputy Secretary is the Chief Management Officer of one of the world's
largest organizations and backs up the Secretary in the wartime chain
of command. The Deputy simply does not have the time to provide
oversight and support to individual defense agencies.
[End of Enclosure 2]
Enclosure 3:
DCAA Actions Taken Since the Issuance of GAO Report GAO-08-857:
Structure:
* Approved Agency-wide reduction in supervisory span of control (June
2008).
* Approved 25 new field audit offices and 5 new Regional Audit Managers
lowering the span of control (May - February 2009).
* Completed Agency-wide staffing assessment and requested staffing
increase to Comptroller on September 10, 2008. Updates on staffing
shortfalls were provided to the Comptroller at regular intervals
throughout FY 2009.
* Realigned Quality Assurance to report directly to the Deputy Director
(August 2008).
- Submitted request to OSD for SES level position for the Integrity and
Quality Assurance (QA) function (September 2008). Request was initially
denied by DoD in January 2009 and the position was filled at the GS-15
level. However, after another attempt by the Director for a SES
position, DCAA received approval in July 2009 and a job announcement
was issued shortly thereafter.
- Expanded the next round of QA reviews.
- Revised process for tracking and following-up on QA findings.
- Revised process for next 3-year cycle to ensure all audit offices are
covered, after consultation with the DoD IG.
- Completed assessment on level of QA staffing.
- Issued revised comprehensive instruction on DCAA's QA program
(December 2008).
* Submitted request for funds under Section 852 acquisition workforce
fund in December 2008. Under the Defense Acquisition Workforce
Development Fund, DCAA has received $17.2 million to date (allotments
in March, April, and August).
* DCAA brought on-board 245 new interns by the end of July and have
many offers with on-board dates in late FY 2009. As a result, DCAA will
easily meet the goal of 300 by the end of September and will probably
exceed it.
* Realigned all Financial Liaison Advisors from the Field Detachment
region (region that handles all Top Secret audits) to Headquarters to
avoid the appearance of a lack of independence. As of November 2008,
all Financial Liaison Advisors report directly to Headquarters.
* At the request of the Director, the DCAA point of contact for the
Office of Special Counsel investigation was moved from the DCAA General
Counsel to the DoD General Counsel's office due to the investigation
being expanded.
Culture:
* Revised policy for resolving differences in audit results and
opinions - elevate within management structure from two to four levels
(July 2008).
* Ceased participation as members of Integrated Product Teams (IPTs) to
avoid the appearance of a lack of independence (August 2008).
* Revised performance measures - eliminated 18 measures and added 8
measures (September 2008).
* Established an anonymous website for employees to voice concerns with
the inappropriate use of performance measures and other inappropriate
actions (September 2008).
* Engaged OPM to conduct an organizational assessment survey and are
assessing results of the survey conducted by OPM - the working group is
evaluating results and developing actions (assessment due August 2009).
* Ceased participation as members of Source Selection Evaluation Boards
to avoid the appearance of a lack of independence - requested audits
will still be provided (November 2008).
* Director/Deputy Director staff presentations emphasize the need to
perform quality audits and discuss performance measures (various
presentations through 2008 and 2009).
* Established a Senior Advisory Council for Improvement chaired by the
Director to Oversee the implementation of improvements as a result of
the Defense Business Board recommendations (report issued January 22,
2009).
* Issued several memorandums reiterating the importance of cooperating
with GAO, IG and other reviewers/investigators.
* Held stand down day for audit quality at all DCAA locations (August
/September 2008 and again in August 2009).
* Completed annual independence training (September 2008).
* Held focus groups to obtain feedback on implementation of performance
measures issued in September 2008 which revealed minimal problems with
implementation of new measures (February/March 2009).
* The Director required all regions to assess whether exceeding budget
hours on individual assignments was inappropriately used to lower
performance ratings. The regions completed the assessments and, where
needed, have implemented corrective actions (December 2008).
* Established new process to obtain input regarding the new hire
employment experience and to identify reasons why employees leave DCAA
(November 2008).
* Revised job objectives/performance plans for the 0511 (auditor)
positions to eliminate the language on meeting audit budget hours and
productivity measures and added language strengthening the need to
execute audits in accordance with the auditing standards and Agency
policy (February 2009).
* Revised supervisory development curriculum based on feedback from
focus groups and other feedback mechanisms to emphasize leadership
skills and the more common day-today activities which supervisors
perform (April 2009).
Processes:
* Issued memorandum on adequate working paper documentation (July
2008).
* Completed Agency-wide assessment to determine whether GAO's findings
are systemic across DCAA. Six of the forty assignments reviewed
contained noncompliances. Actions being taken to address issues
(September 2008).
* Raised the field audit office signature authority for all audit
reports to the level of the manager or higher (August 2008).
* Revised policy for the monthly quality review of issued audit reports
from regions to the Headquarters Quality Assurance division (October
2008).
* Revised DCAA Quality Checklist for Review of Audit Working Papers
(checklist is used by auditors and supervisors prior to report
issuance) (December 2008).
* Issued guidance clarifying DCAA's process for pursuing access to
contractor records and initiating a subpoena (December 2008).
* Issued clarifying guidance on what constitutes a significant
deficiency in contractor internal control systems (December 2008).
* Revised policy on reporting results of the review of contractor
systems and related internal controls to eliminate the inadequate in-
part opinion so that the overall opinion on the system is either
adequate or inadequate (December 2008).
* Issued guidance on performing and reporting on limited scope internal
control audits (December 2008).
* Issued guidance reminding auditors to report suspected contractor
fraud and other irregularities encountered during the audit and
emphasized that managers do not approve the Form 2000, but rather
review it for clarity (February 2009).
* Issued guidance on documentation of judgmental sampling (February
2009).
* Revised guidance for reporting unsatisfactory conditions related to
actions of Government officials wherein certain unsatisfactory
conditions will be reported directly to the DoDIG in lieu of reporting
the conditions to a higher level of management (March 2009).
* Issued guidance clarifying requirements for contractor eligibility to
participate in the direct bill program (April 2009).
* Issued guidance to remove major contractors from direct billing where
contractor has implemented a new billing system or accounting system
that significantly impacts Government billings and the new system has
not been examined (April 2009).
* Revised a self-study training course (CMTL 1326) to include new
guidance on identifying key elements of an effective internal control
audit report and the requirements for issuing a real-time (flash)
report (May 2009).
* Issued an audit alert emphasizing existing guidance which requires
that a separate cost accounting standards (CAS) noncompliance audit
report will be issued when a CAS noncompliance is found during any
audit (June 2009).
* Issued an audit alert to clarify that forward pricing due dates
should be based on the realistic assessment of risk factors for each
specific contractor and proposal under review (June 2009).
* Issued guidance on contract audit closing statement reviews in July
(after receipt of DoD IG comments). This completes the last action item
from the peer review.
Long-Term Planned Actions:
* Obtained the services of the Naval Postgraduate School, Center for
Defense Management Reform to assist with the Agency-wide cultural
transformation. The initial effort started June 2"d with the DCAA
executive team. As a result, four major initiatives were adopted for
incorporation in the DCAA Strategic Plan. Teams of executives were
assigned to each initiative to further develop the milestone plan for
executing the objective. The four items are:
1. How can DCAA put people first to guide its decisions, actions and
values? For example, how can DCAA place an increased emphasis on "soft
skills" such as building morale and developing employees (in terms of a
broad understanding as well as technical proficiency)?
2. How can DCAA develop leaders to serve the employees and the
organization?
3. How can DCAA structure the organization to facilitate compliance
with GAGAS, maximize audit results/ROI, and better align Agency
workload/resources?
4. How can DCAA identify and resolve differing stakeholder expectations
with contracting officers, contractors, the public (Congress), and
external review organizations?
These items will be worked for about the next three years. Once the
milestone plan for each of the four initiatives is developed, it is
envisioned that each objective will have various completed actions
throughout the next three years. Once the milestone plans are
developed, the objectives will be communicated to the workforce.
* Performing a comprehensive assessment and revision to DCAA training
by instituting a life-cycle training process. Effort started in FY 2008
and will conclude in about three years.
* Conducting a comprehensive organizational assessment (based on
Baldrige). Estimated completion in FY 2010.
* Performing a comprehensive review of DCAA's approach for performing
internal control audits. Estimated completion of baseline audit
opinions in FY 2010.
* Engaging the Army Force Management Support Agency to evaluate DCAA's
process for planning FY 2010 audit needs as well as staffing
requirements. The effort is expected to be completed by the end of
September.
[End of Enclosure 3]
Enclosure 4:
GAO Draft Report Dated July 31, 2009:
GAO-09-468 (GAO Code 195099):
"DCAA Audits: Widespread Problems With Audit Quality Require
Significant Reform"
Department Of Defense Comments To The GAO Report Narrative:
1. GAO Narrative: Nationwide audit quality problems are rooted in
DCAA's poor management environment (page 11).
DOD Comments: GAO stated about half of the rescinded reports relate to
unsupported opinions on contractor internal controls. This is
incorrect. The majority of the rescinded reports relate to forward
pricing reports based on the prior GAO investigation report issued in
2008. [See comment 1]
2. GAO Narrative: Audit Quality Problems Found in All Audits GAO
Reviewed, Independence Issues (page 12).
DOD Comments: GAO stated that in 8 audits they reviewed, DCAA
independence was compromised because auditors provided material
nonaudit services to a contractor they later audited; experienced
access to records problems that were not fully resolved; or
significantly delayed report issuance in order to allow the contractors
to resolve cited deficiencies. The Department understands the GAO's
concerns, however, we believe the auditors' intent of providing
preliminary audit results and discussing draft policies and procedures
was generally an attempt to ensure the evidence was accurate and to
expedite contractor actions so that contractor systems would be
corrected promptly to minimize the risk of overpayments. DCAA
acknowledges that significant time lapsed in several of these
assignments between the time the contractor was provided the draft
findings and the issuance of the final audit report. DCAA concurs that
auditors should not provide input to contractors on draft policies and
procedures and that the reports should identify all deficiencies found
even though they have been corrected at the time of report issuance. In
memorandums issued in August and September 2008, DCAA issued guidance
prohibiting auditors from providing input to contractors on such items
as draft proposals, draft policies and procedures, and draft disclosure
statements and to require auditors to report all deficiencies found
even when the contractor corrects the deficiencies during the audit.
3. GAO Narrative: Audit Quality Problems Found in All Audits GAO
Reviewed, Insufficient Evidence (page 12).
DOD Comments: GAO stated that 33 of the 37 internal control audits did
not include sufficient testing to support auditor conclusions and
opinions. GAO stated that GAGAS for examination-level attestation
engagements require that sufficient evidence be obtained to provide a
reasonable basis for the conclusion that is expressed in the report. We
agree with GAO that in several cases the testing was insufficient. The
level of testing was based on the auditor's judgment and the total
audit concept - drawing on an accumulation of knowledge and experience
previously gained at the contractor based on auditing that contractor
on a continual basis. Nevertheless, DCAA acknowledges the testing was
insufficient to support an internal control audit opinion, and
therefore, has rescinded several of these reports, increased the level
of testing on related audits and commenced new full scope internal
control audits at these locations.
4. GAO Narrative: Table 2, Summary of Five Selected Internal Control
Audits, Eastern Region - Billing System Audit (page 16).
DOD Comments: GAO stated that the subject audit had an impairment to
auditor independence because the auditors helped the contractor develop
policies and procedures. We generally concur with the GAO in that the
FAO was performing IPT type effort in providing the contractor comments
on draft policies and procedures. DCAA believes the intent of these
actions was to expedite contractor corrective action so that the
contractor's system would be corrected to minimize the risk of
overpayments and protect the taxpayer's interests. DCAA recognized the
potential appearance of a lack of independence related to this kind of
effort and on August 11, 2008, issued audit guidance that prohibited
auditors from providing input to contractors on such items as draft
policies and procedures regardless of the circumstances.
5. GAO Narrative: Table 2, Summary of Five Selected Internal Control
Audits, Central Region - Billing System Audit (page 16).
DOD Comments: GAO stated that the subject audit had an impairment to
auditor independence because the auditors monitored contractor
corrective action for 7 months instead of issuing the audit report when
the work was completed. DCAA concurs with the GAO that the significant
lapse of time from the date the draft results were provided to the
contractor and the date the audit report was issued gives the
appearance of a lack of independence. However, the field audit office
does not believe it intentionally delayed the issuance of the report to
allow the contractor to correct the system. Staffing issues and an
increase in higher risk assignments played a significant role in the
delay. [See comment 2]
6. GAO Narrative: Table 2, Summary of Five Selected Internal Control
Audits, Central Region - Billing System Audit (page 16/17).
DOD Comments: The GAO narrative appears to imply that DCAA was not
aggressive in pursuing the potential fraud at this contractor. It
should be noted that the DCAA Investigative Support Team was
instrumental in assisting in this fraud investigation that resulted in
recovering more than $2.8 million dollars in a civil case settlement.
[See comment 3]
7. GAO Narrative: Cost Related Assignments (page 17).
DOD Comments: GAO stated that the 32 cost-related assignments did not
contain sufficient testing to provide reasonable assurance that
overpayments and billing errors that might have occurred were
identified. It appears that the GAO is holding DCAA to the GAGAS
requirements for these assignments even though the majority is not
GAGAS-type audits based on Agency policy. DCAA does not agree that all
of the 32 cost-related assignments contained insufficient testing,
however, DCAA is continuing to assess the GAO's comments and will
develop an appropriate action plan. [See comment 4]
8. GAO Narrative: Auditor objectivity issues (page 20).
DOD Comments: GAO stated that DCAA's role in approving contractors for
participation in the direct bill program presented an impairment to
auditor objectivity- which includes being independent in fact and
appearance when providing audit and attestation engagements. The GAO
noted that GAGAS state that audit organizations should not authorize an
entity's transactions or audit their own work. GAO further stated that
DCAA's role in authorizing contractors to participate in the direct
bill program places it in the position of making decisions that impact
its own workload related to review of contractor invoices prior to
payment. Although not explicitly stated, the GAO seems to imply that
when DCAA performs an audit of the contractor's billing system (and
potentially approves the contractor for the direct bill program) while
also having the responsibility for approving interim vouchers, DCAA is
authorizing the contractor's transactions and it is auditing its own
work. In addition, the GAO seems to imply that DCAA's objectivity is
impaired and DCAA auditors may overlook findings to reduce their
workload by approving contractors for the direct bill program. DCAA
disagrees with both implications. [See page 76]
DCAA is not authorizing a contractor's transaction or auditing its own
work either when it approves the contractor for direct bill or approves
an interim voucher for payment. GAGAS 3.14 (GAO-03-673G) defines
authorizing an entity's transactions as an example of performing
management functions or making management decisions. When DCAA approves
a contractor's voucher for payment it is not acting on behalf of the
contractor (i.e., performing a contractor management function) but
acting as a representative of the Government in its role as an
independent external oversight organization based on the authority
provided for in DFARS 242.803. The contractor's interim vouchers
submitted to the Government for payment are prepared by contractor
employees and authorized by contractor management.
DCAA also does not believe that performing the function of an external
oversight organization by approving contractor's interim vouchers or
approving the contractor for the direct bill program places DCAA in the
position of auditing its own work when it later audits the contractor's
billing system. These functions do not involve developing the
contractor's billing system policies and procedures and internal
controls. In addition, as stated above, DCAA also is not involved in
preparing the contractor's vouchers. Therefore, approving contractor's
interim vouchers or approving the contractor for the direct bill
program and subsequently auditing the contractor's billing system does
not result in DCAA auditing its own work. Furthermore, DCAA believes
that its role in reviewing and approving interim vouchers falls within
the category of nonaudit services discussed in GAGAS A3.02 and A3.03
(GAO-07-731G) that do not impair independence.
We also disagree that DCAA's role in authorizing contractors to
participate in the direct bill program results in an impairment to
independence because performing that function places DCAA in the
position of making decisions that impact its own workload. In our
opinion the GAGAS independence standards do not preclude the auditor
from performing such functions. In fact, conclusions reached in many of
the audits and other functions typically performed by auditors have the
potential to impact the audit organization's workload. For example, a
qualified or adverse opinion on the company's financial statements
could prompt the company to replace the independent public accountant
(IPA) that performed the audit; thereby negatively impacting the IPA's
future workload and revenue. The GAO's concerns are mitigated by the
fact that DCAA supervisors are actively involved in all aspects of the
audit including review and approval of the risk assessment, interim
reviews as needed, and a final comprehensive supervisory review of the
working papers and draft report. Technical specialists may also review
the risk assessment and audit conclusion. In addition, field audit
office managers review sensitive and high risk audits and may elevate
them for regional management review prior to report issuance.
GAO stated that DCAA had approved direct billing on all but 2 of the 16
contractors they reviewed. GAO reviewed 20 billing system audits
covering 17 contractors, only 2 of those contractors are still on
direct billing. It should also be noted that since July 2008, the
number of contractors on the direct bill program have been reduced by
over 200 contractors.
9. GAO Narrative: DCAA's audit quality assurance program was
ineffective (page 25).
DOD Comments: GAO stated that DCAA's audit quality assurance program
was not properly implemented, resulting in an ineffective quality
control process that accepted audits with significant deficiencies and
noncompliance with GAGAS and DCAA policy. We do not agree with the
statement that the quality assurance process accepted audits with
significant deficiencies. As the GAO states in its report, the quality
assurance reviews did identify significant GAGAS noncompliances which
they reported to the field audit office for corrective action - they
did not "accept" these audits. DCAA has recently made several
improvements to the quality assurance program to include increasing the
level of management responsible for developing and implementing a
corrective action plan. The current program requires the Regional
Director to ensure corrective actions have been taken and all
corrective actions will be tested by the Headquarters quality assurance
staff to ensure the noncompliances have been corrected. [See page 78]
10. GAO Narrative: DCAA lacks a risk-based audit planning approach
(page 28).
DOD Comments: GAO stated that DCAA lacks a risk-based audit planning
approach. We do not agree with this statement. DCAA has a risk-based
contract audit approach in identifying resource requirements. DCAA
performs annual audit requirements planning procedures to establish
staffing requirements based on its regulatory/statutory audit
requirements and audit risk. [See page 75]
11. GAO Narrative: Allegations about abusive management actions have
continued (page 32).
DOD Comments: The GAO states that allegations about abusive management
actions have continued. The report further states that "DCAA
Headquarters officials explained that in several cases, Western Region
management has not agreed to take disciplinary or other available
corrective action. The officials told us that DCAA hotline staff has no
recourse in these situations." The DCAA hotline group functions as a
finder of fact, and they recommend corrective actions. While it is true
that the DCAA hotline group has no authority to take disciplinary
action itself or to require corrective action, any disagreement between
the hotline team and the region may be resolved by the DCAA Director or
Deputy Director. The Western Region management has agreed with the
recommended actions provided by the hotline team in a final formal
report. Several cases are still in the investigative stage and although
interim recommendations may not have been adopted yet by the region, we
fully expect the Western Region management to support the
recommendations made in a final report.
12. GAO Narrative: Increase authority and independence (Page 50).
DOD Comments: GAO stated that legislation could strengthen DCAA's audit
authority by providing the same level of access to records and
personnel available to IGs. GAO goes on to state that currently, DCAA
has access to certain records related to cost-type contracts or that
contain cost and pricing data, but not to contractor personnel. We do
not agree with the statement that DCAA does not have access to
contractor personnel. DCAA interfaces with contractor employees during
all phases of the audit, which include interviews, inquiry, observation
as well as providing draft audit results for comment and verification
of factual content. [See comment 5]
13. GAO Narrative: Independence Impairments, (Pages 60-61).
DOD Comments: The GAO provides an example in this narrative section
where the GAO contends that the field audit office experienced an
access to records issue. The GAO concludes that since the contractor
inquired regarding the auditor's need for certain data, there was an
access to records issue. DCAA routinely encounters "push back" from
contractors, this does not constitute an access to records impairment
if the auditor does not succumb to the pressure and obtains the
requested data. The field audit office does not believe its access to
data relating to the training records was denied by the contractor as
cited by the GAO. The contractor subsequently provided the requested
data to the auditor. [See comment 6]
14. GAO Narrative: Failure to Design and Perform Procedures to Detect
Fraud Risk (Pages 64-66).
DOD Comments: The GAO provides an example in this narrative section
where the GAO contends the FAO manager and supervisor ordered an
auditor to ignore significant fraud risks during the audit. DCAA does
not agree with this conclusion and has not been provided evidence to
support this assertion. It should be noted that the DCAA was
instrumental in assisting in this fraud investigation that resulted in
recovering more than $2.8 million dollars in a civil case settlement.
[See comment 3]
Defense Procurement and Acquisition Policy (DPAP):
Collateral Action Officer's Comments on GAO Draft Report: "DCAA Audits:
Widespread Problems With Audit Quality Require Significant Reform"
Following are the DPAP's Collateral Action Officer's (CAO's) technical
comments regarding the Government Accountability Office's (GAO's) July
31, 2009 Draft Report GAO-09-468 (GAO Code 195099) "DCAA Audits:
Widespread Problems With Audit Quality Require Significant Reform".
1. Auditing in the Public Interest:
The report, in part, impugns DCAA's audits stating, "DCAA's management
environment ... put DCAA in the role of facilitating DoD contracting
without also protecting the public interest."[Footnote 1] Likewise, the
GAO mentions that the "DCAA mission should be refocused to protect the
taxpayer interest ..." compared to the current mission that "fostered
the culture of supporting contracting officials[Footnote 2] 2 As a
result, the GAO agrees with the Defense Business Board's recommendation
to "revise DCAA's mission to focus on protecting the interest of
taxpayers, with the taxpayer as the primary customer...[Footnote 3]
[See page 78]
The report adopts a position that because DCAA is serving the interests
of Contracting Officers, that DCAA is not auditing in the interest of
the public. DCAA is a service organization created to provide financial
information, audits, and advice to support decision making by DoD
Contracting Officers. DCAA serves the public interest by providing
timely and useful information to Contracting Officers. It is erroneous
to imply that contracting officers do not seek to protect the public
interest.
The contracting officer is bound by regulation to meet the public
interest in the broadest sense, for the entire matter surrounding a
contract. The contracting officer, in the award and administration of a
contract, is the government official responsible for insuring that all
requirements of law, executive orders, regulations, and all other
applicable procedures, including clearances and approvals, have been
met. Any logic that presumes that by focusing on supporting contracting
officials DCAA somehow failed to act in the public interest is flawed
in our view. Someone trained and named in both law and regulation has
to look at the larger picture, and not just the audit, if the public
interest is to be served-the contracting officer is that person.
Numerous provisions of the Federal Acquisition Regulations (FAR), for
instance, speak to the issue of all members of the acquisition and
administration community serving the public interest:
An essential consideration in every aspect of the System is maintaining
the public's trust. Not only must the System have integrity, but the
actions of each member of the Team must reflect integrity, fairness,
and openness. The foundation of integrity within the System is a
competent, experienced, and well-trained, professional workforce.
Accordingly, each member of the Team is responsible and accountable for
the wise use of public resources as well as acting in a manner which
maintains the public's trust. Fairness and openness require open
communication among team members, internal and external customers, and
the public.[Footnote 4]
Specifically to contracting officers, FAR states:
Contracting officers are responsible for ensuring performance of all
necessary actions for effective contracting, ensuring compliance with
the terms of the contract, and safeguarding the interests of the United
States in its contractual relationships. In order to perform these
responsibilities, contracting officers should be allowed wide latitude
to exercise business judgment.[Footnote 5]
By serving the interests of Contracting Officers well, DCAA does serve
the public interest. It is not one or the other as might be interpreted
in the report.
2. Production Auditing:
Throughout the report, the GAO implies and in some instances states
that the problem is "Production-Oriented Auditing" and that audits have
been rushed by contracting officer requirements. This sets up a
dichotomy between "quality" audits and timely audits. We strongly urge
the GAO to consider that an audit not delivered in time to be useful,
is of limited value to the Government. [See comment 7]
For example, a proposal review delivered after negotiation has started
and decisions have already been made is of greatly diminished
usefulness. Likewise, an incurred cost review that is not completed in
a reasonable period after the costs are incurred loses contemporaneous
support-employees of the contractor and the Government leave, some
records are lost or are placed in deep storage. Similarly, business
system reviews need to be issued while a problem is still subject to
correction before the fact to protect the Government's interests, not
two and three years later.
Timeliness is a critical element of quality. Delays in award have
consequences to the warfighter. Contracting officers are required to
consider those consequences and hence, they are very concerned that
DCAA has not been able to consistently deliver timely reports and
advice. The GAO has previously recognized there are consequences to
award delays:[Footnote 6]
"Although federal regulations do not specify how long the contract
award process should take, the regulations state that the purpose of
planning the contract award process is to ensure that the government
obtains the needed goods or services in the most effective, economical,
and timely manner. Therefore, written plans for carrying out the award
process must include milestones for completing the steps in the
process, such as when the agency plans to solicit and evaluate
proposals and make the award. Developing and adhering to these
schedules can help ensure that the department conducts the process
efficiently and can help companies make informed business decisions
regarding the allocation of their resources and whether to compete for
a contract."
"Delays in awarding contracts could increase costs... and could also
affect the willingness of companies to compete for future...contracts
....Specifically, in addition to investing time and resources in
developing proposals, once a company submits a proposal ... the company
is generally required to ensure that the key personnel identified in
the proposal continue to be available until the decision is made and
the contract awarded....Increased costs and the length of time it takes
...to award a contract also have the potential to affect competition
for future...work."
GAO's recognition of this fact in the aforementioned report, while
important, is still a comparatively limited view of timeliness compared
to a contracting officer's point of view. A contracting officer knows
that delays can impact funding decisions and disrupt program management
plans. Contracts are often interrelated and codependent, such that a
delay in awarding one contract can delay an entire system and put off
fielding dates, with consequences distributed and cascading through a
range of other contracts and plans, and might ultimately result in
mission failure. The contracting officer, also by regulation, has to
consider and respect the opinions of other specialists that he works
with, and not just that of the auditor. A good audit in time is better
than an extraordinary audit that is late and never used. An audit is a
tool the contracting officer uses to negotiate and administer a
contract, but in order to realize the benefits of the auditor's work,
the audit must be timely.
3. Generally Accepted Government Auditing Standards (GAGAS):
As the GAO correctly points out, DCAA performs most of its audits and
reviews in conformance with GAGAS. We believe that for some reviews and
financial advice provided by DCAA, it is possible that it may not be
necessary to provide a fully conforming GAGAS audit report to support
certain contracting officer functions (e.g., providing an attestation
review rather than a financial audit). DCAA should use auditing
standards and techniques that produce creditable information that can
be relied upon by the contracting community in the awarding and
administrating of contracts. However, we believe that all types of DCAA
reports and reviews should be examined to determine if the standard
being applied and reported by DCAA is the appropriate standard given
the requirement causing the audit or review to be performed. [See
comment 8]
4. Staffing:
While the report cites examples of poor quality audits and some poor
decisions made by DCAA management, most would seem to be heavily
influenced by lack of adequate staffing. Based on our discussions with
contracting officers, contractors, and auditors, some and possibly most
of the reductions in audit scope and responsiveness by DCAA is a direct
result of the staffing drawdown while workload increased. Until the
staffing issues are resolved, it will not be possible for DCAA to
perform at the level of quality and efficiency that is desired.
Rebuilding the DCAA workforce, while a challenge, can and must be done.
The workforce build-up will require years of effort to hire and train
the staff required to do the work envisioned by the GAO audit. [See
comment 9]
5. Placement of DCAA in the Executive Branch:
The report raises the question of DCAA's placement within DoD or the
Executive Branch. Currently DCAA performs most of the contract auditing
functions within the Executive Branch. Even if DCAA performed the
remaining contract audits it currently is not performing, DoD would
remain by a large factor the majority user of the DCAA services. We do
not believe that any useful purpose would be served by moving DCAA
outside DoD. DoD has the most vested interests in a well functioning
DCAA. [See page 74]
In our view, in reporting to the Comptroller, DCAA is insulated from
direct influence from contract procurement and contract administration
offices. For similar reasons DCMA is in the AT&L chain of command to
insulate it from pressures it might have placed on it, if it were in
the same chain of command as the procurement offices. The Comptroller
is in the best position to understand the DCAA requirements while
maintaining its independence from the audit report users.
6. Risk Based Auditing:
According to the DCAA Contract Audit Manual,[Footnote 7] all audit
planning is risk based. This applies to both the annual planning for
types of audits and staff requirements as well as for the planning of
specific audits. The Audit Manual is quite clear that the final budget
set for the assignment is to be based on the circumstances and risk
attached to the assignment being planned. Further, it also clearly sets
out that as circumstances change or the risk is found to be different
than considered during the planning stage, that budget changes should
be made. [See page 75]
We are faced in the GAO report with the finding that budgeted hours do
not reflect the risk and that changed risk found during the field work
has not resulted in changed budgets. This is obviously not a policy
matter of DCAA not doing risk-based auditing, since the findings are
clearly at odds with the DCAA policy. We believe that the failure to
follow the policy is a result of staffing constraints that made it
impossible for DCAA to perform all the assigned review requirements to
the standards expected.
7. Direct Billing:
This GAO draft report seems to misunderstand the Direct Billing program
and the problems noted in DCAA administration of voucher reviews.
Direct Billing approval was not designed to reduce review of vouchers.
It was designed to administratively take advantage of technology to
better process vouchers in an efficient manner and to better comply
with the Prompt Payment Act. In appropriate circumstances using risk-
based analysis of contractor past performance and the quality of its
business systems, contractors were to be allowed to be paid before
review of vouchers instead of requiring review of the vouchers before
payment. [See page 76]
The nature of the review program for any given contractor should not
have changed due to placement on Direct Billing. The DCAA guidance
requires voucher reviews of all contractors every year that the
contractor has Direct Billing authority. Where DCAA believed based on
past performance or poor systems that there was a significant chance of
improper billing, the contractor was not to be included in the Direct
Billing program. The review program for the contractors should have
been the same as it would have been based on risk factors even if there
was no Direct Billing program.
The problem with voucher reviews both before the Direct Billing program
and after the initiation of the program is that DCAA did not have
sufficient staff to perform the reviews required by the risk-based
analysis. New contractors and problem contractors should have voucher
reviews before payment just as required by DCAA policy. Established
contractors with adequate past performance should have vouchers
reviewed after payment using a reasonable plan tailored to the
contractor's circumstances just as required by DCAA guidance. Changing
the decision authority for participation in Direct Billing should have
no impact on what vouchers are reviewed. Taking a contractor off of the
program does not ensure that the vouchers will be properly reviewed
prior to payment if there is not sufficient staff to perform the
reviews.
Footnotes for Appendix IV:
[1] Executive Summary.
[2] Page 34.
[3] IBID.
[4] FAR 1.102-2 (c)(1) Performance standards.
[5] FAR 1.602-2 Responsibilities.
[6] GAO-06-722, DOE Contracting, Better Performance Measures and
Management Needed to Address Delays in Awarding Contracts, June 30,
2006.
[7] Chapter 3, Section 100.
The following are GAO's comments on the U.S. Department of Defense
letter dated September 4, 2009.
GAO Comments:
1. Rescinded reports. DOD stated that we were incorrect in stating that
about half of the rescinded reports relate to unsupported internal
control reports. DOD is correct. Of the 80 rescinded audit reports, 24
(31 percent) relate to unsupported opinions on contractor internal
controls, 47 (61 percent) relate to forward pricing reports, and 6 (8
percent) relate to defective pricing, compliance with cost accounting
standards, and a labor floor check. We have corrected this information
in the body of our report.
2. Central Region billing system audit. DOD stated that the DCAA field
audit office does not believe that it intentionally delayed issuance of
the report to allow the contractor to correct the system. Audit
documentation clearly shows that the auditors monitored the
contractor's actions for 7 months and issued the audit report 9 months
after the exit conference, once the contractor had prepared "written
desk procedures to ensure liquidation progress billings would be
handled correctly." Opinions should be based on the findings at the end
of the audit, and reports should be issued when the audit is completed.
3. Central Region billing system audit during fraud investigation. DOD
stated that our report appears to imply that DCAA was not aggressive in
pursuing the potential fraud at this contractor and noted that the DCAA
Investigative Support Team was instrumental in assisting in the fraud
investigation that recovered over $2.8 million in a civil case
settlement. The audit documentation shows that the Regional Audit
Manager, in the presence of the field office manager and the
supervisory auditor, directed the auditor not to pursue contractor
charges of costs to future-year, unfunded contract lines and to forget
what she learned in her previous DOD contract administration job where
she had been responsible for reviewing similar types of contracts. In
addition, after reassignment of the first supervisor, the second
supervisory auditor instructed the auditor to stop "over documenting"
her audit, to complete the assignment, and issue the report. Moreover,
the DCAA auditors who investigated the fraud worked with the Army
Criminal Investigative Division special agent and Department of Justice
Attorneys, not the DCAA field audit office. Finally, we did, in fact,
discuss additional documentation we received from the investigative
auditors with DCAA headquarters officials and provided them a summary
of the key audit-related issues that we obtained from the
investigators.
4. Insufficient testing in cost-related assignments. DOD stated that it
appears that GAO is holding DCAA to the GAGAS requirements for these
assignments even though the majority of these audits are not GAGAS-type
audits. As discussed in our report, DCAA does not consider its paid
voucher reviews and overpayment assignments to be GAGAS assignments.
However, this is important work intended to assure the reliability of
contract payments. Specifically, DCAA paid voucher reviews are relied
on for making billions of dollars in continuing contract payments
without prior review by the government. The Defense Finance and
Accounting Service (DFAS) relies on DCAA voucher reviews, and DFAS
certifying officers do not repeat review procedures they believe were
performed by DCAA. Because paid voucher reviews constitute a payment
audit, they require sufficient testing to support reported DCAA
conclusions that the government can rely on contractor controls over
preparation of interim vouchers to continue to make contract payments
without prior review. In addition, DCAA's overpayment audits are
intended to determine whether the contractor has adequate controls in
place to detect and correct causes of overpayments and billing errors
and make timely refunds and adjustments. The limited testing we
observed in our work does not provide the intended assurance.
5. Increase authority and independence. DOD stated that it did not
agree with our statement that DCAA does not have access to contractor
personnel. The discussion in our report is based on DCAA's authority in
10 U.S.C. 2313(a)(B)(2), which gives DCAA legal access to certain
contractor records but not access to contractor personnel. Further,
DCAA subpoena authority in 10 U.S.C. 2313(b) is specific to the
production of contractor records that DCAA is authorized to audit or
examine and does not cover contractor personnel. We agree that in
practice, DCAA auditors have numerous ongoing discussions with
contractor personnel. However, if a contractor official refuses to talk
to an auditor, DCAA does not have legal authority to compel contractor
officials to meet with or talk to DCAA auditors. Our point is that
under authority similar to the IG Act, DCAA's authority to interview
contractor officials would be enhanced.
6. Independence impairments. DOD stated that DCAA routinely encounters
"push back" from contractors and that the DCAA field office
subsequently received training records from the contractor. We
recognize that the field office received some training records from the
contractor. However, we saw a pattern throughout this audit where the
auditor limited requests for contractor documentation and also
performed little or no testing in various areas because "the contractor
would not appreciate it" if he did more testing. The audit
documentation shows that the auditor performed limited testing of
selected billing clerk training. Additionally, documentation on testing
of the contractor's review of subcontractor costs shows that although
the auditor should have tested cost data for three of the top five
subcontractors, the auditor asked the contractor to "provide a list of
the top 3-5 subcontracts, including subcontract values.... Three
subcontractors would be fine." This indicates that the auditor not only
accepted data the contractor was willing to provide for testing, but he
also let the contractor select the data to be used for testing. The
auditor then tested costs of only one subcontractor. The pattern of
backing off on requests for documentation and limiting the extent of
testing based on concerns about the contractor's reaction indicates
that the auditor was influenced by the contractor and limited his audit
procedures as a result--a clear independence impairment. DCAA rescinded
the audit report on February 10, 2009.
7. Production auditing. USD AT&L comments suggest that there is a trade-
off between audit timeliness and audit quality. We view both quality
and timeliness as critical to effective contracting officer decision
making. However, timely audits that do not meet professional standards
are not quality audits and could be misleading or impair important
contract decisions. For example, our audit identified three contractor
internal control audits--an accounting system audit and two billing
system audits--that were completed in 9, 13, and 15 days, respectively--
all with adequate opinions on the contractor's internal controls.
Apparently, the contracting officers involved thought these audits were
timely and met their needs because there was no audit documentation to
the contrary. However, in response to our work, DCAA has rescinded all
three of these audits. USD AT&L comments also stated, "A good audit in
time is better than an extraordinary audit that is late and never
used." Our report did not call for extraordinary audits. DOD has
determined that certain DCAA audits should comply with professional
standards. When audit organizations state that their audits comply with
professional standards, they must follow these standards. Further,
until DCAA and AT&L address the need for DCAA to perform 30,000
assignments and issue over 20,000 reports annually, DCAA will continue
to face audit quality and timeliness problems.
8. Contract audits in conformance with GAGAS. USD AT&L states that it
believes that for some reviews and financial advice provided by DCAA,
it is possible that it may not be necessary to perform GAGAS work to
support certain contracting officer functions. We agree. As discussed
in our report, a risk-based audit approach may require an appropriate
delegation of nonaudit contract administration activities and audit
responsibilities among DCMA, buying commands, finance community, and
DCAA. An effective risk-based approach would include an effort by these
communities to re-evaluate whether all such services should be provided
as audits and whether DCAA, as an independent audit organization, would
perform any nonaudit services.
USD AT&L also stated that DCAA may be able to support contracting
officer functions through an attestation review rather than a financial
audit. However, DCAA does not perform financial audits. Instead, DCAA
performs examination-level attestation audits and reports conclusions
and opinions on subject matter as a whole. Examinations provide the
highest level of assurance, and they must be based on sufficient
evidence, often referred to as positive assurance work. For an
attestation review, GAGAS require auditors to perform sufficient
testing to form a conclusion based on the work performed. It is
important to note that GAGAS prohibit auditors from performing review-
level attestation work for reporting on internal control or compliance
with laws and regulations.
9. DCAA staffing. USD AT&L stated that "the [DCAA] workforce build-up
will require years of effort to hire and train the staff required to do
the work envisioned by the GAO audit." We did not call for a build-up
of the DCAA workforce. Instead, we noted that DCAA production metrics
had a direct impact on audit quality. Therefore, it will be important
to perform a risk-based analysis of FAR requirements and determine the
mix of audit and nonaudit services that will best meet these
requirements with consideration of appropriate roles and
responsibilities of the contracting and finance communities.
[End of section]
Appendix V: Comments from the Department of Defense Inspector General:
Inspector General:
Department Of Defense:
400 Army Navy Drive:
Arlington, Virginia 22202-4704:
September 3, 2009:
Gregory D. Kutz:
Managing Director:
Forensic Audits and Special Investigations:
Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Re: GAO Draft Report, "DCAA Audits: Widespread Problems with Audit
Quality Require Significant Reform," dated July 31, 2009 (GAO Code
195099/GAO-09-468):
Dear Mr. Kutz:
Thank you for the opportunity to respond to the subject draft report.
We recognize the critical role that the Defense Contract Audit Agency
(DCAA) plays in contractor oversight inside and outside the Department
of Defense, and we take very seriously concerns about compliance with
generally accepted government auditing standards (GAGAS) by DoD audit
organizations.
Our narrative response to your recommendations are included at
Enclosure 1. As an alternative to the recommendation that this office
rescind or modify our May 2007 External Review of the DCAA Quality
Control System opinion report, we instead notified DCAA on August 24,
2009, that our May 2007 "adequate" opinion on the DCAA system of
quality control would expire on August 26, 2009 (See Enclosure 2). On
the basis of our action, DCAA has begun to qualify its GAGAS-compliant
audits with a statement noting an exception to compliance with the
Quality Control and Assurance Standard. In addition, it was recommended
that DCAA publicly disclose the concerns of your office to include
questioning the reliability of audit reports issued during the period
covered by our May 2007 opinion. Our August 24, 2009, memorandum to the
DCAA will he made public upon the release of your report.
Please contact Ms. Carolyn R. Davis at (703) 604-8877 if you have any
questions.
Sincerely,
Signed by:
Gordon S. Heddell:
Enclosures: As stated:
[End of letter]
Enclosure 1:
GAO Draft Report Dated July 31, 2009
GAO-09-468 (GAO Code 195099)
"DCAA Audits: Widespread Problems With Audit Quality Require
Significant Reform"
Department Of Defense Inspector General Comments To The GAO
Recommendations:
Recommendation 1: The GAO recommends that the Department of Defense
Inspector General (DoD IG) reconsider its overall conclusions in the
May 2007 DoD IG report on the audit of DCAA's quality control system in
which it reported an adequate ("clean") opinion on DCAA system of
quality control in light of the serious deficiencies and findings
included in that report and the additional evidence identified in our
audit. (Page 57/GAO Draft Report)
DODIG Response: Concur.
Recommendation 2: The GAO recommends that the Department of Defense
Inspector General based on the above, determine whether the report
should be rescinded or modified. (Page 57/GAO Draft Report)
DODIG Response: Nonconcur. In reference to your recommendation that we
rescind or modify our May 2007 External Review of the DCAA Quality
Control System opinion report, we have taken an alternative action that
conforms to the intent of your recommendations. The DoD IG has taken
the extraordinary action of notifying DCAA that our "adequate" opinion
on DCAA's system of quality control as detailed in the May 2007
External Review of the Defense Contract Audit Agency (DCAA) Quality
Control System report will expire as of August 26, 2009 (See Enclosure
2).
Our action recognizes that our May 2007 report was based upon a quality
review methodology that differed substantially from your audit, but
acknowledges that additional concerns about DCAA quality controls must
be addressed. On August 5, 2009, we announced a project under the title
"Evaluation of the Defense Contract Audit Agency Quality Assurance
Program" (Project No. D2009-DIPOAC-0283). The results of this
evaluation will be used in formulating our next opinion on the DCAA
external quality control system for the period ending September 30,
2009. The overall opinion will take into consideration repeated non-
compliances with Government Auditing Standards identified in our May
2007 and December 2003 opinion reports on the DCAA quality control
system. By not rescinding our May 2007 report, we can also use the
repeat deficiencies in formulating our next opinion.
Placing an expiration date on the opinion means that after August 26,
2009, DCAA will be operating without an opinion on its system of
quality control. We have recommended to the Director, DCAA, that her
agency immediately begin to qualify its GAGAS-compliant audits with a
modified GAGAS statement noting an exception to compliance with the
Quality Control and Assurance Standard. Additionally, we have
recommended that DCAA publicly disclose on its official website your
concerns, including the questioning of the reliability of audit reports
issued during the period covered by this office's May 2007 opinion.
Our May 2007 report and the GAO July 2009 draft report focused on the
period ended September 30, 2006. 1 believe it is paramount that we move
forward and critically analyze the existing DCAA environment, its
organizational effectiveness, and the quality of its recent audit work.
Given the critical mission of DCAA, we plan to focus our attention and
resources on a current analysis to yield real-time effective
recommendations to improve DCAA audit quality.
[End of Enclosure 1]
Enclosure 2:
Inspector General:
Department Of Defense:
400 Army Navy Drive:
Arlington, Virginia 22202-4704:
August 24, 2009:
Memorandum For Director, Defense Contract Audit Agency:
Subject: Review of the Defense Contract Audit Agency Quality Control
System (OIG Report No. D-2007-6-006) and GAO Draft Report, "DCAA
Audits: Widespread Problems with Audit Quality Require Significant
Reform" (GAO-09-468):
Our May 2007 External Review of the Defense Contract Audit Agency
(DCAA) Quality Control System provided DCAA with an adequate opinion on
its internal quality control system while still identifying significant
audit quality problems. However, our significant findings in 2007
coupled with the results of the July 2009 Government Accountability
Office (GAO) draft report, "DCAA Audits: Widespread Problems with Audit
Quality Require Significant Reform" (GAO-09-468), necessitates that we
take further action. We have determined that it is not prudent to allow
the adequate opinion from our May 2007 report to carry forward.
Therefore, effective August 26, 2009, our adequate opinion will no
longer apply to the DCAA system of quality control and will require
further actions on your part. Specifically, we recommend the following
be implemented immediately:
1. After August 26, 2009, all DCAA audits identified as being in
compliance with generally accepted government auditing standards
(GAGAS) must be qualified with a modified GAGAS statement noting an
exception to compliance with the Quality Control and Assurance
standard.
2. DCAA should publicly disclose on the DCAA website GAO's concerns
regarding the reliability of DCAA audit reports issued during the
period covered by this office's May 2007 opinion.
As requested by your July 30, 2009, letter to my office, we have
started preparing for the external quality control review ("peer
review") of DCAA for the period ending September 30, 2009. On August 5,
2009, we announced that project under the title "Evaluation of the
Defense Contract Audit Agency Quality Assurance Program" (Project No.
D2009-DIPOAC-0283.000). The results of this evaluation will be used in
formulating our overall opinion of the DCAA quality control system. The
overall opinion will also take into consideration repeated non-
compliances with Government Auditing Standards identified in our May
2007 and December 2003 opinion reports on the DCAA quality control
system.
This action is necessary to maintain the integrity of this office's
oversight responsibilities for audits conducted by Department of
Defense agencies. This memorandum is being distributed to the
recipients of our May 1, 2007, opinion report, and will be posted with
the May 2007 opinion report on our DoDIG website.
Please contact me or Mr. Charles W. Beardall at (703) 602-1017 or Ms.
Carolyn R. Davis at (703) 604-8877 if you have any questions.
Signed by:
Gordon S. Heddell:
cc: Under Secretary of Defense (Comptroller)/Chief Financial Officer:
[End of Enclosure 2]
[End of section]
Footnotes:
[1] GAO, DCAA Audits: Allegations That Certain Audits at Three
Locations Did Not Meet Professional Standards Were Substantiated,
[hyperlink, http://www.gao.gov/products/GAO-08-993T] (Washington, D.C.:
Sept. 10, 2008).
[2] GAO, DCAA Audits: Allegations That Certain Audits at Three
Locations Did Not Meet Professional Standards Were Substantiated,
[hyperlink, http://www.gao.gov/products/GAO-08-857] (Washington, D.C.:
July 22, 2008).
[3] Hereafter referred to as the DOD Comptroller/CFO.
[4] Under Secretary of Defense--Comptroller, Memorandum for Director
Defense Contract Audit Agency, Subject: Implementation of Corrective
Actions, (Washington, D.C.: Aug. 20, 2008).
[5] Defense Business Board, Report to the Secretary of Defense:
Independent Review Panel Report on the Defense Contract Audit Agency,
October 2008.
[6] GAO, Generally Accepted Government Auditing Standards, [hyperlink,
http://www.gao.gov/products/GAO-03-673G] (Washington, D.C.: June 2003)
and GAO-07-731G (Washington, D.C.: July 2007).
[7] In the case of follow-up audits, we also reviewed the documentation
for the previous audit to gain an understanding of the scope of work
and deficiencies identified in the prior audit.
[8] In selecting the seven DCAA offices, we considered a 2-year history
of internal control audit results. The seven DCAA offices we selected
reported adequate opinions on 89 percent or more of the internal
control reports they issued during fiscal year 2006. During fiscal year
2005, 4 of the 7 offices reported adequate opinions in 85 percent or
more of the internal control reports they issued, and the other 3
offices issued adequate opinions in 50 to 69 percent of the internal
control audit reports they issued.
[9] DCAA, Contract Audit Manual (CAM) 5-1202.1a and Defense Federal
Acquisition Regulation Supplement (DFARS) 215.407-5.
[10] FAR §§ 16.104(h) and 16.301-3(a)(1).
[11] FAR § 42.101 and DFARS § 242.803.
[12] Contractor overpayments can occur as a result of errors made by
paying offices, such as duplicate payments and payments in excess of
amounts billed, and contractor billing errors, such as using the wrong
overhead rate, failing to withhold designated amounts on progress
payments, duplicate billings, or billing for unallowable cost.
Recoveries of overpayments can be accomplished through refunds,
subsequent billing offsets, or other adjustments to correct billing
errors.
[13] Although we selected 73 assignments for review, two internal
control assignments were assist audits and two cost related assignments
were not completed assignments. As a result, we did not consider these
four assignments in our analysis, and we discuss the results of our
analysis of the 69 completed assignments that we reviewed.
[14] On August 19, 2008, at the request of the DOD Defense,
Comptroller, the Deputy Secretary of Defense established an independent
review panel under the Defense Business Board (DBB) to review DCAA
operations and make recommendations for improvements.
[15] Codified in an appendix to Title 5 of the United States Code
(hereafter 5 U.S.C. App.).
[16] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[17] GAO, High-Risk Series: An Update, GAO-09-271 (Washington, D.C.:
January 2009).
[18] GAO, Global War on Terrorism: DOD Needs to More Accurately Capture
and Report the Costs of Operation Iraqi Freedom and Operation Enduring
Freedom, [hyperlink, http://www.gao.gov/products/GAO-09-302]
(Washington, D.C.: Mar. 17, 2009); Centers for Medicare and Medicaid
Services: Internal Control Deficiencies Resulted in Millions of Dollars
of Questionable Contract Payments, [hyperlink,
http://www.gao.gov/products/GAO-08-54] (Washington, D.C.: Nov. 15,
2007); Defense Contract Management: DOD's Lack of Adherence to Key
Contracting Principles on Iraq Oil Contract Put Government Interests at
Risk, [hyperlink, http://www.gao.gov/products/GAO-07-839] (Washington,
D.C.: July 31, 2007); Hanford Waste Treatment Plant: Department of
Energy Needs to Strengthen Controls over Contractor Payments and
Project Assets, [hyperlink, http://www.gao.gov/products/GAO-07-888]
(Washington, D.C.: July 20,2007); Iraq Contract Costs: DOD
Consideration of Defense Contract Audit Agency's Findings, [hyperlink,
http://www.gao.gov/products/GAO-06-1132] (Washington, D.C. Sept. 25,
2006); Department of Energy, Office of Worker Advocacy: Deficient
Controls Led to Millions of Dollars in Improper and Questionable
Payments to Contractors, [hyperlink,
http://www.gao.gov/products/GAO-06-547] (Washington, D.C.: May 31,
2006); and Federal Bureau of Investigation: Weak Controls over Trilogy
Project Led to Payment of Questionable Contractor Costs and Missing
Assets, [hyperlink, http://www.gao.gov/products/GAO-06-306]
(Washington, D.C.: Feb. 28, 2006).
[19] GAO, Defense Acquisitions: Assessments of Selected Weapon
Programs, [hyperlink, http://www.gao.gov/products/GAO-09-326SP]
(Washington, D.C.: Mar. 30, 2009); Defense Management: Actions Needed
to Overcome Long-standing Challenges with Weapon Systems Acquisition
and Service Contract Management, [hyperlink,
http://www.gao.gov/products/GAO-09-362T] (Washington, D.C.: Feb. 11,
2009); and Defense Acquisitions: DOD's Increased Reliance on Service
Contractors Exacerbates Long-standing Challenges, [hyperlink,
http://www.gao.gov/products/GAO-08-621T] (Washington, D.C.: Jan. 23,
2008).
[20] DCAA, Contract Audit Manual (CAM), DCAAM 7640.1.
[21] Project 60 also resulted in consolidation of the military
services' contract management activities under the Defense Contract
Management Agency (DCMA), formerly the Defense Contract Management
Command (DCMC) within the Defense Logistics Agency. On March 27, 2000,
DCMC was established as DCMA under the authority of the Under Secretary
of Defense (Acquisition, Technology, and Logistics).
[22] DOD, General Plan: Consolidation of Department of Defense Contract
Audit Activities into the Defense Contract Audit Agency (Feb. 17,
1965).
[23] DODD 5105.36, paragraph 4.2, reissued on February 28, 2002.
[24] DODD 5105.36, paragraphs 5.1 through 5.14.
[25] Contract administration responsibilities are set forth in FAR
Subparts 42.2 and 42.3.
[26] CAM 2-001.
[27] Disbursing officers are authorized to make payments on the
authority of a voucher certified by an authorized certifying officer,
who is responsible for the legality, accuracy, and propriety of the
payment. 31 U.S.C. §§ 3325, 3521(a), and 3528(a).
[28] FAR § 32.503-4.
[29] CAM, 2-101. Except where stated otherwise in this report, various
types of evaluations entailing different levels of assurance that DCAA
refers to as audits--such as examinations, attestations, and reviews--
were subject to GAGAS.
[30] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §1.01, and
[hyperlink, http://www.gao.gov/products/GAO-07-731G], §1.03.
[31] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 1.11.
[32] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 6.01, and
[hyperlink, http://www.gao.gov/products/GAO-07-731G], § 6.01.
[33] [hyperlink, http://www.gao.gov/products/GAO-07-731G], §§ 2.06
through 2.10.
[34] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 2.01.
[35] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 2.10.
[36] According to documentation provided by DCAA as of the end of July
2009, the 80 rescinded reports include 62 reports related to findings
in our July 2008 investigative report and 18 reports related to this
audit.
[37] See [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.19,
and [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.10.
[38] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 6.04b.
[39] AICPA Statements on Auditing Standards, AU 350, and Audit and
Accounting Guide: Audit Sampling, §§ 3.14, 3.29-3.34, 3.58, and 3.61.
[40] GAO/PCIE, Financial Audit Manual, GAO-08-585G (Washington, D.C.:
July 2008).
[41] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 4.15.
[42] FAR §§ 16.104(h) and 16.301-3(a)(1).
[43] FAR § 42.101 and DFARS § 242.803(b)(i)(C).
[44] DFARS § 215.407-5-70; see FAR § 15.407-5.
[45] DCAA, "Audit Guidance on Significant Deficiencies/Material
Weaknesses and Audit Opinions on Internal Control Systems," 08-PAS-043R
(Dec. 19, 2008).
[46] Under its decentralized management environment, DCAA headquarters
obtains field office agreement to rescind audit reports that do not
meet GAGAS.
[47] DOD, Fiscal Year 2008 Agency Financial Report, Department of
Defense (Washington, D.C.: Nov. 17, 2008).
[48] DCAA does not perform paid voucher reviews during the year that it
performs an audit of the contractor's billing system internal controls.
[49] CAM 6-1007.
[50] AU § 350.19 and SSAE §§15.64 and 15.69.
[51] AU §§ 350.07 through 350.14.
[52] [hyperlink, http://www.gao.gov/products/GAO-08-585G], § 450.
[53] Confidence interval is the probability associated with the
precision, that is, the probability that the true misstatement is
within the confidence interval.
[54] For example, for a confidence level of 90 percent and a tolerable
rate of 5 percent, a sample size of 45 transactions would have an
acceptable number of deviations of zero and a sample size of 78
transactions would have an acceptable number of deviations of one. For
the same confidence level of 90 percent and a tolerable rate of 10
percent, a sample size of 45 would have an acceptable number of
deviations of one and a sample size of 78 would have an acceptable
number of deviations of four.
[55] The AICPA Audit Guide is an interpretive publication pursuant to
AT section 50, SSAE Hierarchy (AICPA, Professional Standards, vol. 1).
[56] AICPA Audit Guide § I-17, and AU § 350.23. Statements on Auditing
Standards (SAS) 39 is referred to as AU 350.
[57] DCAA, "Audit Program: Audit of Contractor Overpayments," (Activity
Code 17310), April 2004, September 2007, and May 2008.
[58] CAM 6-102.
[59] FAR 42.101, DFARS 242.803(b)(1)(c), and CAM 6-1007.
[60] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§ 3.03
through 3.18.
[61] Canceling funds refers to the point in time at which the
availability of a fixed-year appropriation cancels and is no longer
available for recording, adjusting, and liquidating obligations
properly chargeable to the appropriation. (31 U.S.C. §§ 1552(a) and
1553(b)).
[62] Pub. L. No. 103-62, 107 Stat. 285 (Aug. 3, 1993).
[63] [hyperlink, http://www.gao.gov/products/GAO-07-731G], §§ 3.50-
3.52.
[64] In using professional judgment, GAGAS [hyperlink,
http://www.gao.gov/products/GAO-07-731G], §§ 3.32 and 3.35, require
auditors to act diligently in accordance with applicable professional
standards and ethical principles in all aspects of carrying out their
professional responsibilities.
[65] All 10 categories of recommendations in the DOD IG's report
related to GAGAS compliance problems.
[66] DOD Inspector General, Oversight Review: Review of the Defense
Contract Audit Agency Quality Control System, Report No. D-2007-6-006
(Arlington, VA: May 1, 2007).
[67] Of the 80 rescinded audit reports, 39 reports were issued in
fiscal year 2006--the period covered in the DOD IG peer review report
on DCAA.
[68] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[69] Codified, as amended, at 31 U.S.C. ch. 75. The Single Audit Act
requires that a state, local government or non-profit organization that
expends more than $500,000 in a fiscal year undergo a single audit,
which includes an audit of the entity's financial statements and
Schedule of Expenditures of Federal Awards, as well as testing of and
reporting on certain internal controls.
[70] [hyperlink, http://www.gao.gov/products/GAO-07-731G] §§ 3.40
through 3.49, and [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[71] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.43.
[72] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 60.04a,
and [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 6.04a.
[73] [hyperlink, http://www.gao.gov/products/GAO-08-857].
[74] [hyperlink, http://www.gao.gov/products/GAO-08-857].
[75] We spoke to the auditors and reviewed documentation they provided.
To the extent that the auditors also submitted complaints to DCAA's
anonymous Web site, we reviewed DCAA's handling of their complaints.
[76] After we provided our report to DOD for comment, we received
updated information on DCAA anonymous Web site complaints. As of the
end of July 2009, DCAA had established 209 cases. Eight of those cases
were immediately referred to the DOD IG for investigation. Of the 209
cases, 82 were for the Western Region.
[77] [hyperlink, http://www.gao.gov/products/GAO-08-857].
[78] Based on audit quality problems identified in our July 2008
report, in August 2008, the DOD Comptroller/CFO conducted a tiger team
review in August 2008 and also asked the Secretary of Defense for
support in conducting a study of DCAA. With the Secretary's approval,
the DOD Advisory Panel determined that the Defense Business Board would
perform this study.
[79] On most contracting matters with DCAA involvement, the cognizant
agency contracting officer makes final decisions based on DCAA's
findings and recommendations.
[80] DCAA also established contracting officer sustention rates related
to questioned cost and net savings as an informational goal to show
return to the taxpayer.
[81] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.40.
[82] [hyperlink, http://www.gao.gov/products/GAO-07-731G], §§ 3.49-
3.52.
[83] 10 U.S.C. § 2313 and § 2306a.
[84] FAR §§ 52.214-26, 52.215-2.
[85] The Army Force Management Support Agency's mission includes
providing requirements studies and staffing analysis as well as
determining whether organizations have the appropriate staff to carry
out their mission. The Army Force Management Support Agency also
provides services to DOD components.
[86] Pub. L. No. 110-181, §1705, 122 Stat. 3 (Jan. 28, 2008), the
National Defense Authorization Act for Fiscal Year 2008, authorized the
Secretary to establish the Department of Defense Acquisition Workforce
Fund, in addition to other funds that may be available, for the
recruitment, training, and retention of department acquisition
personnel. The fund is managed by the Under Secretary of Defense for
Acquisition, Technology, and Logistics.
[87] According to a DOD Comptroller official, DCAA will receive an
additional 300 positions in fiscal year 2009 and additional 200
positions in each of fiscal years 2010 and 2011.
[88] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.38 and
AU § 339.12.
[89] Disbursing officers are authorized to make payments on the
authority of a voucher certified by an authorized certifying officer,
who is responsible for the legality, accuracy, and propriety of the
payment. 31 U.S.C. §§ 3325, 3527(c). DOD 7000.14-R, Department of
Defense Financial Management Regulation (DFMR), Vol. 5, Ch. 11 (March
2009), paras. 110102, 110203. In general, certifying officers
designated in writing by the agency are financially liable for any
improper, illegal, or incorrect payment made, and each payment made
must be audited (or "examined"). 31 U.S.C. §§ 3521(a), 3528(a). DFMR,
Vol. 5, Ch. 33 (April 2005), para. 330303. However, 31 U.S.C. § 3521(b)
authorizes heads of agencies to carry out a statistical sampling
procedure, within certain parameters, to audit vouchers when the head
of the agency determines that economies will result. Further, 31 U.S.C.
§ 3521(c) provides that certifying and disbursing officials are not
liable for payments that are not audited if they were made in good
faith under a statistical sampling procedure. See 68 Comp. Gen. 618
(1989); also see generally, GAO, Policy and Procedures Manual for
Guidance of Federal Agencies, title 7, §§ 6.5, 7.4, and 7.5
(Washington, D.C.: May 18, 1993).
[90] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[91] The Baldrige National Quality Program is named for Malcolm
Baldrige, a former Secretary of Commerce, who was a proponent of
quality management as a key to national prosperity and long-term
strength. The seven Baldrige performance excellence criteria are:
leadership; strategic planning; customer and market focus; measurement,
analysis, and knowledge management; workforce focus; process
management; and results.
[92] Codified in an appendix to Title 5 of the United States Code
(hereafter 5 U.S.C. App.).
[93] The IG Act also requires the heads of many "designated federal
entities" to appoint an inspector general for each entity. 5 U.S.C.
App. 8G.
[94] 5 U.S.C. App. § 3(a).
[95] 5 U.S.C. App. § 3(b).
[96] 5 U.S.C. App. °Þ 8F(4)(A).
[97] 5 U.S.C. App. °Þ 6(f)(1).
[98] 5 U.S.C. App. °Þ 6(a)(1), (4), and (5).
[99] As noted previously, in these cases, there was no evidence that
DCAA supervisors elevated the issue to management or to procurement
officials to initiate enforcement action, as set out in DCAA policy.
[100] 5 U.S.C. App. °Þ 5(a).
[101] GAO, Defense Contract Audits: Current Organizational
Relationships and Responsibilities, [hyperlink,
http://www.gao.gov/products/GAO/AFMD-91-14] (Washington, D.C.: Apr. 3,
1991).
[102] The Deputy Secretary of Defense is appointed by the President
after confirmation by the Senate. 10 U.S.C. § 132(a). Among other
duties as assigned by the Secretary of Defense and in statute, the
Deputy Secretary serves as the Chief Management Officer of the
department with primary responsibility for "effectively and efficiently
organizing the business operations of the Department of Defense." Pub.
L. No. 110-181, div A, title IX, § 904(a)(2) (Jan. 28, 2008). In that
capacity, the Deputy Secretary is to be assisted by a Deputy Chief
Management Officer, who also is appointed by the President after
confirmation by the Senate, and who supervises the Defense Business
Transformation Agency. 10 U.S.C. §§ 132(c), 192(e).
[103] Current provisions of law relevant to the Secretary of Defense
establishing and assigning defense agencies and defense field
activities within the Office of the Secretary of Defense include 10
U.S.C. §§ 125(a), 131(b), 191(b), 192(a), and 194.
[104] Pub. Law No. 111-23, 123 Stat. 1704, May 22, 2009.
[105] The USD(AT&L) is responsible under 10 U.S.C. § 133 for
establishing DOD policies related to the negotiation, award, and
administration of contracts, such as those related to the use of
contract audit services, and for coordinating contract audit activities
within DOD.
[106] [hyperlink, http://www.gao.gov/products/GAO-08-857].
[107] See [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 1.03.
[108] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 2.06.
[109] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.55.
[110] CAM 2-101(a) and 2-103c(1).
[111] We originally selected 39 internal control audits for our review.
Because two audit assignments were performed as assist audits to an
internal control audit in our selection, we considered these three
assignments as one audit, and therefore, we reviewed a total of 37
audits of contractor system internal control audits.
[112] [hyperlink, http://www.gao.gov/products/GAO-03-673G], Chapter 3,
especially §§ 3.03, 3.04, and 3.13-3.17.
[113] GAGAS for attestations audits related to requirements 2 through 8
are covered in [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§
6.04a; 6.13-6.14; 6.24a & c; 6.15a, and 6.16-6.20; 6.02a, 6.04b, 6.22
and 6.24; and 6.28-6.54.
[114] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.33-
3.38.
[115] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.03, and
[hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.02.
[116] See [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.19
and [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.10.
[117] [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.16.
[118] See [hyperlink, http://www.gao.gov/products/GAO-03-673G], § 3.19,
and [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 3.10.
[119] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§ 6.04a,
6.06, and 6.11.
[120] CAM 5-103.
[121] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§6.13-
6.14.
[122] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§6.13 and
6.14.
[123] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §6.15a.
[124] CAM, Figure 4-7-3.
[125] DOD Inspector General, Handbook on Fraud Indicators for Contract
Auditors, Section II.4 (IGDH 7600.3 APO, March 31, 1993).
[126] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§ 6.04b,
6.22, and 6.24a.
[127] CAM 4-600 and Appendix B.
[128] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §6.04b.
[129] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §6.24.
[130] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§ 6.04a
and 6.24e.
[131] AICPA, Standards for Attestation Engagements, AT §101.63
incorporated by reference in [hyperlink,
http://www.gao.gov/products/GAO-03-673G], § 6.01, and [hyperlink,
http://www.gao.gov/products/GAO-07-731G], § 6.01.
[132] [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 7.37.
[133] [hyperlink, http://www.gao.gov/products/GAO-03-673G], §§ 6.50 and
6.24, and [hyperlink, http://www.gao.gov/products/GAO-07-731G], § 6.24.
[134] We initially selected 34 cost-related audit assignments for
review. After reviewing the audit documentation, we determined that one
assignment only covered part of an audit and the other assignment was
terminated and the procedures were incorporated into a related billing
system audit. Therefore, we reviewed a total of 32 completed cost-
related assignments.
[135] Contractor overpayments can occur as a result of errors made by
paying offices, such as duplicate payments and payments in excess of
amounts billed, and contractor billing errors, such as using the wrong
overhead rate, failing to withhold designated amounts on progress
payments, duplicate billings, or billings for unallowable cost.
Recoveries of overpayments can be accomplished through refunds,
subsequent billing offsets, or other adjustments to correct billing
errors. Unallowable costs include lobbying cost, certain legal
expenses, executive and management bonuses, luxury items, and certain
overhead costs.
[136] REA relates to contractor requests to adjust contract terms for
rates and payments resulting from contract modifications. In the case
of the two REA audits, contract modifications related to requests for
increased hours of service and related labor and materials.
[137] FAR § 42.101 and DFARS § 242.803.
[138] FAR 52.232-25(d) was amended in October 2008 to require
contractors to monitor for and make adjustments to correct overpayments
they may receive, but it still does not specify a timeframe for making
any needed adjustments.
[139] FAR 32.606(a).
[140] DCAA, Audit of Contract Overpayments Audit Program, version 2.1,
October 2006.
[141] Although the government pays contractor invoices on a provisional
basis when they are submitted for payment, DCAA incurred cost audits
provide the basis for final approval of contractor incurred costs
claims.
[142] Questioned costs include costs questioned by DCAA auditors as
unallowable or unsupported.
[143] [hyperlink, http://www.gao.gov/products/GAO-08-857].
[144] As stated in DCAA's Contract Audit Manual, CAM 2-100, DCAA uses
the term audit to refer to a variety of audits, evaluations, reviews,
assessments, and analyses.
[145] GAO, Government Auditing Standards: 2003 Revision, [hyperlink,
http://www.gao.gov/products/GAO-03-673G] (Washington, D.C: June 2003)
and Government Auditing Standards: 2007 Revision, [hyperlink,
http://www.gao.gov/products/GAO-07-731G] (Washington, D.C: July 2007).
[146] In selecting the seven DCAA offices, we considered a 2-year
history of internal control audit results. The seven DCAA offices we
selected reported adequate opinions on 89 percent or more of the
internal control reports they issued during fiscal year 2006. During
fiscal year 2005, four of the seven offices reported adequate opinions
in 85 percent or more of the internal control reports they issued, and
the other 3 offices issued adequate opinions in 50 to 69 percent of the
internal control audit reports they issued.
[147] DCAA Contract Audit Manual (CAM) 5-1202.1a and Defense Federal
Acquisition Regulation Supplement (DFARS) § 215.407-5.
[148] FAR § 16.301-3(a)(1).
[149] FAR § 42.101, and DFARS § 242.803.
[150] In the case of follow-up audits, we also reviewed the
documentation for the previous audit to gain an understanding of the
scope of work and deficiencies previously identified.
[151] The Internal Control Integrated Framework developed by the
Committee on Sponsoring Organizations (COSO) of the Treadway
Commission, September 1993, are applicable to private sector entities.
We considered whether DCAA audits addressed contractor controls related
to the five key control activities: (1) contractor control environment;
(2) contractor risk assessment; (3) control activities, including
policies and procedures and segregation of duties; (4) information and
communication (i.e., information system processing controls); and (5)
monitoring.
[152] Contractor overpayments can occur as a result of errors made by
paying offices, such as duplicate payments and payments in excess of
amounts billed, and contractor billing errors, such as using the wrong
overhead rate, failing to withhold designated amounts on progress
payments, duplicate billings, or billing for unallowable cost.
Recoveries of overpayments can be accomplished through refunds,
subsequent billing offsets, or other adjustments to correct billing
errors. Unallowable cost include lobbying cost, certain legal expenses,
executive and management bonuses, luxury items, and certain overhead
costs.
[153] REA audits relate to reviewing contractor requests for
adjustments in billing rates pursuant to contract modifications. For
example, if a contractor is asked to provide additional services or
expand hours of service, contract costs would need to be recalculated
and adjusted rates verified. REA audits relate to audits of contractor
estimating system controls.
[154] Pub. L. No. 103-62, 107 Stat. 285 (Aug. 3, 1993).
[155] [hyperlink, http://www.gao.gov/products/GAO-03-673G], and
[hyperlink, http://www.gao.gov/products/GAO-07-731G].
[156] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-21.32.1] (Washington,
D.C.: November 1999).
[157] DOD Inspector General, Oversight Review: Review of the Defense
Contract Audit Agency Quality Control System, Report No. D-2007-6-006
(Arlington, VA: May 1, 2007).
[158] [hyperlink, http://www.gao.gov/products/GAO-03-673G], and
[hyperlink, http://www.gao.gov/products/GAO-07-731G].
[159] 5 U.S.C., App.
[160] GAO, Defense Contract Audits: Current Organizational
Relationships and Responsibilities, [hyperlink,
http://www.gao.gov/products/GAO/AFMD-91-14] (Washington, D.C.: Apr. 3,
1991).
[161] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[End of section]
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