Category Archives: Contractor Business Ethics Compliance Program and Disclosure Requirements

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What Exactly Is DCAA Thinking?

Recently, contractors have begun receiving formal requests for information from the Defense Contract Audit Agency (“DCAA”). The purported purpose of these requests is to “[o]btain an understanding of the management control environment” of major government contractors. In pursuit of this goal, DCAA has crafted a letter that demands, among other things, the following: A list … Continue Reading

The First 100 Days

Since the FAR Council’s November 2008 publication of new regulations mandating the disclosure by federal contractors of certain categories of wrongdoing and Government overpayments, there has been much ink spilled by lawyers, consultants, and the Government itself regarding what it all means.  The lack of clear definitions in the rule – notwithstanding the accompanying pages … Continue Reading

Internal Control Compliance: It’s More Than You Think

By now, everyone who has even a passing familiarity with the new “Contractor Code of Business Ethics and Conduct” clause that went into effect on December 12, 2008 knows that “internal controls” are important.  In fact, with the stakes under the new clause so high, many government contractor personnel can tell you that, under the … Continue Reading

New DCAA Guidelines Severely Restrict Auditor Authority To Exercise Judgment In Audit Of Internal Controls

On December 19, 2008 DCAA issued new guidance for audit of and reporting on internal controls that — in two short pages of sometimes cryptic text — (a) redefines the agency’s approach to the critical concepts of "significant deficiency" and "material weakness" in internal controls and (b) establishes new criteria for auditor reports of deficiencies in … Continue Reading

Glass Houses and Stones – Does Anyone in Government Ever Try to Connect the Dots?

In its 2008 report on the Government’s financial consolidated statements released on December 15, the Government Accountability Office criticized “serious financial management problems at the Department of Defense, the federal government’s inability to adequately account for and reconcile intragovernmental activity and balances between federal agencies, and the federal government’s ineffective process for preparing the consolidated … Continue Reading
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