Under the proposal published January 19, 2012, every contractor is automatically approved for direct billing. DCAA has no say in the matter. The only interim vouchers that DCAA can review prior to payment are those "selected using sampling methodologies". This proposal represents a significant diminution of DCAA's authority and responsibility and is yet another example of how DoD is systematically dismantling its auditing arm or, as some have called "its first line of defense" against contract irregularities.
You can read the entire proposal here.
Any comments received by March 19, 2012 will be consider in the formation of the final rule.