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Government Contracting — DCAA Audit Types

The Defense Contract Audit Agency (DCAA) performs audits and financial advisory services for DoD and other federal agencies to ensure contractors comply with government cost accounting standards, pricing regulations, and contract terms. Understanding these audit types is critical for government contractors.

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Pre-Award Audits

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Pre-Award Survey

A comprehensive evaluation requested by the contracting officer before contract award to determine whether a prospective contractor has the technical capability, financial resources, accounting system, and production capacity to perform the proposed contract. Pre-award surveys assess the contractor's overall responsibility and readiness to take on government work.

Triggered by contracting officer request, typically for first-time government contractors, large dollar awards, or when concerns exist about a contractor's capability. Not routine for established contractors with proven track records.
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Forward Pricing Rate Proposal Audit

An audit of the contractor's proposed forward pricing rates (indirect cost rates projected for future periods) used in pricing new contract proposals. DCAA evaluates whether the proposed rates for overhead, G&A, fringe benefits, and other indirect cost pools are reasonable, allocable, and consistent with the contractor's cost experience and anticipated changes.

Annually or when the contractor submits new forward pricing rate proposals. Contractors with active government contracts typically submit rate proposals covering a 3-5 year forward period. DCAA schedules these audits based on risk assessment and significance of government business.
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Forward Pricing Rate Agreement

A negotiated agreement between the contractor and the government establishing indirect cost rates for use in pricing future contracts and modifications during a specified period. FPRAs streamline the proposal process by eliminating the need to negotiate rates on each individual contract action. DCAA audits support the government negotiator in establishing these agreements.

Typically negotiated annually or biennially. The FPRA is renegotiated when significant changes occur in the contractor's business base, cost structure, or when the existing agreement period expires. DCAA performs the supporting audit before each new FPRA negotiation cycle.
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Accounting System Adequacy Audit

An audit to determine whether the contractor's accounting system meets the criteria established in DFARS 252.242-7006 for adequacy in accumulating and reporting costs under government contracts. An adequate accounting system is a prerequisite for receiving cost-reimbursable, incentive, time-and-materials, or labor-hour contracts from the Department of Defense.

Required before award of first cost-type DoD contract. Subsequent reviews conducted when significant changes to the accounting system occur, when deficiencies are identified during other audits, or on a risk-based cycle (typically every 3-5 years for established contractors).
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Estimating System Audit

An audit of the contractor's estimating system to determine whether it produces reliable, consistent, and verifiable cost estimates for government contract proposals. DFARS 215.407-5-70 requires contractors with significant government business to maintain an acceptable estimating system that generates cost estimates consistent with actual costs and accounting practices.

Typically conducted every 3-5 years for major defense contractors, or when triggered by significant estimating deficiencies identified during other audits or contract negotiations. May be accelerated if proposal audit findings indicate systemic estimating problems.
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Subcontract Consent Audit

An audit performed when the contracting officer requires consent before the prime contractor can award a subcontract. DCAA evaluates the proposed subcontract cost or pricing data and the prime contractor's price analysis to assist the contracting officer in determining whether the proposed subcontract price is fair and reasonable.

Triggered by individual subcontract actions that exceed the consent threshold established in the prime contract. The threshold depends on whether the prime contractor has an approved purchasing system (higher threshold) or not (lower threshold, typically $150,000 for fixed-price, any amount for cost-type).

Post-Award Audits

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Incurred Cost Audit

An audit of the contractor's actual indirect costs incurred during a completed fiscal year, submitted through the Incurred Cost Electronically (ICE) model. This is the most common DCAA audit and determines the final indirect cost rates used to settle cost-reimbursable contracts and flexibly-priced contracts. Contractors must submit incurred cost proposals within six months of their fiscal year end.

Annual — required for every fiscal year in which the contractor has cost-type government contracts. Contractors must submit within 6 months of fiscal year end. DCAA prioritizes audit scheduling based on risk assessment, dollar magnitude, and adequacy of the contractor's submission.
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CAS Compliance Audit

An audit to determine whether the contractor is complying with the Cost Accounting Standards (CAS) applicable to its government contracts. CAS establish rules for measuring, assigning, and allocating costs to government contracts. Non-compliance can result in contract price adjustments, withholding of payments, and potential False Claims Act liability.

CAS compliance reviews are ongoing — DCAA performs focused reviews based on risk assessment, accounting changes, or triggers identified during other audits. A comprehensive CAS compliance review may be conducted every 3-5 years, with targeted reviews of specific standards conducted more frequently.
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Defective Pricing Audit

An audit to determine whether the contractor submitted accurate, complete, and current cost or pricing data in connection with a negotiated contract or modification subject to the Truth in Negotiations Act (TINA, now 10 U.S.C. 3702). If the contractor's certified cost or pricing data was defective (inaccurate, incomplete, or not current as of the date of agreement on price), the government is entitled to a price reduction.

Conducted selectively based on risk assessment, typically within 3 years of contract award or modification. Higher likelihood for large-dollar sole-source contracts, significant price increases, or when other audit findings suggest potential data integrity issues. Not applicable to contracts awarded through adequate price competition or under the TINA threshold.
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Purchasing System Audit

An audit of the contractor's purchasing system to evaluate whether it provides reasonable assurance that the contractor is obtaining materials and services at fair and reasonable prices and complying with government procurement regulations. An approved purchasing system allows higher thresholds for consent-to-subcontract requirements under government contracts.

Conducted approximately every 3 years for contractors with approved purchasing systems, or more frequently if significant deficiencies are identified. Initial review required when a contractor first seeks purchasing system approval to raise the consent threshold.
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Earned Value Management System Audit

An audit or surveillance review of the contractor's Earned Value Management System to determine compliance with the ANSI/EIA-748 guidelines. EVMS integrates scope, schedule, and cost data to provide objective measures of contract performance and early identification of cost/schedule variances on major acquisition programs.

Initial validation review for new systems or major contracts, followed by ongoing surveillance (typically annually) during contract performance. Integrated Baseline Reviews (IBRs) are conducted near contract start. Surveillance intensity is based on risk and program dollar value.
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Labor Floor Check

An unannounced verification of labor charging practices at the contractor's facility, where DCAA auditors compare employees observed at work with the labor charges recorded in the accounting system. Floor checks are designed to detect mischarging — employees working on one contract but charging time to another, or employees not present but showing charges.

Conducted on an unannounced, random basis — typically several times per year for major contractors. More frequent floor checks may be triggered by hotline complaints, other audit findings suggesting mischarging, or as part of a broader labor audit. Timing varies to prevent contractor anticipation.
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Billing System Review

An audit of the contractor's billing system to ensure that interim and final vouchers (invoices) submitted to the government accurately reflect costs incurred, comply with contract terms, and properly exclude unallowable costs. The billing system must interface accurately with the accounting system and produce invoices that match the cost data in the contractor's books.

Typically reviewed as part of the accounting system adequacy audit or on a 3-5 year cycle. More frequent reviews triggered by billing discrepancies, late voucher submissions, or findings during incurred cost audits that suggest billing system weaknesses.
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Material Management and Accounting System Audit

An audit of the contractor's system for managing and accounting for government-owned and contractor-acquired materials. DFARS 252.242-7004 establishes criteria for an acceptable MMAS that ensures accurate material cost charging, proper inventory control, and adequate property management for materials used on government contracts.

Typically reviewed every 3-5 years for contractors with significant material content in their government contracts. More frequent reviews if material-related deficiencies are identified during other audits or if the contractor's material management practices change significantly.

Special Audits

About DCAA Audits

The Defense Contract Audit Agency is the primary audit agency for the Department of Defense, performing contract audits and providing accounting and financial advisory services to DoD procurement and contract administration activities. DCAA also provides audit services to other federal agencies on a reimbursable basis.

For government contractors, DCAA audits are a fact of life. They verify that costs charged to government contracts are allowable, allocable, and reasonable under FAR Part 31 cost principles. The results of DCAA audits directly affect contract pricing, billing rates, and the settlement of cost-reimbursable contracts. Maintaining audit-ready systems and records is essential for any company with significant government business.