Thursday, April 1, 2010

Comments on DoD's Business Systems Proposal - Part IV

In today's post, we take a look at the comments submitted by The Commission on Wartime Contracting. Many of you are well aware of the work performed by the Commission in publicizing fraud, waste and abuse that DCAA and others have identified in contracts to support the war efforts in Iraq and Afganistan. Most recently, the Commission has been looking into why the drawdown of contractor support personnel in Iraq is not commensurate with troop drawdowns.

Like the DoD-IG that we covered yesterday, the Commission is wholly supportive of the proposed regulations that require DoD to withhold billings from contractors who have had one or more of their business systems determined to be deficient. The Commission writes: "Your proosed DFARS changes provide much needed clarification regarding system definition, requirements, and evaluation criteria, as well as penalties for noncompliance." The Commission believes however that the proposal will benefit if it included a coordination and feedback mechanism to enhance contractor progress and government oversight. This, in the Commission's opinion, would provide a method to resolve potential differences between contracting officers and the auditors.

The other comments included in the Commission's response were editorial rather than substantive. We would expect, given the Commission's high profile, that its position in this matter will carry great weight when it comes time to publish the final rule.

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