Those who Audit contractors on Timekeeping have their own issues.  We here at www.paulgunn.com want you to remember and understand that finding perfection in the Timekeeping environment and complying with requirements is not an exact science, but an art.

We as small contractors can only do our best as we seek guidance!  Support, documentation, and compliance with your methodology are your best defense and offense. 

 Paul Sr. 

Article from the FederalTimes.com by Elise Castelli - December 16, 2008

Some Defense Contract Audit Agency employees are concerned the agency is reverting back to practices that congressional investigators say undermined the agency’s effectiveness.
 

At issue is whether the agency continues to track the hours that DCAA auditors spend examining prices that defense contractors charge the government. DCAA is responsible for ensuring defense contractors deliver what they promised and don’t overcharge the government.  

In July, the Government Accountability Office reported that DCAA’s policy of evaluating the performance of its auditors based in part on how much time they spend on a particular contract was causing auditors to rush their work, resulting in shoddy contract oversight. At that time, DCAA would budget so many hours of auditor time per contract and auditors were expected to meet those time targets or possibly face an adverse performance evaluation. As a result, the GAO said the agency was missing or neglecting instances of over-pricing by contractors.  

Shortly after the GAO report, the head of DCAA, April Stephenson, announced the agency would no longer evaluate employees’ performance based on how fast they complete a Defense contract audit.

But the agency is continuing to track how long it takes auditors to perform their contract audits. And this has DCAA auditors nervous that, even though the information won’t be used to evaluate employees’ performance, it will nevertheless pressure them to be expedient at the expense of thoroughness.  

Some agency auditors point to a recent memo from DCAA’s assistant director for operations, Karen Cash, which directs managers to use a report to track audit hours. The report, called the Hours Roll-Up Report, was once used to track hours for performance evaluations.

According to one western region auditor at DCAA, his manager told auditors that their superior — deputy western regional director Susan Barajas — “would like to see audits come in under their budgets once in a while.”

“That comment was meant to intimidate auditors,” the auditor told Federal Times. “With few exceptions, federal employees-auditors at DCAA are very timid and just hints of dissatisfaction with their audit hours make them cringe and more acquiescent.” The auditor asked to remain anonymous for fear of reprisals. 

But DCAA denies the move is a return to old ways. The report is just the most convenient tool to ensure workers have captured the hours charged to a job, said Navy Commander Darryn James, a spokesman for the agency. Other systems used to log that information are not as user-friendly as this report, he said. “There are no [performance] goals or other measures included in this report,” James said. “It merely provides the actual hours incurred for an assignment.”  

DCAA supervisors and auditors work together to set hours based on risk of the audit, complexity of the issues and experience of the auditor, James said. They’re allowed to adjust hours to address unexpected delays and events, he said.

While budget hours are not a measure of an auditor’s performance, they could indicate performance issues if an auditor takes significantly more time to complete an audit than was budgeted or revised, James said.  

“Supervisors should be alert to situations of auditors overrunning budgets absent justifiable revisions,” he said. James admits there may be cases where some supervisors have viewed budget hours as a performance issue, rather than evaluating whether there is another cause for the overrun, he said.  

“DCAA leaders have been working hard to clarify expectations with the work force on the role of the budget hours and continue to educate on the need to perform quality audits regardless of the hours incurred,” James said. If auditors feel their supervisors aren’t acting appropriately, DCAA has an anonymous Web portalhttps://feedback.dcaaintra.mil/feedback.asp where they can report their concerns directly to headquarters. 

A second DCAA auditor, who asked not to be named for fear of reprisals, agreed with the first that nothing has changed in terms of how auditors are evaluated in the field. Part of the problem is that supervisors are still held to productivity measures, such as cost and hours, which trickles down to the field auditor level, the second auditor said.Both auditors work in the western region, which was the region under review by GAO.  

Instead of productivity measures, DCAA should develop clear qualitative measures to grade auditors on, she said.

But outside observers say there needs to be a balance.  

“There needs to be a balance between the amount of time an auditor spends on a project … depending on the risk and dollar value involved,” said Richard Loeb, a government contracts law professor at the University Of Baltimore School Of Law.

“There should be a sense of how long the audit should take, allowing an auditor to exercise judgment if he runs into problems,” said Loeb, a former Office of Management and Budget official who helped set cost accounting standards for government contracts.  

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