Billing Procedures for DHS (Homeland Security) Contracts

The Department of Homeland Security (DHS) and the Defense Contract Audit Agency (DCAA) recently entered into a MOU (Memorandum of Understanding) on contract audit coverage to provide for DCAA review of interim public vouchers submitted under DHS cost reimbursement and T&M/LH contracts.

Under these new procedures, contractors must submit copies of its interim vouchers to DCAA at the same time as the original is sent to the contracting officer (or the contracting officer technical representative). The auditor has five business days to perform his/her review.

Vouchers selected for review include (i) the first voucher submitted under any contract, (ii) any voucher greater than $1 million, and (iii) a randomly selected sample of all others.

The specific steps in reviewing these vouchers consists of a seven point test including:

1. Comparison of the information shown on the voucher with the contract.
2. Verification that amounts claimed for reimbursement of indirect costs are computed using approved billing rates.
3. Verification that interim fees claimed are computed by the formula or basis in the contract.
4. Verification that billable labor costs on T&M/LH contracts have been reduced by five percent until the maximum withheld amount of $50 thousand is reached (when required by the contract).
5. Determination that the voucher has been properly prepared and that payment for the items is not precluded by any contractual provisions.
6. Test of the mathematical accuracy.
7. Reconciliation of billed costs to the contractor's accounting records.

The final test, reconciliation of billed costs to the accounting records, seems to be where the auditors spend most of their time. For contractors that prepare billings directly from accounting records, this should pose no problem.